Putting a Price Tag on The Environment: Air Pollution Deregulation

In the early 1990’s, the Clean Air Act provided the first steps prior to regulating air toxics emissions as a result of power plants in the United States. For many years, the EPA and Congress went back and forth concerning the necessity to regulate power plant emissions specifically air toxins such as mercury, lead, particulate matter and many more. By 1998, both the Mercury Study Report and the Utility Air Toxics Study were produced, yet Congress decided not to implement but to push the deadline for research back until 2000. Studies and reports were provided, and more deadlines were extended. It wasn’t until March 15th of 2005 that the EPA issued the final Clean Air Mercury Rule, which essentially limits mercury emissions from new and existing utilities through a national market-based cap-and-trade program. Mercury, however, is specific and, because its only one toxin, is much easier to manage from the perspective of power plant operators in relation to general air toxics, which is why we don’t see the introduction of the Utility Air Toxics Study in regulation until 2011. On March 16th of 2011 the EPA proposed a rule reducing emissions from new and existing oil and coal-fired power plants effectively taking over the Clean Air Mercury Rule to encompass over 80 dangerous air toxics including Mercury.[1] Ultimately on December 16th of 2011, the Mercury and Air Toxics Standards (MATS) was issued.

 

Current Events

 

The U.S. Environmental Protection Agency, under its new appointee and former coal lobbyist, Andrew Wheeler, has released a new proposal attempting to roll back the 2011 regulations providing power plants the opportunity to essentially turn off air pollution controls.[2] The EPA determined that coal and oil-fired power plants complying with the MATS regulations are experiencing costs of approximately $7.4 to $9.6 billion annually.[3] However, the proposed changes to the MATS regulations on air toxins in order to prioritize financial benefit to the coal and oil industry were met with rage and uneasiness among the environmental community. “This is an unconscionable rollback to serve the coal industry at the expense of all Americans, especially our children,” says John Walke, director of the National Resources Defense Council’s Clean Air program. Walke claims it’s an “absurd and dangerous” proposal.[4] The proposal, however, was issued prior to the government shutdown and remains stagnant.[5]

 

Environmental and health concerns

 

Mercury & Air Toxics Standards (MATS) provides limits to over 80 dangerous pollutants. Currently, according to the National Resources Defense Council, these regulations prevent up to 11,000 deaths, 13,000 asthma attacks, and nearly 5,000 heart attacks every year, which adds up to about $90 billion in health benefits annually.[6] The revision of MATS will undo decades of work by the EPA put into the Clean Air Act produced in 2011 in which over 80 percent of mercury emissions from power plants along with particulate matter and hazardous air pollution is controlled.[7]

Not only does mercury and other air toxins effect human health, biodiversity, animal behavior, and organism development are at risk as well. As mercury pollutes bodies of water, these toxins work their way up the food chain infiltrating fish that act as a food source for other parts of the ecosystem. Birds and mammals that consume fish can experience mercury poisoning which can cause reduced reproduction, slower growth and development, behavioral abnormalities, and even death.[8] Environmental impact of these toxins are observed drastically effecting National Parks which are supposedly preserved by law. According to a 2014 report by the U.S. Geological Survey and the National Park Service, dangerous mercury levels are observed in more than 1,400 freshwater fish collected from 21 different national parks.[9]

 

Recommendations

 

The quantifiable benefits for the oil and gas industry produced by the EPA as a result of the recommended changes is approximately $6 billion annually.[10] Although assigning monetary loss through the connection of power plant emissions and environmental issues proves to be a difficult and polarized task, our understanding of mercury and air toxin poisoning in both humans and other animals is clear. Annual health benefits are predicted to accumulate over $90 billion and these health risk applies to everyone on this planet. Due to the nature of atmospheric constituents and heterogeneous distribution, air toxins in one remote location effects life around the planet. Both environmental and human health risks resulting from the EPA’s proposal to MATS should generate concern among not only activities of a conservationists but the daily life of every human being.

I would recommend to the EPA that the regulations set by MATS must be taken seriously and the effects of the proposed reformation should be reconsidered. The cost benefit analysis, specifically, should encompass the monetary cost of health benefits as a form of generating a price tag for life on earth. Recent governmental action, in the quest for energy independence, has played up the price tag of environmental regulations and neglected costs to the environment and people. The discussion of ethics sparked by the conscious effort to exponentially increase health risk at this volume should be enough to drive further analysis prior to proposal.

 

References:

 

“Danger in the Air.” Earthjustice, 5 Mar. 2019, earthjustice.org/features/what-you-should-know-about-the-mercury-and-air-toxics-standards.

 

“Basic Information about Mercury.” EPA, Environmental Protection Agency, 29 Jan. 2019, www.epa.gov/mercury/basic-information-about-mercury.

 

“Bowing to Coal Industry, EPA Moves to Weaken Mercury & Air Toxics Standards.” NRDC, 28 Dec. 2018, www.nrdc.org/experts/nrdc/bowing-coal-industry-epa-weakens-mercury-air-toxics-standards.

“History of the MATS Regulation.” EPA, Environmental Protection Agency, 20 July 2017, www.epa.gov/mats/history-mats-regulation.

Irfan, Umair. “The EPA Wants to Make It Harder to Ratchet down Toxic Chemicals from Power Plants.” Vox, Vox, 28 Dec. 2018, www.vox.com/2018/12/28/18159509/mats-mercury-epa-toxic-coal-power-plant.

 

“Mercury and Toxics in Nature.” National Parks Service, U.S. Department of the Interior, 11 Sept. 2018, www.nps.gov/subjects/air/nature-toxics.htm.

