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Air Quality Impacts Associated With Extraction and Burning of Western Coal

James A. Holtkamp, Emily C. Schilling, Air Quality Issues Affecting Oil, Gas, and Mining Development in the West

The United States is often called the “Saudi Arabia” of coal because of its immense coal reserves. In fact, the United States has the largest estimated recoverable reserves of coal in the world, enough to last more than 200 years based on current production levels.2 Wyoming alone is home to 40 percent of coal mined in the U.S., far ahead of second place West Virginia, which produces 12 percent.3

The emissions impacts of burning coal, however, are significant. The primary pollutants resulting from combustion of coal are nitrogen oxide (“NOx”), sulfur dioxide (“SO2”), particulate matter (“PM”), carbon monoxide (“CO”) and greenhouse gases (“GHG”), including carbon dioxide (“CO2”). In addition, coal combustion results in emissions of mercury and other hazardous air pollutants. As a result, emissions from coal combustion are subject to an ever-increasing and ever more complex web of air pollution control and climate change regulations. This paper examines the numerous regulatory requirements applicable to coal-fired electricity generators and discusses the broader implications of these regulatory requirements--particularly as they relate to GHG emissions--on the analysis of coal development under land use statutes.

II. EPA's Finding That Regulation of Hazardous Air Pollutants from Utilities is “Appropriate and Necessary” and the Resulting Mercury and Air Toxics Sta