Good morning, I am Don Vickers, Regional Vice President for Northern Appalachia operations of 

Arch Coal, Inc. Our company is one of the world's largest coal producers, selling 131 million tons of coal 

in 2013, which represents about 14% of total U.S. coal supply. Arch Coal operates mines in Wyoming, 

Colorado, Illinois, Kentucky, Virginia, Maryland and West Virginia — covering each of the major coalproducing regions of the U.S. 

I wish to comment on three of the reasons why the Clean Power Plan as proposed by EPA is 

flawed. These reasons are 

1) No discernible climate impact 

U.S. power plants are responsible for only four percent of global Green House Gas GHG 

emissions and EPA's proposal will reduce those emissions by less than a percent. If the 

United States totally eliminated coal-powered electric generation by 2017, the result would 

be a 1 percent reduction in atmospheric CO2 concentrations and a 1/50th of one degree in 

warming in the year 2050. 

2) Costly economic impact 

The EPA estimated the cost for carbon regulation to be between $4.2 billion and $8.8 billion 

per year. In exchange for reducing coal utilization for power generation, the American 

consumer will have to suffer rising electricity prices and reduced electric grid reliability. 

EPA estimates that its proposal will increase electricity prices between six and seven percent 

nationally in 2020. While the nationwide average increase looks relatively small, it masks 

substantially higher increases in individual states. These increases will fall 

disproportionately on middle class and lower income families that can least afford it. The 

increases will also place an immense burden on U.S. businesses which employ those 
Americans, businesses which depend on affordable energy to provide a critical operating 

advantage in competitive global markets. 

3) Threat to low-cost, reliable power 

Power generators' transform our abundant, affordable and reliable coal into a low-cost, 

stable flow of electricity on which the U.S. economy has been built — an economy which will 

be jeopardized by EPA's proposal. This proposal increases the share of electricity generated 

from natural gas, which has a variety of alternative markets outside the power-generation 

sector. Natural gas is delivered to power plants via pipeline systems on a just-in-time basis 

and as witnessed during this past severe winter, delivery on particularly cold days can be 

constrained. In short, a dramatic move away from coal threatens the reliability of the 

electric power system. In addition, the rapid retirement of coal-fueled plants will further 

strain reliable, base load power availability. The Midcontinental Independent Systems 

Operator (MISO), which operates in the middle of the country, reports that it already faces a 

generation short-fall due to a previous EPA rule known as MATS. Federal Energy Regulatory 

Commission (FERC) Commissioner Moeller concluded that the electricity sector is now 

"living on the edge ... if we have a hot summer in 2016, we could have rolling blackouts in 

MISO by 2016." 

In summary, EPA's proposal has no effective impact on reducing GHG emissions, imposes higher 

cost electricity on U.S. households and industry, and reduces the reliability of the grid. For these 

reasons, Arch respectfully requests that the agency withdraw its proposed plan. Thank you for your 

time and attention. 

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