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TAUC submits comments to EPA on proposed carbon rule

June 4 2012

TAUC has formally submitted comments to the Environmental Protection Agency on its proposed Carbon Pollution Standard. You can read and download the comments here.

Background: On April 13, EPA issued a proposed rule setting strict carbon dioxide (CO2) emission limits for new fossil fuel-fired electric power plants. Natural gas plants will easily be able to meet the standard, but it will be extremely difficult for new coal-fired plants to do so without expensive modifications. This has led many experts to conclude that the proposed rule will act as a de facto ban on any new coal-fired plants being built in the future. Coal plants currently provide about 40% of the nation’s electricity and represent a major source of employment for TAUC contractors and their partners in the building trades.

TAUC believes EPA’s proposed rule will have a negative impact not only on our membership and the union construction industry in particular, but also on the nation as a whole. Consider the following points:

  • Higher electricity costs. In order to meet the new standard, any new coal-fired plant would have to employ some form of carbon capture and storage (CCS) technology. EPA acknowledges that deployment of current CCS technologies “results in increased capital and operating costs and decreased electricity output (that is, an energy penalty), with a resulting increase in the cost of electricity. The energy penalty occurs because the CO2 capture process uses some of the energy produced from the plant.”
  • Massive job losses. Maintenance and installation of environmentally friendly technologies at coal-fired power plants represent a significant source of work for union contractors and the building trades. EPA’s proposed rule – with its emphasis on expensive and largely untested CCS systems – would essentially phase out coal by discouraging construction of new coal-fired plants. As existing coal facilities age, utilities may be forced to take them offline rather than build replacement coal plants. This would lead to less overall capacity to meet growing electricity demand. It would also result in the permanent loss of countless thousands of union jobs.
  • Carbon capture and storage (CCS) technology is unproven and untested. EPA argues that (1) coal plants can meet the new standard by employing CCS systems, and (2) that the cost of CCS will decrease over time as its use becomes more widespread; thus, if a utility decides to build a new coal plant at some point in the near future, the economic penalty will not be so severe. However, there are several problems with this argument. In a nutshell, CCS involves first capturing CO2 from industrial gas streams and then “sequestering” it, usually by pumping it into geologic formations found deep underground (and the CO2 must also be transported from the power plant to the sequestration site via pipeline). Although theoretically feasible, CCS – aside from being extremely expensive – is still in the very early stages of development, and there are few large-scale CCS systems in operation, either in the U.S. or elsewhere in the world. Thus there is very little hard data to back up CCS supporters’ claims. Numerous questions remain regarding the long-term viability of CCS, especially the logistical, technical and environmental hurdles associated with not only capturing and transporting CO2, but pumping (potentially) billions of tons of carbon into deep-rock chambers. TAUC believes that CCS should not be touted as a “silver bullet” to allay the concerns of proponents of coal-fired power. This untested and still maturing technology should not be the cornerstone of a major government regulation.
  • The U.S. should not abandon coal as an energy source. The U.S. contains massive coal reserves – enough to last 200 years, according to some estimates – and has been referred to as the “Middle East of Coal.” Given this simple fact, it makes no sense for EPA to create a carbon emissions standard that would effectively phase out coal-fired plants over time. TAUC believes the country should maintain a “diversified portfolio” of energy options, and that includes coal as well as natural gas. Both can and should be important resources as we move into the 21st century. However, it is unwise to rely too heavily on any single source of energy. Like any other commodity, natural gas is susceptible to fluctuations in supply, demand and price – not to mention the specter of additional environmental and drilling regulations, which could have a serious impact on future production.
  • If the U.S. doesn’t use the coal, other countries will. EPA’s proposed carbon emission standard would sound a death knell for coal-fired power plants. However, this does not mean the coal will stay in the ground. Instead of selling it to U.S. utilities, coal producers will simply export their product to foreign countries, where demand for energy is at an all-time high. Many of these countries have far less stringent environmental regulations than the U.S. Ironically, then, EPA’s carbon emission standard will ultimately result in more air pollution, not less.


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