Virginia Attorney General Kenneth Cuccinelli testified yesterday before the House Committee on Oversight and Government Reform on the Obama Administration's proposed Maximum Achievable Control Technology (Utility MACT) regulation.

http://EnergyTomorrow.org The EPA's role is to develop regulations based on science from laws passed by Congress to protect human health and the environment. However, with its proposals to toughen ozone standards and regulate greenhouse gases and its premature approval of E15, the EPA is now moving beyond its mandate into a political agenda that is not based on realistic science. While the U.S. needs to protect the environment, it's time for EPA to stop overreaching its authority. It could ultimately cost millions of American jobs, increase energy costs, and put U.S. businesses at a competitive disadvantage in the global race for energy.

For more information, visit http://EnergyTomorrow.org.



1. Is Utility MACT likely to be a costly rule in terms of jobs?

Answer: Utility MACT will undermine job creation in the United States in several different ways. It will result in retirement of a significant number of power plants and either fail to replace that capacity or replace it with less labor-intensive forms of generation. It will increase the cost of power, undermining the international competitiveness of almost two dozen manufacturing industries, and it will reduce employment upstream in the mining sectors. All told, it is anticipated that the rule will result in the loss of some 1.44 million jobs by 2020. While some jobs are created by complying with the new rule, the number and quality of those jobs is far less than those destroyed. We estimate that for every one temporary job created, four higher-paying permanent jobs are lost. The bottom line: this rule is the most expensive air rule that EPA has ever proposed in terms of direct costs. It is certainly the most extensive intervention into the power market and job market that EPA has ever attempted to implement.

On January 24, 2012, Gene Trisko, the General Counsel to Unions for Jobs and The Environment, made a presentation to the UJAE Board of Directors, which analyzed the basis and effect of USEPA’s final utility MACT and CSAPR rules. UJAE is an association of 12 national labor unions, including IBW, Mine Workers, Boilermakers, Utility Workers and most other coal related energy unions. For a copy of Trisko’s presentation, click here.

Key points raised by this presentation are:

(1) The MACT standards for future plants are supposed to reflect the performance of a group of best performing plants; however, the final MACT standards for new plants are so stringent that coal is effectively eliminated as a fuel option for future generation. This portion of the presentation was based on the comments of American Electric Power submitted on August 4, 2001 with respect to the proposed MACT rule, which analyzed new coal units built since 2001 and determined that based on air permit limits for these 40 newest units, none could meet all of the new source standards. For a copy of AEP’s comments, click here.

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