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USEA Presentations and Articles
Recent Speeches and Presentations by Barry Worthington, USEA Executive Director
Clean Coal, The Energy Investment Forum
Barry K. Worthington, Executive Director, United States Energy Association
January 26, 2012
UJAE Presentation on EPA Regulations
The final MACT and CSAPR regulations have been the subject of much analysis since they were finalized in 2011. Gene Trisko, General Counsel to Unions for Jobs & The Environment, presented his perspectives to the Board of Directors on January 24, 2012.UJAE is an association of 12 national labor unions, including the IBEW, Mine Workers, Boilermakers, Utility Workers and most other coal-related energy unions.
The presentation is publicly available at www.ujae.org. There are many issues with the regulations for coal fired generating plants and states but the presentation highlights these major ones:
1. The MACT standards for future plants are supposed to reflect the performance of a group of best performing units. But the final MACT standards for new units are so stringent that coal is effectively eliminated as an option for future generation. AEP’s comments on the proposed rule analyzed new coal units built since 2001 and determined that based on the air permit limits for these 40 newest units, none could meet all of the new source standards. EPA statements that the Logan co-gen plant can meet the standards has yet to be proven.
2. Is CSAPR really needed? Air monitoring data available at the Midwest Ozone Group web site shows that the objectives of CSAPR have already been
achieved by states. In December, 2011, IN, OH, LA, TX and WV
environmental commissioners said the rule wasn't needed to address interstate transport in the OP ED they published in the Ft. Wayne Journal Gazette on December 22, 2011.
http://www.journalgazette.net/article/2011312229984.
3. EPA's MATS compliance deadlines are inadequate for all the required pre-construction and construction retrofit activities. The Fair Compliance Act introduced by Senators Manchin (WV-D) and Coats. (IN-R) with it's federally legislated timeline is an example of a good solution.
4. EPA has published suspect job and plant retirement figures. MATS is projected to create between 31,000 and 40,000 construction jobs according to EPA's Regulatory Impact Analysis based on EPA's revised downward projection from 9.9GW to 4.7GW of plant closures. EEI's latest plant closure map shows 48GW of retirements were announced through December 2011, and studies show thousands of associated job losses. EEI revised the announced retirement figure to 50GW on January 26, 2012.