paceenergyfairness.org Partnership for Affordable Clean Energy P.O. Box 70072 • Montgomery, AL 36107 • 334.294.9673 June 17, 2011

The Honorable Lisa Jackson Administrator U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Washington, DC 20460

Dear Administrator Jackson: As organizations located in the Southeast, a region whose economy depends heavily on the availability of affordable, reliable electricity, we write to you to express our concern with the National Emissions Standards for Hazardous Air Pollutants From Coal- and Oil-Fired Electric Utility Steam Generating Units, otherwise known as ‘Utility MACT.’ We believe these rules, if implemented within the stated timelines and with the stringency we believe is likely, will weaken industry in our region, cause job losses, and hurt power consumers. As you are aware, study suggests that EPA’s Utility MACT rules will affect 1,350 coal and oil-fired units at 525 power plants across our nation. You may also be aware that the North American Electric Reliability Corporation (NERC) reports that by 2018 nearly 50,000 MW of generating capacity will be forced into retirement by these new regulations. In the end, nearly half of America’s electricity portfolio will either shut down altogether or undergo expensive upgrades. In either case, businesses and consumers will bear the cost. Our fear is that the Southeast will be particularly vulnerable to the consequences of Utility MACT rules. Our region remains the last bastion of heavy manufacturing, with hundreds of thousands of jobs and billions in economic impact that rely on the success of manufacturing. In this atmosphere, skilled labor has thrived and foreign manufacturing investment has flourished. Our region also relies more intently than others on coal-fired power generation. These two features are not coincidental; in fact, they are inextricably linked. The availability of abundant, reliable, and inexpensive electricity from America’s native coal resources has fueled this success. The cost estimates of Utility MACT are difficult to predict. EPA itself reports a compliance price tag of $10.9 billion, making this regulation one of the most expensive in the agency’s history. This is twice the cost of current regulations that reduce sulfur and nitrogen oxide emissions. Other estimates include an Energy Information Administration report of $358 billion and an estimate from Representative Upton and Senator Inhofe of more than $300 billion by 2015. No matter the study, it is clear that Utility MACT will impose daunting costs not only to the electric utilities that will bear them directly, but also to the businesses, workers, and families who will bear them indirectly. For example, the American Coalition for Clean Coal Electricity estimates electricity price increases from Utility MACT could be as high as 24% in some regions, or between $400 and $500 in annual buying power for the average family. This at a time when American families are struggling to survive and so many have no job at all. Moreover, many in the energy industry could lose their jobs directly due to the coal-fired capacity losses under Utility MACT. Many of these losses in the energy sector will be felt within the Southeast’s borders. Put simply, we believe that the closure of significant numbers of coal-fired plants in the Southeast due to Utility MACT will mean economic setbacks for our region and strike a blow to manufacturing in one of the only regions in the United States where heavy industry is viable. We believe Utility MACT will mean the loss of high-paying, high-skill jobs and the advent of drastic price increases for consumers who cannot bear them in this economy. We also believe that Utility MACT will weaken reliability by removing a trusted baseload resource of electricity. The agency should recognize the tremendous gains our nation has made in this area, including the fact that our nation is producing 55% more electricity than we did just twenty years ago, with fewer toxic emissions. In fact, the use of coal to meet electricity demand has tripled since 1970 and yet emissions are still down. We can have a future that utilizes our nation’s vast supply of coal and also achieve gains in controlling emissions, but we fear that Utility MACT could make such a future impossible. 1 EPA has an opportunity to avoid these negative outcomes by establishing reasonable and realistic standards and timelines for controlling emissions from coal-fired generation. We believe the current compliance deadline of three years set by the agency meets neither the test of reasonability nor realism. For this reason, we join together to ask EPA to delay indefinitely its proposed Utility MACT rule until further study can be undertaken on the potential costs and negative incomes to industry, jobs, and consumers in the Southeast and across our nation. Sincerely,

Lance Brown William J. Canary Stewart Burkhalter PACE Business Council of Alabama Alabama AFL-CIO

Deborah Woolley George Clark Blake Wilson Tennessee Chamber of Commerce Manufacture Alabama Mississippi Economic Council

G.L. Bowen, III Jay C. Moon Casey Shelton Georgia Association of Manufacturers Mississippi Manufacturers Association IBEW System Council U-19

Cline Jones Charles Steele, Jr. Larry Merrihew Tennessee River Valley Association Working People for Fair Energy Coalition of AL Waterway Associations

Richard Holland Leigha Cauthen Roy McAuley Tennessee Paper Council Alabama Agribusiness Council Alabama Pulp and Paper Council

Ernie Glenn Daryl Dewberry Bryan Tolar Alabama Iron and Steel Council United Mine Workers of America, Dist 20 Georgia Agribusiness Council

Chip Koplin Richard Ray Chris Clark Georgia Recyclers Association Georgia AFL-CIO Georgia Chamber of Commerce

Rudy Underwood Patti Gettinger John Poole American Chemistry Council Georgia Tea Party Georgia Paper and Forest Products Association

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