Hello and thank you for this opportunity to come before you today. My name is 

Paul Pokrowka, I am speaking on behalf of the SMART-Transportation Division, 

a Labor Union that represents Railroad Workers across the country. I serve as 

the Pennsylvania Legislative Director & Chairman. I am here today to convey our 

concerns with the EPA's proposed Clean Power Plan. 

We are concerned and we care about this issue because of the impact this plan 

will have on our jobs and our future. 

There are ?? freight railroads in Pennsylvania which employ thousands of people. 

These are not temporary jobs, they are careers. These people, My co-workers, 

your neighbors, precious careers are in jeopardy because of the hit taken on the 

Coal industry. 

1. Nearly 40% of all freight railroad cars in America are Coal Cars. Coal has 

provided the revenues needed to build and rebuild Americas railroads. Coal 

continues to provide the money necessary to expand and maintain our rail 

infrastructure. America's railroads will spend approximately $25billion in 2014 to 

maintain and expand rail infrastructure, as well as hire 14,000 employees. 

2. 25% of the freight rail industries revenue come from the shipping of coal. The 

miners mine it, the loaders load it, and the railroaders haul it. 

3. 20% of all freight rail jobs involve hauling coal 

These are huge numbers and will have huge impacts on peoples lives and the 

American economy. 

Preliminary estimates of the impact on Jobs brought about with the EPA's 

proposed clean power rule indicate the potential loss of 52,000 permanent, 

Direct jobs by the year 2020 in the utility, rail, and coal sectors due to power 

plant retirements. When you include the indirect job losses the total increases to 

approximately 167,000 lost jobs. 

As I stated previously, these are not temporary jobs, these are not stepping 

stones, these are life changing careers. High skilled, high paying positions 

and they are typically in rural communities without other opportunities for 

comparable employment. 
We, those who work in the affected sectors of the proposed Clean Power 

Plan would like to provide you with some recommendations and topics for 

consideration. We believe these would enhance the plan in a positive manner if 

agreed upon. 

1. The plan should provide states with credit for prior C0/2 reductions as an 

option towards meeting a reasonable national target for reducing C0/2 emissions 

from the electric power sector. 

2. EPA's compliance timetable is unrealistic and unachievable, even with multiyear compliance averaging toward the interim and final targets. The initial 

reduction program should be delayed by several years to allow states and 

affected sources adequate time to prepare and submit state plans, and to 

structure and implement compliance strategies in the most flexible least-cost 

manner. 

3. EPA's proposals for major expansions of state energy efficiency and renewable 

energy programs interfere with traditional state authority in energy planning, 

and appear to be well beyond the agency's authority under the Clean Air Act. 

The Supreme Court's recent decision on the GHG permitting rule contains 

strong cautionary language that the Court will take a skeptical view of an overlyexpansive interpretation of EPA's authority to regulate greenhouse gases. 

4. We believe that the agency should reconsider the proposed rule's "building 

block" approach to set state C0/2 emissions reduction goals based on end-use 

energy efficiency, increased use of natural gas and renewable energy, as well as 

other "beyond the fence" emission reduction strategies. Rather, we urge EPA to 

focus the rule only on options for reducing emissions within the plant fence line. 

The proposed 6% efficiency improvement for existing coal units is a step in the 

right direction, but we are doubtful that all of these investments would ever be 

made given the rule's negative impact on Coal generation and new source review 

permitting. 

5. Finally, we believe that the rule is premature since we do know the extent to 

which other nations, particularly large developing countries, will be willing to 

commit to a truly global program of greenhouse gas reductions. We, America, 

cannot "go it alone" and expect that our actions will have any meaningful climate 
impact in a world economy that is using more coal and other fossil fuels every 

day. Developing nations already emit more C0/2 than advanced industrial 

nations, and the Department of Energy projects that their share of global 

emissions will grow steadily and continue to do so regardless of what the United 

States decides to do. 

Before I surrender the microphone, I want to make something clear. I love our 

environment and I am thankful for the clean air we breathe. That being said, I 

value my career on the Railroad which allows me to provide for my family. And 

without this career I am not sure how I could provide for them. As a middle class 

worker, speaking on behalf of other middle class workers, I plead with the EPA 

to listen to our recommendations and work to find a sensible, common sense 

solution that works for everyone. 

Thank you for the opportunity and for your attention. 

Paul Pokrowka 

State Legislative Director & Chairman 

SMART- Transportation Division