[eDebate] More on mercury: Segal responds
Fri Jul 16 11:34:18 CDT 2004
THAT's your argument? "If you choose MACT instead of cap-and-trade we'll
sue you and that takes a lot of time. If you choose cap-and-trade instead
of MACT, we'll cheerfully comply."
Maybe true. But far from compelling. The argument feels less like a
substantive net-benefit to cap-and-trade than a threat that the regulated
community will throw a temper trantrum over any other method.
And I'm not convinced that the companies would refrain from going to court
over whatever cap-and-trade protocal was chosen anyway. The lawsuits are
That cap-and-trade worked for acid rain doesn't mean that it is BETTER than
MACT. Many of the reductions in the major air pollutants that you cite have
been made with MACT, not cap-and-trade.
AND, if it's true that the highest emitting facilities had the greatest
reductions under cap-and-trade, it would be equally true under MACT. (If
all facilities are reduced to a base-line level, then you'd expect the
highest emitting to have the greatest reduction...they HAVE to). And, if
your argument is that the cap-and-trade program provided economic incentives
for the highest-emitting facilities to adopt better control technology (so
they wouldn't have to pay for emissions credits), wouldn't the economic
incentives created by criminal and civil sanctions imposed for MACT
violations ALSO provide (even stronger) incentives to adopt the best
So if the same outcome is achieved in either case, explain to us what, in
the end, is the incentive for the regulated community to prefer
cap-and-trade to MACT?
PS. I think you're right about my hair confounding the mercury detectors.
I have enough product in there to refill the SPR.
From: Christopher Cooper [mailto:ccooper at planning.org]
Sent: Friday, July 16, 2004 12:08 PM
To: 'edebate at ndtceda.com'
Subject: [eDebate] More on mercury: Segal responds
Scott Segal asked that I post this:
My first post was a rulemaking comment; they have to be measured in
order to be read. If you would prefer, see the following from the
Atlanta Journal Constitution. But, just in case, I think you should get
your hair tested; do you think bleach throws off the mercury detector?
BTW, I think you are missing the point of cap/trade programs: by
creating a financial incentive for substantial early reductions, the
historical record is that c/t get greater reductions sooner than
command/control regulations. Lawsuits, while fun for lawyers (note the
declaration against interest), do not create incentives. In fact, they
are cumbersome, and create delay.
So, go eat plenty of fish. ss/
Seek best way to limit mercury
By SCOTT SEGAL
Special to the Atlanta Journal-Constitution
Published on: 03/24/2004
Americans have every right to expect both clean air and reliable,
affordable electricity. Power providers agree that mercury emissions
should be controlled. We should be discussing the best way to achieve
the result. Mechanisms based on market principles have shown the best
results in improving air quality.
Back in 1990, the Congress adopted a "cap-and-trade" regime to deal
with emissions associated with acid rain. Under this program, utility
emissions are capped. If companies do better than the cap, they can sell
credits to companies that might have missed the mark. This creates a
strong financial incentive to reduce emissions quickly.
According to an Environmental Protection Agency report in 1999, when
the EPA was under the Clinton administration, cynics opposing
cap-and-trade were wrong about that program. Now the same critics want
us to reject a similar program for mercury.
How do critics' mercury arguments stack up against real-world
experience? Poorly. First, the acid rain experience shows that
substantial incentives are created for reductions well in advance of the
program's mandates, refuting the notion that mercury reductions come too
slowly. Second, the acid rain experience shows that the highest emitting
facilities had the greatest reductions, turning the critics' belief in
so-called "hot spots" on its head.
You would almost think the previous administration actually proposed a
mercury control program that the present EPA has rejected. Wrong. With
eight years to weigh their options, the last administration never did
get around to it. The one mercury finding they made was without any
public notice and comment, but with full knowledge they wouldn't have
time to write any rule. By contrast, the current EPA has proposed two
different ways to make large mercury reductions, and is presently taking
public comments on both.
Power providers have made billions of dollars in investments in
pollution control in recent years that led to improved environmental
performance. EPA reports that since 1970, total emissions of the six
major air pollutants fell 48 percent. Emissions from U.S. electric
utilities represent only about 1 percent of total global mercury
emissions. These air-quality improvements occurred even as the economy
grew by 164 percent and energy consumption by 42 percent. In fact, we
could shut down all the coal plants in Georgia today and in 50 years the
mercury levels in fish in Georgia's rivers and lakes would be at the
same levels as they are today.
Too much hangs in the balance to be inflexible in controlling mercury.
There is great doubt about the feasibility and effectiveness of new
control technologies. If the result of new regulations were to force
ever greater switching from coal to natural gas, the result would be
higher prices for those on fixed incomes and living in poverty, and less
employment in manufacturing sectors dependent on natural gas. By
contrast, building on our past experience can produce substantial
results, faster and at lower cost.
Scott Segal is an attorney and director of the Electric Reliability
Coordinating Council, a group of electric utilities working on clean air
policy. He is a graduate of Emory University.
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