Power plants have long been among the largest sources of pollution that contribute to climate change, bad air quality, and serious threats to public health. In our latest CleanLaw interview, Kathy Fallon Lambert walks us through the results of recent studies highlighting the potential impact of two Trump EPA proposals – withdrawing the “appropriate and necessary” foundation of the Mercury and Air Toxics Standards (MATS) and replacing the Clean Power Plan (CPP) with the Affordable Clean Energy rule (ACE). Joe and Kathy discuss the findings she and a team of a dozen scientists published on these rules (full author list is on the following links): The Center for Climate, Health, and the Global Environment‘s recent Mercury Matters 2018: A Science Brief for Journalists and Policymakers with updated research on mercury; US Power Plant Carbon Standards and Clean Air and Health Co-benefits in Nature Climate Change; and The Affordable Clean Energy Rule and the Impact of Emissions Rebound on Carbon Dioxide and Criteria Air Pollutant Emissions in Environmental Research Letters.
Note: the conversation begins with a discussion of MATS, but if you would like to go straight to CPP/ACE that’s at 27:15.
Key Points – MATS and Mercury
- The EPA is basing its proposal to withdraw the foundation for regulating hazardous air pollution from power plants on very out of date science on mercury emissions and impacts.
- A full accounting of the costs of IQ loss linked to mercury exposure has been estimated by scientists at $4.8 billion. This and other supporting research clearly suggests that the benefits of curbing mercury emissions from power plants are in the billions of dollars, not at $4-6 million, as EPA’s proposal suggests.
- In addition to determining what a full accounting for the impact of IQ loss entails, scientists have also discovered: The form in which mercury is emitted from power plants has greater local impacts and the pathways through which humans are exposed to mercury are more extensive than previously recognized; and Mercury exposure contributes to cardiovascular disease and heart attacks.
- Although the EPA proposal claims to present the results of comparing the benefits and costs of regulating mercury and other hazardous its calculation of the benefits grossly understates the benefits and is off by orders of magnitude.
Key Points – ACE
- Compared to no policy at all, under ACE about 18 states would have an increase in carbon dioxide emissions by 2030. In addition, 20 states would potentially see an increase in either sulfur dioxide or NOx compared to no policy.
- Not mentioned in the interview, but just as important, the ACE proposal includes a proposal to remove states’ ability to require power plants to make changes that would minimize or prevent those potential sulfur dioxide and NOx emissions increases through a Clean Air Act provision known as “New Source Review”.
- The increase in co-pollutants contributes to higher ground-level ozone and particulate pollution that affect not only people living in the states where they occur, but in neighboring states as well.
- ACE presents an unwarranted trade-off between purported – but at best minimal – reductions in carbon dioxide emissions and increases in other pollutants. Of all the approaches to reducing power plant carbon dioxide emissions available to the EPA, ranging from flexible, system-level strategies to do nothing, ACE does not represent the “Best System of Emissions Reduction” as required by the Clean Air Act.