Hello and thank you forthis opportunityto come before you today. My name is Paul Pokrowka, I am speaking on behalfofthe SMART-Transportation Division, a Labor Union that represents Railroad Workers across the country. I serve as the Pennsylvania Legislative Director 

### & Chairman. Iam here todayto convey our concerns with the EPA's proposed Clean Power Plan. We are concerned and we care aboutthis issue because ofthe impactthis plan will have on ourjobs and ourfuture. There are 

### ?? freight railroads in Pennsylvania which employthousands ofpeople. These are nottemporaryjobs, they are careers. These people, My co-workers, your neighbors, precious careers are in jeopardy because ofthe hittaken on the Coal industry. 1. Nearly40% ofall 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 necessaryto expand and maintain our rail infrastructure. America's railroads will spend approximately$25billion in 2014to maintain and expand rail infrastructure, as well as hire 14,000 employees. 2. 25% ofthe freight rail industries revenue come from the shipping ofcoal. The miners mine it, the loaders load it, and the railroaders haul it. 3. 20% ofall freight rail jobs involve hauling coal These are huge numbers and will have huge impacts on peoples lives and the American economy. Preliminary estimates ofthe impact on Jobs brought about with the EPA's proposed clean power rule indicate the potential loss of52,000 permanent, Directjobs bythe year 2020 in the utility, rail, and coal sectors due to power plant retirements. When you include the indirectjob losses the total increases to approximately 167,000 lostjobs. As Istated previously, these are nottemporaryjobs, these are not stepping stones, these are life changing careers. High skilled, high paying positions and theyare typically in rural communities without other opportunities for comparable employment.We, those who work in the affected sectors ofthe 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 mostflexible least-cost
manner. 3. EPA's proposals for major expansions ofstate 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 askeptical view ofan overlyexpansive interpretation of EPA's authorityto 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 plantfence line. The proposed 6% efficiency improvementfor existing coal units is a step in the right direction, but we are doubtful that all ofthese investments would ever be made given the rule's negative impact on Coal generation and new source review permitting. 5. Finally, we believe thatthe rule is premature since we do knowthe extentto which other nations, particularly large developing countries, will be willingto committo atruly global program ofgreenhouse gas reductions. We, America, cannot "go it alone" and expect that our actions will have any meaningful climateimpact in aworld economythat is using more coal and otherfossil fuels every day. Developing nations already emit moreC0/2 than advanced industrial nations, and the Department of Energy projects thattheir share ofglobal emissions will growsteadilyand continue to doso regardless ofwhat the United States decides to do.

Before Isurrenderthe microphone, I want to make something clear. I love our environment and Iam thankful forthe clean air we breathe. That being said, I value mycareer on the Railroad which allows me to provide for myfamily. And withoutthis career Iam notsure how I could provide forthem. As a middle class worker, speaking on behalfofother middle class workers, Iplead with the EPA to listen to our recommendations and workto find asensible, common sense solution that works for everyone. Thankyou for the opportunity and for your attention.

Paul Pokrowka State Legislative Director 

### & Chairman SMART- Transportation Division