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wholesale price index, despite strong, long-term, utility demand for coal. This experience leads us to believe that there is a serious question as to whether adequate quantities of suitable coal will be available to meet the sharply increased utility demand for coal which would be occasioned by enactment of S. 1777. Also, the price which utilities might be required to pay for coal were they to be forced into such a market would be, again based on recent experience, totally unrelated to cost of production and would place an intolerable burden on electricity consumers. Any legislation which would force the rapid conversion of electric utility generators to coal firing should deal with these two primary questions of supply adequacy and reasonable prices.

The availability of adequate transportation is apt to be a serious bottleneck in any attempt to greatly increase utility use of coal in the near term. One of the most common excuses offered for coal delivery failures to APPA member utilities is the unavailability of railroad hopper cars with which to move the coal. John Corcoran, chairman of the nation's second largest coal producer, Consolidation Coal, observed in a recent interview that among the many obstacles to large scale coal conversion is the fact that many of the railroads that haul coal are in need of a "massive rehabilitation project." Not only is there not an adequate stock of modern hopper cars, but the roadbeds of many rail lines are in deteriorated condition.

Long-term availability of reasonably priced coal is only part of the broader question of the economic feasibility of converting existing utility boilers to coal firing. Some generating units, especially those designed for natural gas as the primary fuel, cannot be converted to coal firing. While a national policy which denies natural gas for use under boilers so that the scarce fuel may be reserved for "superior" uses may make sense in the aggregate, if in specific instances its application would result in the

waste of existing capital equipment, the national interest might be best served by use of selective exceptions to the general policy. APPA recognizes the wisdom of conserving natural gas reserves for those purposes for which there is no acceptable substitute, but there are certainly instances wherein exceptions must be made so as to avoid the gratuitous waste of other

scarce resources.

The environmental impact of requiring electric utilities to convert from other fuels to coal is of concern to our member utilities both as good public citizens and as business enterprises which may be asked to comply with conflicting societal wishes and directives. We believe that no electric utility should be required to make expenditures to comply with a governmentally imposed coal conversion program until such time as there is clear agreement among all levels of government that the construction and operating permits necessary for coal-fired generation will be forthcoming. This is important both to insure that scarce capital is not wasted, and to allow electric utilities to meet their responsibility to their rate payers to control costs

and hence electric rates.

The objectives of S. 1777, to conserve scarce domestic petroleum and

natural gas, and to promote national energy self-sufficiency, are fully supported by the American Public Power Association. APPA supports the concept of a coal conversion program. We do, however, question the wisdom of the ambitious time schedule outlined in S. 1777, and ask that any new program recognize the limitations on coal supply and be sufficiently flexible to accommodate sensible exceptions to general program objectives.

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AMERICAN PUBLIC POWER ASSOCIATION

2000 VIRGINIA AVENUE NW WASHINGTON DC 20037 202/333-9200

OFFICERS

President STANLEY R. CASE President-elect LOUIS H. WINNARD Vice President CHARLES E. DUCKWORTH

Treasurer WALTER R. WOIROL General Counsel NORTHCUTTELY General Manager ALEX RADIN

DIRECTORS

JAMES E. BAKER

Shrewsbury, Massachusetts

ALDO BENEDETTI
Tacoma, Washington

STANLEY R. CASE
Fort Collins, Colorado
WILLIAM H. CORKRAN, JR.
Easton, Maryland

NORMAN E. DIETRICH
Austin, Minnesota

CHARLES E. DUCKWORTH
Garland, Texas
AL EDWARDS
Grand Haven, Michigan
JOHN C. ENGLE
Hamilton, Ohle
JAMES P. FULLER

Muscatine, lows
JAMES L GRAHL
Basin Electric Power
Cooperative, Inc.
Bismarck, North Dakota
CALVIN R. HENZE
Memphis, Tennessee
PATRICK JHESTER
Rockville Centre, New York
WARREN D. HINCHEE
Burbank, Califomia
W. G. HULBERT, JR.
PUD #1 of Snohomish County
Everett, Washington

W. BERRY HUTCHINGS
Bountiful, Utah
ALAN H. JONES

McMinnville, Oregon

MAX E. KIBURZ

Loup River Public Power District
Columbus, Nebraska

C. D. MCINTOSH, JR.
Lakeland, Florida
JAMES L. MULLOY
Los Angeles, California

A. J. PFISTER
Salt River Project
Phoenix, Arizona
JOHN POLANCIC
Rochelle, Illinois
V. G. SCOGGIN
Nashville, Tennessee
JAMES D. SHERFEY
Bristol, Tenness

EARL SWITZER

Macon, Missouri

J. B. THOMASON
South Carolina Public
Service Authority

Moncks Comer, South Carolina

MITCHELL W. TINDER
Frankfort, Kentucky
MARION R. ULMER
Jonesboro, Arkansas
DENNIS VALENTINE
Califormia Municipal
Utilities Association
Sacramento, California

DONALD VON RAESFELD
Santa Clara, California
GEORGE W. WATTERS

Clark County Public Ulity District
Vancouver, Washington

LOUIS H. WINNARD
Jacksonville, Florida

WALTER A. WOIROL
PUD $1 of Chelan County
Wenatchee, Washington

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I noted with keen interest reports of your remarks
before the annual convention of the National Coal
Association in which you argued that coal must be priced
at levels which reflect actual costs of production and
not international oil prices currently set by the OPEC
nations. Members of the American Public Power Association
share your belief that coal is one of the most important
fuels of the future and also agree that its potential
cannot be achieved if coal prices are tied to oil prices
rather than production costs. You are to be commended
for bringing this point so forcefully to the attention
of coal producers.

Because of your personal concern about this pricing
problem, I thought you would like to have the enclosed
copy of a study of coal prices made for APPA and several
other organizations. As you will note in the summary
beginning on page V-1, the study found that increases in
the price of coal in recent years cannot be fully explained
by increases in the cost of production, that short-term
profits have risen at a very rapid rate during this period,
and that coal company actions relative to supply are not
consistent with competitive market behavior.

AR/dt
Encl.

Sincerely,

als Radia

Alex Radin

55-305 O-75 pt. 3-5

AN ECONOMIC ANALYSIS OF PRICE INCREASES

IN THE U. S. COAL INDUSTRY

Prepared for:

American Public Power Association

Emergency Committee for the Tennessee Valley
National Rural Electric Cooperative Association
Tennessee Valley Public Power Association

By:

Dr. James R. Barth, Assistant Professor of Economics,
George Washington University

Dr. James T. Bennett, Assistant Professor of Economics,
George Washington University

October 1, 1974

AN ECONOMIC ANALYSIS OF PRICE INCREASES

IN THE U. S. COAL INDUSTRY

I. Introduction

The purpose of this report is to document the rapid increases in

the price of all types of coal produced in the U. S. and to investigate possible causes of these increases. Coal is a primary fuel used to drive the nation's economy and to provide a source of power for the generation of electricity. Due to shortages in oil and natural gas, the traditional substitutes, the nation will become increasingly dependent upon coal, which is relatively abundant. Increases in the price of coal, therefore, have and will continue to have far-reaching effects into every segment of the U. S. economy, particularly on the cost of generation of electric power, for utilities typically consume more than 65 percent of the Bituminous coal produced in the U. S.

In the second section of this paper, increases in coal prices are reviewed and trends in production in coal mining are surveyed. Although some of the price increases can be explained by increased costs of production, it appears that the supply response of the coal industry to a rapid rate of price increase cannot be justified on the basis of cost increases alone. In a competitive environment, one would typically expect a rapid rate of price increase to lead to substantial increases in

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