EPA Public Hearing - Statement by Betsy Monseu 7-30-14
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Environmental Protection Agency Public Hearing

Docket ID No. EPA-HQ-OAR-2013-0602

Statement of Betsy Monseu, CEO, American Coal Council

(5 minutes)


July 30, 2014


My name is Betsy Monseu, and I am CEO of the American Coal Council (ACC). The ACC has been in existence for 32 years and represents the collective business interests of the American coal industry. Our members include coal suppliers, transportation companies, terminals, electric utilities, industrial consumers, and industry support services providers. They touch every aspect of turning one of America’s most abundant resources into reliable and affordable electricity for the United States economy. I appreciate the opportunity to address the Environmental Protection Agency’s (EPA) proposed Clean Air Act Section 111(d) rule for greenhouse gas emissions from electric generating units. The rule is lengthy, complex, and far-reaching. Its implementation would cause serious economic harm, reduce energy diversity, increase electricity prices, jeopardize electric grid reliability, result in major job losses, and hinder coal technology advances. Moreover, it will fail to achieve the Administration and EPA’s goal of global leadership on CO2.

The EPA §111(d) rule will not meaningfully impact global CO2 emissions. It will, however, alter U. S. energy policy and manipulate our energy mix. It will predispose fuel choices for electricity providers and dramatically transform how electricity is generated, distributed, transmitted, and used.

In ACC’s comments to EPA on its §111(b) rule for carbon for new fossil plants, we discussed the spikes in natural gas prices and corresponding increased electricity costs during the harsh winter of 2014. The winter was a stark reminder of how quickly and dramatically energy and electricity markets can change. Many of the same coal plants which were essential in meeting electricity needs and avoiding brownouts or blackouts during the winter are planned for shutdown beginning in 2015 due to EPA’s MATS rule.[1] As a result, concerns over resource adequacy, grid reliability, and electricity pricing have been expressed by a chorus of elected officials, policymakers, regulators, industry, and consumers. EPA’s proposed §111(d) rule greatly intensifies the concerns. This regulatory path to diminish coal and force an increase in natural gas is at odds with robust, competitive energy markets and affordable, reliable electricity in America.

From an economy-wide perspective, the projected impacts are staggering. In May 2014, the U.S. Chamber of Commerce analyzed similar carbon emissions scenarios with the following results through 2030[2]:

1)   Lowering of U.S. GDP by $51 billion per year

2)   Loss of 224,000 jobs per year

3)   Electricity cost increases of $289 billion

4)   Lowering of total disposable income for households by $586 billion


Unfortunately, the toll would be greatest on the poor, the elderly, small businesses, and domestic manufacturing.


We have only to look at the recently-repealed carbon tax in Australia for a reality check. It cost the economy $8.5 billion annually and increased electricity costs to families by over $500 per year.[3]


EPA’s §111(d) rule would impose tremendous pain with no gain. It will not meaningfully impact either U.S. or global CO2 levels. The same U.S. Chamber of Commerce study estimated that the resulting U.S. carbon reductions represent only 1.8 percent of global CO2 emissions, which the International Energy Agency projects will otherwise grow by 31 percent.[4] Unilateral U.S. mandates to decrease carbon emissions will not spur other countries to take action, especially developing countries. They will not risk increasing basic energy costs, suppressing economic growth, and limiting the ability to improve the standard of living for their citizens.


U.S. global climate leadership should instead be demonstrated by a strong federal commitment to technology. Coal was the world’s fastest growing fuel over the past decade, and is projected to surpass oil as the largest energy source in the future.[5] Advancing the development of cost-effective coal technologies is the critical path to their global adoption.


EPA’s proposed §111(d) rule is unworkable. It should be significantly revised or withdrawn to avoid the economic harm, job loss, heavy administrative burden, and lack of benefits of proceeding. ACC requests EPA take the following actions now:

1)   Add public hearings, especially in coal producing states and states most reliant on coal generation such as West Virginia, Kentucky, Ohio, Indiana, Missouri, Wyoming, and Utah.

2)   Provide interactive forums for stakeholders to address questions with EPA.

3)   Extend the 120-day comment period by at least 60 days.

4)   Continue and increase engagement with states, and with other agencies including the Federal Energy Regulatory Commission (FERC), the North American Electric Reliability Corporation (NERC), and the Department of Energy (DOE).

Thank you for your attention.



[1] http://www.eia.gov/todayinenergy/detail.cfm?id=15031

[2] U.S. Chamber of Commerce - http://www.energyxxi.org/sites/default/files/file-tool/Assessing_the_Impact_of_Potential_New_Carbon_Regulations_in_the_United_States.pdf

[3] http://dailycaller.com/2014/07/17/aussie-lawmakers-vote-to-repeal-carbon-tax/

[4] U.S. Chamber of Commerce - http://www.energyxxi.org/sites/default/files/file-tool/Assessing_the_Impact_of_Potential_New_Carbon_Regulations_in_the_United_States.pdf

[5] BP Statistical Review of World Energy, June 2013; International Energy Agency, World Energy Outlook 2013