All Pain and No Gain

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Executive Summary

The U.S. Environmental Protection Agency’s (EPA) Utility MACT Rule establishes the first-ever maximum achievable control technology (MACT) standards for emissions of hazardous air pollutants (HAPs) fromcoal- and oil-fired power plants.

Mercury is the principal HAP targeted by the Rule. Unlike most air pollutants, mercury poses health risks not via inhalation but after being deposited in bodies of water. Microbes can transform some of the mercury into an organic form, methylmercury, which can accumulate in aquatic food chains.

The EPA contends that pregnant women in subsistence fishing households consume enough methylmercury in self-caught fish to impair fetal cognitive and neurological development. The MACT Rule supposedly reduces the risk to unborn children by lowering methylmercury concentrations in non-commercial fish. But the agency provides no empirical evidence that any American children are harmed by mercury emissions.

With an EPA-estimated annual compliance cost of $9.6 billion, the Utility MACT Rule is one of the most costly environmental regulations in the nation’s history.The EPA claims that the Rule will deliver up to $80 billion in annual net benefits, with no risk of significant adverse impacts on fuel choice, electric supply reliability, or employment. These claims are false.