By Edward D. Yankovich, Jr., International Vice President, District 2, United Mine Workers of America, George Ellis, President, Pennsylvania Coal Association, Donald C. Siegel, International Vice President, International Brotherhood of Electrical Workers, Douglas L. Biden, President, Electric Power Generation Association

Union families, electric generators, and the coal industry support reducing mercury emissions from coal-fired power plants. But let’s do it in a way that makes a real difference in reducing health risks and without threatening our jobs.

A recent proposal by the Department of Environmental Protection (DEP) for Pennsylvania to adopt its own mercury limit ignores a fundamental fact about mercury emissions – they are a global problem and travel hundreds and thousands of miles. Globally, power plant emissions make up about 1 percent of mercury emissions.

It also ignores a nationwide standard just put in place by the U.S. Environmental Protection Agency that will reduce mercury emissions by 70 percent nationwide by 2018, the first mercury limits on coal-fired power plants by any country.

Under the new federal rule, mercury emissions from Pennsylvania power plants are required to drop even more than the national average, from 4.9 tons to 1.7 tons in 2010, and to 0.7 tons (about 1400 pounds) in 2018, for an 86 percent reduction from 1999 levels.

The federal rules would also result in an additional 65 percent reduction in sulfur dioxide emissions that cause acid rain and a 70 percent reduction in nitrogen oxides that cause smog. Achieving these emission reductions will be challenging. However, the federal rule gives individual power plants the flexibility to adopt new technology as it becomes available and determine the best way to meet the new mercury limits in the most cost-effective way possible. It also sets a timetable that will allow for the continued use of Pennsylvania coal, one that will not unnecessarily accelerate the economically destructive use of scarce natural gas as a replacement fuel for coal.

In contrast, DEP has announced that the Pennsylvania-only rule will not include this flexibility for sources to minimize costs and that it will be more stringent than the federal rule. Businesses, consumers and workers within the Commonwealth would be disadvantaged if the Department were to implement a state-specific mercury rule that is more stringent than the federal rule. This is particularly true now that Pennsylvania’s electric industry has been restructured and in-state generation facilities must compete with power producers in neighboring states. The higher costs resulting from a Pennsylvania-specific rule would likely result in more power being generated in those neighboring states. Emissions from those out-of-state plants, including mercury emissions, would then be transported into Pennsylvania, negating any potential environmental benefit to the Commonwealth.

And how much environmental benefit can be expected from a Pennsylvania rule compared to the federal rule to begin with? Available research data suggests little or none at all. In its Regulatory Impact Analysis of the federal mercury rule EPA found that completely eliminating mercury emissions from power plants produced negligible additional reductions in deposition compared to the reductions produced by the federal rules. This is because the federal rules result in very large decreases in the type of mercury that is most readily deposited onto land and water surfaces – reactive gaseous mercury. Given these considerations, coupled with the fact that emissions from Pennsylvania’s power plants represent a tiny percentage of the mercury we can be exposed to, we believe any reasonable person must ask whether any incremental environmental benefit can be expected from any Pennsylvania unilateral approach to controlling mercury emissions from power plants.

Let’s reduce the health risks from mercury in ways that make good scientific and economic sense, and that minimize job losses, by adopting a federal approach to controlling mercury emissions.

8/12/2005