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Mercury Emissions Campaign
Call for Comments
Mercury is a neuro-toxin and coal-fired power plants are the largest source
of man-made mercury emissions in the world. Until 2005 these emissions
were unregulated.
In 2005, in response to the Clean Air Act, the EPA put forth a set of
mercury emissions rules. After a period of evaluation by the ODEQ staff,
they proposed to adopt these same mercury rules for Oklahoma ("Incorporate
by Reference"). These rules have been widely criticized by a number of
groups: Physicians groups, nurses associations, citizen groups,
environmental groups, states attorneys general, etc. Their view is that
the EPA rules are far too lenient for a neuro-toxin, and that the rules
are inadequate for protecting children and nursing mothers (and fish and
birds and the animals that consume them). A number of states across the
country are suing the EPA for stricter mercury rules, and they claim that
the coal-fired power plant industry was granted an insider concession on
the rules by the Bush administration. Many states have already written
stricter rules on their own.
The following quote is from an article in the Journal of the American
Medical Association: "Under the Clean Air Act, power plants would have
been required to use the best available technology to reduce mercury
emissions. According to an EPA report to Congress in 2000, this
requirement would have reduced mercury emissions from the plants by
90%-from about 50 tons per year to 5 tons per year-by 2008. In a reversal
of this approach, on March 29, 2005, the EPA finalized a mercury rule that
exempts the power plants from these requirements and instead would
institute a program favored by the industry."
The program put forth by the EPA would require a 70% reduction by 2018.
The rules also included a "Cap and Trade" system that would allow power
plants to exceed the standards by purchasing credits from cleaner
out-of-state plants. There is concern that this Cap & Trade system could
lead to mercury "hot spots" around the power plants that exceed the limits
(by using these credits).
Republican Senator Susan Collins had this to say: "EPA put out a rule
which does not account for mercury hotspots and which places children and
pregnant women at risk."
A good question is whether power plants can actually meet these stricter
rules. Is it technically possible? Apparently it is, but it might cost
more initially when building a new plant. It would require the use of
"Maximum Available Control Technology" (MACT). A number of plants are
already successfully using this technology to capture more than 90% of
their mercury emissions, including plants in Alabama, Michigan, North
Dakota, Illinois, and more.
The National Wildlife Federation has calculated that using MACT could add
1-3% to the average homeowner's monthly electric bill, or about the cost of
a cup of coffee.
Part of the reason for ODEQ adopting the weaker EPA rules is that they
haven't heard any comments from the public, only from the power companies.
The cancellation (due to weather) of the recent Air Quality Advisory
Council meeting means that the rules weren't formally incorporated. But
more significantly, it gave a member of the ODEQ Board an opportunity to
study the proposals more closely, and this board member has asked the DEQ
staff to reconsider the rules. This means that the public has a
opportunity to help shape DEQ's final rules.
This board member, Terri Savage, has asked for immediate public comment.
Her request is printed below:
From: Terri Savage, Member, DEQ Environmental Quality Board.
Input from the public is needed on the Mercury Rule.
As proposed, Oklahoma would incorporate by reference language put forth by
the Bush Administration EPA that doesn't even recognize that mercury is a
toxin and furthermore allows too much it into the environment.
Air Quality Council Agenda item F. OAC 252:100-44. Control of Mercury
Emissions from Coal Fired Electric Steam Generating Units [NEW]. "The
Department is proposing a new Subchapter 44, Control of Mercury Emissions
from Coal Fired Electric Steam Generating Units, which would incorporate by
reference the federal Clean Air Mercury Rule (CAMR) issued in May 2005."
A better approach, I believe, would be to start with a model put forth
under the auspices of the State and Territorial Air Pollution Program
Administrators (STAPPA) and the Association of Local Air Pollution Control
Officials (ALAPCO) -- (State, Local Air Officials Urge Rapid Mercury Emissions Cuts) that agrees that mercury is a dangerous neurotoxin -- that could be tailored to address the specific needs of Oklahoma. This approach is endorsed by the National Wildlife Federation.
Your polite comments should always incorporate two (2) key items, the first
is your opinion, the second is your alternative solution.
Opposing incorporating EPA's language by reference as Oklahoma's Rule is a
no-brainer for me. My alternative solution is stated above. To see why I
have taken this position, please go to the ENN webpage using the
highlighted link above. I am including my letter to Eddie Terrill, Air
Quality Division head, in this email. Feel free to use areas I have
highlighted in your letter, but please don't copy it outright as it makes
a reference to my vote when the board meets...
Email your comments to Mr. Terrill at Eddie.Terrill@deq.state.ok.us
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