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Category — NESHAP Rule (Mercury)

Reconsidering U.S. EPA’s Proposed NESHAP’s Mercury Emission Rule

“The proposed rules will have little, if any, impacts on mercury concentrations in the environment at a very high monetary and societal cost.”

The Environmental Protection Agency’s (EPA’s) newly proposed National Emission Standards for Hazardous Air Pollutants (NESHAP) from Coal- and Oil-fired Electric Utility Steam Generating Units and Standards of Performance for Fossil-Fuel-Fired Electric Utility, Industrial-Commercial-Institutional, and Small Industrial-Commercial-Institutional Steam Generating Units1 failed to describe the scientific reality of natural processes and multi-factorial controls that govern the cycling of mercury (Hg) and the ultimate biomethylation and bioaccumulation processes for methylmercury (MeHg). As this report documents, this natural cycle has been taking place for at least the last 650,000 years.

According to a new United Nations Environment Programme (UNEP) report on mercury,2 U.S. mercury emissions from all sources are indeed far lower than those of China and India. Indeed, an earlier EPA press release and webpage acknowledge that U.S. emissions are only “roughly three percent of the global total”and that from “1990 through 2005, [U.S.] emissions of mercury into the air decreased by 58 percent.”3

The ultimate question that EPA and the public should therefore ask then is this: What will we get by cutting our already very small U.S. mercury emissions from power plants and other man-made sources – especially since new estimates from peer-reviewed papers suggest that mercury emissions from U.S. forest fires alone release about 44 tons of mercury per year,4 an amount roughly equivalent to the annual emissions from all power plants in the United States today?

The bottom-line remains that trace amounts of mercury (Hg) or the biochemically-active form of methylmercury (MeHg) in fish, either from lakes and streams or oceans, are essentially a natural manifestation that has no clearly controllable relationship vis à vis any anthropogenic emissions of mercury. More importantly, consuming reasonable amounts of fish, at reasonable frequency, is safe and should be a crucial component of a healthy dietary plan for every Americans.

The proposed rules will have little, if any, impacts on mercury concentrations in the environment at a very high monetary and societal cost.

EPA’s proposed NESHAP provides no detectable beneficial outcomes in the control of mercury emissions (even accepting EPA’s own risk-benefit analysis without a challenge). The new rules will result in a major economic impact, harm American public health by creating exaggerated and unfounded fears about eating fish that are beneficial in everyone’s diet, and further degrade the essential role of science in informing public policy.

This report makes the following findings regarding EPA’s proposed new emission rules focusing on mercury: [Read more →]

June 11, 2012   No Comments