Already, operators have announced plans to shutter 30 gigawatts of coal plants, about 10 percent of the nation's capacity, by 2016.
M.J. Bradley's Van Atten said that based on discussions with industry officials and analysts, many of those closures wouldn't be reversed even if EPA regulations vanished tomorrow. "There are some clear situations where the retirement of a plant is driven by regulations or you can tease out exactly what the cause was," he said. "But in many cases it's a combination of these factors."
A July report by the Bipartisan Policy Center, a nonpartisan think tank, tried to tease out the exact impact of EPA policy on coal's decline. It estimated that about 30 percent of projected coal retirements of 56 gigawatts by 2016 would be tied to pollution rules. The rest, it found, would be due to low natural gas prices, shrinking demand for power and the rising share of renewable energy in electricity generation.
Coal Caught in Election-Year Politics
The coal industry's future has emerged as a major storyline in this year's election—not a surprising development given the size of the industry and its prominence in battleground states like Ohio, West Virginia and Kentucky. Romney in September released a trio of ads centered on Obama's alleged "war on coal." He has also used coal factories as rally sites. At a Saturday appearance in Portsmouth, Ohio, he declared, "We have a lot of coal, we're going to use it."
Lisa Camooso Miller, a spokesperson for the American Coalition for Clean Coal Electricity, an industry lobbying arm, told InsideClimate News it's "not an accident" that Romney is painting Obama as an enemy of coal, because industry polls suggest the issue could turn moderate Democrats against the president.
ACCCE recently released polling data that found that 59 percent of voters in Ohio, Pennsylvania and Virginia support the use of coal, with that number rising to 68 percent among so-called "working class Democrats" and Democrat-leaning independent voters. When told that EPA regulations could lead to major job losses or an increase in energy prices, the number of coal-supporting respondents rose to 70 percent.
Obama also has been heavily campaigning in coal states. Earlier this month he released an ad responding to Romney's attacks, which includes a 2003 clip of Romney as Massachusetts governor decrying a coal plant. Obama's "all-of-the-above" energy approach includes developing clean coal technology within 10 years.
The campaign rhetoric has effectively made the EPA a "scapegoat," said David Marshall, an attorney with the Clean Air Task Force, a nonprofit group working to reduce air pollution.
"The coal industry has a lot of problems, and blaming everything on EPA is an extremely simplistic and opportunistic approach," said Marshall, who was part of the legal team representing a coalition of environmental groups that defended the cross-state pollution rule this summer.
Marshall and other environmentalists say the EPA is simply enforcing pollution rules that should have been in place long ago, and that the health and environmental benefits would outweigh the costs of compliance—a point that has disappeared from the national debate.
The EPA has estimated that the MACT rule could cost the industry $9.6 billion a year by 2015, although industry estimates put the figure at $10.4 billion. The cross-state pollution rule could cost $800 million a year during that same time period.
The agency has also said that the sulfur dioxide and nitrogen oxide reductions from power plants could save as much as $280 billion in health costs a year, while preventing 34,000 annual deaths. The MACT rule, meanwhile, would create some $90 billion in annual health and economic benefits from reduced pollution.
"When you're looking at any of these EPA regulations that the coal industry or Romney are pointing to, they're actually extremely cost effective," Marshall said.
"You have to keep in mind all of these external costs, like the health impact and environmental costs. If you look at this in a holistic way, it's clear that no matter how you slice it there are benefits."