 

Regulatory Actions – Final Mercury and Air Toxics Standards (MATS) for Power Plants.” EPA, Environmental Protection Agency, 28 Dec. 2018, www.epa.gov/mats/regulatory-actions-final-mercury-and-air-toxics-standards-mats-power-plants.

 

Thompson, Jake. “Memo: EPA Set to Roll Back Lifesaving Mercury & Air Toxics Safeguards—for Big Coal.” Received by Environmental Protection Agency, National Resource Defense Council, 2 Oct. 2018, www.nrdc.org/sites/default/files/editorial-board-memo-epa-mats-20181002.pdf.

 

[1] “History of the MATS Regulation.” EPA, Environmental Protection Agency, 20 July 2017

[2] Thompson, Jake. “Memo: EPA Set to Roll Back Lifesaving Mercury & Air Toxics Safeguards—for Big Coal.” Received by Environmental Protection Agency, National Resource Defense Council, 2 Oct. 2018

[3] “Regulatory Actions – Final Mercury and Air Toxics Standards (MATS) for Power Plants.” EPA, Environmental Protection Agency, 28 Dec. 2018

[4] “Bowing to Coal Industry, EPA Moves to Weaken Mercury & Air Toxics Standards.” NRDC, 28 Dec. 2018

[5] Irfan, Umair. “The EPA Wants to Make It Harder to Ratchet down Toxic Chemicals from Power Plants.” Vox, Vox, 28 Dec. 2018

[6] “Bowing to Coal Industry, EPA Moves to Weaken Mercury & Air Toxics Standards.” 2018

[7] “Danger in the Air.” Earthjustice, 5 Mar. 2019

[8] “Basic Information about Mercury.” EPA, Environmental Protection Agency, 29 Jan. 2019

[9] “Mercury and Toxics in Nature.” National Parks Service, U.S. Department of the Interior, 11 Sept. 2018

[10] “Regulatory Actions – Final Mercury and Air Toxics Standards (MATS) for Power Plants.”  2018

6 thoughts on “Putting a Price Tag on The Environment: Air Pollution Deregulation

  1. Theo, your article was very informative! I did not know that it has taken nearly 20 years for the EPA to issue regulations on dangerous Mercury emissions. Much of the insightful historical information you provided in your article is missing on the EPA’s website on MATS. It appears the rollbacks proposed by Wheeler leave many loopholes open for coal companies to get away with their mercury emissions. It is extremely upsetting that this information is omitted from the EPA’s website, making it harder for the average citizen to become informed.

  2. I think you touch on one of the most complex topics in environmental science. It is so hard to physically quantify and monetize environmental impacts. It is even harder, then, to force companies and sources to pay for these impacts when they are not immediately visible/obvious. Further, when discussing the tangible benefits that limiting emissions and pollutions have, this is not a benefit you can physically see, but rather an accumulation of all the benefits and a life saved rather than one gone.
    It is slightly terrifying to me that we live in a country that is trying to rollback regulations and restrictions on such polluters when we have come so far to restrict them and must greatly limit them in the future. It is also shocking because it seems to me that the American population at large supports environmental policies and acknowledges human’s role in climate change due to these emissions. Huge emitters are not going to have any incentive to reduce emissions or pollutants when profits are their main priority and thus an external force (i.e. the government) is greatly needed. I wholeheartedly agree with your recommendations to the EPA and am curious how feasible the new reformations to MATS is.

  3. Theo, thanks for addressing this topic! I’ve heard of mercury pollution in the context of fish consumption, but hadn’t realized the extent of human health, biodiversity, and animal safety implications. It’s so unfortunate Administrator Wheeler is choosing to allow more toxic chemicals to be released simply to increase oil and gas company profit. I appreciate your mention that a more comprehensive cost-benefit analysis would demonstrate how the regulations put in place are net positive for society, not to mention all of the non-monetizable benefits which come from having healthy species and clean air and water. I hope you’ll continue to raise this issue moving forward. Although climate change is a monumental challenge, addressing pollutants beyond carbon dioxide remains critical for the future.

  4. I’m so glad you wrote your blog on this! I actually first heard about this decision about MATs in an Economics class I’m taking this semester, because of the main debate of the issue, which, as you point out, is over cost-benefit analysis. Before learning about this issue, it seemed to me that cost-benefit analysis is a calculated number and therefore is not a contested matter. But as we see through this decision, the valuation of the environment is clearly a partisan issue. Wheeler’s removal of these regulations is another example of how environmental regulation has followed the pattern of being popular when a Democrat is in office, but is stripped when a Republican is president.

  5. This blog was very insightful and thought-provoking. As time goes on and the climate gets worse, it seems that putting price tags on invaluable environmental assets becomes a necessity. Assigning monetary values to conserved land, clean air, and clean water is a complicated task that will likely never appease every stakeholder who would like to assign them values, as evidenced by the amount of time it took Congress and the EPA to decide upon MAT values. I am particularly interested in the part of your blog post that explains compliance costs and how they factor into pricing clean air. It seems that the value of mercury-free (or mercury-reduced) air was determined based on the way it affects humans–both in terms of health risks and companies’ compliance costs. Do you think this is the best way to assign value to our environment? How would you do it?

  6. While I was aware of the potential harms of mercury this blog post was very informative and broadened my knowledge. It is a particular threat to human health which is what jumps out at me, and will have a great impact on the general public and government when being prioritized as an issue. It could be argued that in the current political climate, placing monetary consequences on environmental toxins, especially through the EPA could be extremely difficult to implement and get through the current administration. How do you propose that this issue get framed to the administration in order for it to get clearly passed?

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