WMA Comments on Proposed EPA Emissions Standards

(Wyoming Mining Association, July 29) – DENVER, CO – Comments of the Wyoming Mining Association On Proposed Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units

The Wyoming Mining Association is a statewide trade organization that represents and advocates for 39 mining company members producing bentonite, coal, trona and uranium, as well as one company developing rare earth minerals.  WMA also represents 129 associate member companies, two railroads and 180 individual members.

Wyoming leads the nation in coal production, mining nearly 400 million tons of annually.  In addition, Wyoming is the single largest net producer of energy for the nation.  While Texas produces slightly more energy than Wyoming, it consumes more than its production.  Wyoming exports almost 10 trillion BTU’s per year to the rest of the nation for use in power plants, automobiles, homes and factories.  Most of that energy is from coal.

Recently announced stringent Environmental Protection Agency (EPA) emission standards on existing stationary electric utility generating units require states to submit plans to reduce their power-sector CO2 emissions by 26-27% by 2020 and 30-32% by 2030 as compared to 2005 levels.  Whether or not EPA has the authority to regulate CO2 emissions from existing coal-fueled electric generators is yet to be determined.

In effect, the EPA, has placed a de facto ban on older coal-fired plants, while not allowing for new technologies to come online to reduce emissions.  It has essentially eliminated coal as a future source of electricity for our nation.

Coal currently accounts for nearly 20 percent of America’s electricity generation, and the question of what will make up the megawatt difference once existing plants are retired has largely gone unanswered.  But aside from this problematic scenario, there will be real and tangible effects for every citizen.

If the agency’s decision on existing and future plants is an indicator of future action, WMA has serious concerns.  This continued uncompromising effort to end coal as a viable energy source for America has very real consequences for real people in Wyoming and around the country.

In Wyoming, real people rely on extraction industries to fund our state and local governments.  Revenues from coal mining alone account for over $1 billion annually in taxes, royalties, fees and Abandon Mine Lands funds.  This keeps the tax burden for Wyoming citizens low.  Among other things, these revenues fund schools, the University of Wyoming and community colleges, highways, and cities and towns.  Monies derived from coal are a key reason as to why Wyoming people are not burdened with a state income tax.

In the past two decades bonus bids paid to the state by coal companies on federal coal lease sales, totaling over $2.6 billion since 1992, have built new schools in every county in Wyoming.  Regretfully, the uncertainty caused by EPA’s regulatory regimen contributed to the collapse of the two most recent lease sales, costing Wyoming millions.  The federal government also lost out, as those bonus bids as they are shared equally.

WMA estimates that every coal mining job supports three more jobs around the state in the form of service and supply employment.  If we continue on EPA’s current regulatory path, the coal industry and our economy will necessarily contract due to restrictions placed on utilities and the choking off of export opportunities.  The elimination of the industry’s customers and markets will cause job losses here at home.  Real people will be hurt.

Finally, Americans everywhere will feel the crunch of rising electricity costs.  These rising bills will affect America’s economic competitiveness at a time when the economy is still in a soft recovery from the great recession.  According to the U.S. Chamber of Commerce, the cost of these new regulations will be $51 billion in annual economic losses and 224,000 Americans losing their jobs.  This isn’t acceptable.

Coal is America’s most abundant, reliable and affordable energy source.  Yet, the choice has been made to deliberately put it off limits, playing favorites for costly, heavily subsidized and unreliable resources to blindly advance the president’s environmental program.  Utilities will face issues from over-reliance on natural gas and the innate inability and undependability of renewables meet generation needs, while passing along the cost at the expense of consumers.

Again, here lies the real crux of the matter: the elimination of coal as a source of electricity generation through oppressive regulation hurts real people in the form of job losses, higher utility bills and a lower standard of living for little to no benefit to public health, reduction in global emissions, or lowering of perceived global temperature hikes.  This is a lose-lose situation for America.

The facts speak for themselves, but are often lost in the gamesmanship that accompanies the implementation of political agendas.  According to the EPA’s own data, coal based power generation in the United States has increased 170 percent since 1970, while emissions of the pollutants originally regulated under the Clean Air Act have decreased over 85 percent.  This remarkable success has been achieved by common sense regulation and timely advances in technology.  There is every reason to expect this trend will continue in respect to carbon dioxide.

State-of-the-art coal-burning plants in Illinois and Arkansas are proof today that coal can continue to be used more cleanly and efficiently than ever before.  The technology will continue to improve, viable carbon capture and storage will come online in time, and performance of current and future plants will become even better.  But not under arbitrary, costly and unattainable standards and timelines.

WMA appreciates the opportunity to be here to comment today, and we respectfully urge the agency to fully consider the real impact of its actions on the American consumer and taxpayer, jobs and affordable energy in developing CO2 emissions rules for the existing coal fire fleet.  WMA also urges EPA to consider holding additional listening sessions in coal producing states and rural America to hear from those most directly affect by its actions.