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. Ultimately on December 16th of 2011, the Mercury and Air Toxics Standards (MATS) was issued.
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. 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. 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. The proposal, however, was issued prior to the government shutdown and remains stagnant.
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. 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.
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. 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.
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. 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.
“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.
 “History of the MATS Regulation.” EPA, Environmental Protection Agency, 20 July 2017
 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
 “Regulatory Actions – Final Mercury and Air Toxics Standards (MATS) for Power Plants.” EPA, Environmental Protection Agency, 28 Dec. 2018
 “Bowing to Coal Industry, EPA Moves to Weaken Mercury & Air Toxics Standards.” NRDC, 28 Dec. 2018
 Irfan, Umair. “The EPA Wants to Make It Harder to Ratchet down Toxic Chemicals from Power Plants.” Vox, Vox, 28 Dec. 2018
 “Bowing to Coal Industry, EPA Moves to Weaken Mercury & Air Toxics Standards.” 2018
 “Danger in the Air.” Earthjustice, 5 Mar. 2019
 “Basic Information about Mercury.” EPA, Environmental Protection Agency, 29 Jan. 2019
 “Mercury and Toxics in Nature.” National Parks Service, U.S. Department of the Interior, 11 Sept. 2018
 “Regulatory Actions – Final Mercury and Air Toxics Standards (MATS) for Power Plants.” 2018