Listening sessions held by the Department of Environmental Protection around the state are gathering comments on EPA’s Clean Power Climate Plan to help Pennsylvania develop a plan for meeting those requirements.
Ron Stipanovich of the United Mine Workers of America International Union presented these comments at the September 22 session--
Good evening. I am Ron Stipanovich of the United Mine workers of America International Union. We appreciate the opportunity that DEP has provided for these listening sessions on U.S. EPA’s final Clean Power regulations.
EPA’s final regulations require Pennsylvania fossil generation units to achieve a 35 percent reduction of emissions of CO2 per Megawatt-hour of generation by 2030 compared to 2012 emissions.
The final rule also gives Pennsylvania the option of meeting tonnage-based targets. Pennsylvania would need to reduce its emissions from 117 million tons of CO2 in 2012 to 90 million tons by 2030, or 23 percent.
Here is our central point: Pennsylvania should not submit a final “trade-ready” state plan to EPA on September 6, 2016. Pennsylvania is not required to do so. EPA will provide a two-year extension to September 2018 for the submission of a final plan. Pennsylvania should submit an extension request to EPA on September 6, 2016.
In the meantime, Pennsylvania DEP, in consultation with the legislature and affected stakeholders, should work out the details of the “Pennsylvania=centric” plan that DEP advocates in its notice for these hearings. This may, or may not, involve a cap-and-trade program like EPA’s model trading rule.
The UMWA strongly urges this course of action because the stakes are too high for Pennsylvania’s coal-based industries, communities, and workers.
Coal production in Pennsylvania in 2013 accounted for 39,800 direct and indirect jobs, $7.7 billion of state gross domestic output, and nearly $2 billion of annual household income.
These direct jobs are all high-paying jobs, typically in rural communities near mines and power plants.
A recent study of EPA’s Clean Power Plan by the Economic Policy Institute show that the jobs lost as a result of the rule will be concentrated among unionized, high-wage, high-skilled workers. Those gaining jobs will tend to be in nonunion, lower-wage sectors.
EPA projects that total U.S. coal-generating capacity will decline from 336 Gigawatts in 2012 to 174 Gigawatts in 2030, a reduction of 52 percent.
EPA also projects that steam coal production in the Appalachian region, from Pennsylvania to Alabama, will decline by 70 percent from 2009 to 2025.
These are grim statistics for Pennsylvania’s coal miners and their families and communities.
A basic problem that the EPA rule poses is that much of the electricity generated in Pennsylvania is exported to other states. We cannot shape the compliance actions of these states. But we can set our own goals to meet EPA’s targets in a manner that is least harmful to our economy and jobs.
In this regard, we are concerned that a multi state cap-and-trade program could potentially inflict more damage to Pennsylvania than an in-state compliance plan.
DEP’s plan should carefully balance the interests of Pennsylvania stakeholders and our diverse array of energy resources-- coal, natural gas, nuclear, renewables and energy efficiency.
We also urge DEP to consider incentives to advance carbon capture technology in the context of a “Pennsylvania-centric” compliance plan.
The UMWA does not object to EPA’s regulation of greenhouse gases under the Clean Air Act. The (U.S.) Supreme court settled that issue in 2007. We disagree, however, with EPA’s expansive exercise of its regulatory authority in this rule.
That is why the UMWA will join with other unions, states and affected industries in challenging the rule when it is published in the Federal Register next month (October).
The many legal uncertainties surrounding this rule are another major reason for DEP to proceed cautiously in its submission to EPA in September 2016.
Thank you.
For more information and a schedule of the remaining sessions, visit DEP’s Climate Change webpage. Comments on the Clean Power Plan can be submitted online. Click Here to see comments submitted by others so far.
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