[greenyes] Inspector General Charges EPA Biased Mercury Standard

["Peter Anderson" <anderson@no.address>]

USEPA INSPECTOR GENERAL

Additional Analyses of Mercury Emissions Needed Before EPA Finalizes Rules 
for Coal-Fired Electric Utilities

Evidence indicates that EPA senior management instructed EPA staff to 
develop a Maximum Achievable Control Technology (MACT) standard for mercury 
that would result in national emissions of 34 tons annually, instead of 
basing the standard on an unbiased determination of what the top performing 
units were achieving in practice. The 34-tons-per-year target was based on 
the amount of mercury reductions expected to be achieved from implementation 
of nitrogen oxide (NOx) and sulfur dioxide (SO2 ) controls under a 
separately proposed, but related, air rule. According to EPA officials, 34 
tons represents the most realistic and achievable standard for utilities. 
However, because the results of the MACT standard were prescribed and prior 
estimates were lower than what was proposed, the standard likely understates 
the average amount of mercury emissions reductions achieved by the top 
performing 12 percent of utilities, the minimum level for a MACT standard 
required by the Clean Air Act. Further, this MACT standard, as proposed, 
does not provide a reasonable basis for determining whether the MACTor 
cap-and-trade approach provides the better cost benefit.





_________________________
Peter Anderson, President
RECYCLEWORLDS CONSULTING
4513 Vernon Blvd. Suite 15
Madison, WI 53705-4964
Ph: (608) 231-1100
Fax: (608) 233-0011
Cell: (608) 698-1314
eMail: anderson@no.address
web: www.recycleworlds.net

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