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Comments on NRDC's Testimony on Power Plant Regulation

Issue Analysis

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Comments on NRDC's Testimony on Power Plant Regulation

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The Natural Resources Defense Council (NRDC) is the leading force behind Sen. James Jeffords's (I-Vt.) Clean Power Act (S. 366), a bill that would impose costly new controls on power plant emissions of sulfur dioxide, nitrogen oxides, mercury, and carbon dioxide. The Bush Administration’s Clear Skies Initiative, which would establish new controls on sulfur dioxide, nitrogen oxides, and mercury, but not carbon dioxide, is, in no small measure, a “me-too” response to Senator Jeffords’s bill. It is thus fair to say that NRDC is driving much of the debate in Washington over Clean Air Act “reform.”

NRDC Climate Center Director David Hawkins has testified twice on the Clean Power Act, and once on the Clear Skies Act (S. 485). Mr. Hawkins has argued that the Bush plan will kill thousands of Americans every year because it does not go far enough to reduce power plant emissions.

This paper examines NRDC’s claims regarding the health and mortality effects of fine particulate matter (PM 2.5) and mercury emissions. It finds that PM2.5 at current levels is unlikely to be increasing mortality, and that sulfate—the form of PM caused by power plant emissions—is a particularly implausible cause of deaths, because sulfate is not toxic. 

Current power plant mercury emissions are also an implausible cause of harm. Power-plant mercury is a concern because high levels are found in some non-commercial freshwater fish consumed by sport-fishers and their friends and families. But less than one in 1,000 women have blood mercury levels as high as those associated with even subtle reductions in children’s neurological health. Furthermore, as EPA concluded, no one knows where the mercury in fish is coming from. Most of it may come from past emissions that remain in the environment and are continually deposited and reemitted, and/or from areas outside the U.S. where mercury emissions are much higher. Thus, there is a significant risk that mandatory reductions in power plant mercury emissions will not significantly reduce mercury levels in freshwater fish.

Because higher incomes allow people to enhance their overall health and safety, the economic burdens of the Clean Power Act and the Clear Skies Act are likely to do more harm than good for public health.