the goodman group, ltd.

Employment Impacts of Air-Pollution Controls at North Dakota Coal Plants

TGG has been evaluating green job impacts for over 30 years. In November 2011, TGG prepared an expert report for the Sierra Club (National) entitled Employment Impacts of Air Pollution Controls at North Dakota Coal Plants. The purpose of this study was to estimate the employment impacts of pollution-control expenditures at the Milton R. Young and Leland Olds coal-fired plants in North Dakota.

TGG estimated that the EPA’s proposed requirement (since withdrawn) for the installation of Selective Catalytic Reduction (SCR) for NOx reduction at these plants would have created 7,700 temporary jobs and 180 permanent new positions. The bulk of the jobs (5,100 temporary jobs and 130 permanent jobs) would have been be in North Dakota.

In addition to the EPA’s proposed requirement for SCR, the North Dakota plants had already installed scrubbers and other pollution control measures required by North Dakota in its State Implementation Plan (SIP). The two programs combined would have delivered 20,200 temporary jobs and 1,130 permanent jobs to the US economy, with most of these jobs in North Dakota.  In addition to the reduction of harmful pollutants, as well as health and visibility benefits, pollution control measures undertaken in the SIP program and proposed in the SCR program would have resulted in important economic development benefits.

Despite the economic and employment benefits demonstrated in the TGG Report, the EPA’s proposed SCR requirement was opposed by the State of North Dakota and the coal industry (and was the target of legal challenges). In 2012, the EPA reversed its proposed SCR requirement for the North Dakota coal plants and approved a final plan with weaker pollution controls. 

Update 2012-2024: Since 2011, as climate change awareness (and impacts) have increased, the environmental movement has shifted its focus with respect to coal generation. Instead of advocating for air pollution controls for coal plants, the focus is increasingly on their replacement with renewable generation.  The Obama administration’s Clean Power Plan (CPP) called for the reduction of GHG emissions from electricity generation. Under the CPP, the EPA assigned each state an individual goal for reducing power plant emissions. Conversely, the Trump Administration tried to protect the coal industry by replacing the CPP with the less stringent Affordable Clean Energy Act and weakened air pollution control regulation for coal plants.

In 2020, President Biden campaigned of a bold promise to achieve 100% clean electricity by 2035. His clean energy plan was considerably more ambitious than the CPP and faced steep challenges. However, the landmark 2022 bipartisan Inflation Reduction Act (IRA) created the largest single investment in clean energy and climate protection in American history. It has been widely viewed as a success in accelerating the clean energy transition, curbing GHG emissions, creating jobs, and reducing the deficit.

Update January 20, 2025: Despite the economic and environmental success of the IRA, Trump signed an executive order, “Unleashing American Energy,” to repeal the clean energy subsidies in the Inflation Reduction Act. 

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REPORT | November 21, 2011

Project Categories

Energy: Coal
Client: Environmental Group
Type: Job Study