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 thoseAmericans, 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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