And I’d like to interject and say that Una Persson and Jshore are both models of decorum and civility, and I for one really appreciate this debate. The signal to noise ratio is always very high when either of you two are involved in a discussion. So hijack away!
I don’t really like my use of the word “naive” in retrospect because, besides being a little more negative connotation, it doesn’t really convey what I wanted it to. My point was that I think that saying that the Administration is just not actively supporting pro-active environmental efforts is ignoring the fact that, on the political landscape, they are quite far toward the side of the debate that is pushing most strongly to weaken environmental regulation. It’s not like they are not fighting the tide; they are largely causing the tide.
As for McCain-Lieberman, I think if a bill can get 40-some votes when the President opposes it and only a few senators from his party break ranks to support it would likely pass if it got endorsement from the President. The Republicans would really have to vote against him more in mass than they’ve done on anything else that I can think of in order to defeat it.
I certainly didn’t want to imply that Edison Electric Institute would be against Clear Skies! I’m sure it is a godsend for them! For one thing, it is claimed (and I think rightfully) that this sort of approach to pollution limits can be more efficient and provide more certainty for the industry. And, as I am trying to argue, for another, it is weaker than the limits they would face under business-as-usual. It’s a double bonus for them…One of these bonuses I am not opposed to because it could be win-win but the other one I am.
Here is a link to ClearTheAir.org that explains things. They used to have a better page that I can’t seem to find that explained the history. Basically, what they said was that several months before the Clear Skies Initiative was announced, the EPA gave a talk to the Edison Electric Institute. Two notable things were different in that talk:
(1) What they called the “straw man” proposal was basically Clear Skies but with considerably lower caps, demonstrating what EPA had in mind at the time. [I think it is the same as what I discuss below as the original EPA plan.] By the time the proposal was finalized, the caps had risen considerably.
(2) The numbers for emissions under the “business-as-usual” under the Clean Air Act scenario were also considerably lower than the numbers that were released as being the business-as-usual numbers when Clear Skies was unveiled. If you compared Clear Skies to the old “business-as-usual” numbers, then Clear Skies allowed considerably higher emissions than the Clear Air Act would achieve. However, if you looked at the new “business-as-usual” numbers, then Clear Skies looked a bit better than what the Clean Air Act would achieve.
At any rate, I can’t seem to find that page anymore, but from the page I did link to, here is the explanation of the different ways of comparing to what would happen under the Clean Air Act:
They then have a table comparing the original EPA proposal to the final Clear Skies plan. The EPA plan had a cap of 2 million tons of SO2 in 2010 whereas the final plan had a cap of 4.5 million tons in 2010 and 3 million tons in 2018. For NO2, the numbers for the EPA plan were 1.9 million tons in 2008 and 1.25 million tons in 2012. The final plan, by contrast has 2.1 million tons in 2008 and 1.7 million tons in 2018.
Note added in preview to pantom and Sam Stone: Thanks! I don’t think I’ve ever gotten such ringing endorsements (one from the OP no less) to hijack a thread.
Actually, here is a link to a (1.1 Meg) PDF file that contains the original presentation that EPA apparently gave to Edison Electric Institute in September 2001. I think the 10th page “Comparison of Requirements Under Business-As-Usual Proposal and Straw Proposal” is what Clear the Air was talking about in what I was speaking about above from memory. The EPA estimate of a 2.0 million ton cap for SO2 under business-as-usual by 2012 is pretty clear (as opposed to the final proposal of 4.5 million ton cap in 2010 and 3 million tons in 2018 under Clear Skies). I’m a little unclear how to read the NOx part because I don’t know what the “OTAG region” is.
:Gulp: :eek:40:eek: MPG??? [sub]: Does some quick calculations: [/sub] She wants to spend $140 billion on renewables???
Holy Nader, Mr. President! We have a loose cannon on board!
Yes, I know, it was facetious. Still…
By the way, I think page 12 of that EPA presentation is most interesting because it seems to be (implicitly) trying to tell the industry you have a choice:
(option 1) You can either support this straw man proposal which actually has somewhat tougher limits but we estimate will save you $3 billion dollars …or more, depending on what the states do… over business-as-usual by 2020.
OR
(option 2) You can face what you will under business-as-usual.
Of course, in reality, it looks like what the industry chose and got was:
(option 3) You can get us to give you all the cost-savings advantages of a cap-and-trade approach and then the additional cost savings of raising the caps to emission levels to a fair bit above what business-as-usual would require.
Given how this all seemed to have turned out, I am rather impressed with how well Edison has hid their glee in the supportive statements you quoted from them saying nonetheless how aggressive it is and how challenging it may be for companies to meet the requirements.
Umm…the main thing that confuses me is that they seem to be mixing PM2.5 in with Clear Skies. I mean, they seem to be saying that to meet PM2.5, SO2 reductions would have to be required (although those reduction levels are not specified by law currently) at some level they have assumed? I thought one benefit of Clear Skies was the fact that the high-density baghouses and additional wet scrubbing which would be required in most Hg removal schemes would reduce the PM2.5 emissions levels to the point where most plants would meet the 2009 limits?
I mean - in the discussions in the industry that have gone on with mercury removal, especially with studies by EPRI and UND-EERC, I thought the PM2.5 issue was not going to be an issue any more?
I see how the Clear Skies limits are not as tight as the August 2001 EPA proposal, and I see where you are coming from now. The main thing I see is how the values for the “implicit” SO2 and NOx levels were arrived at to determine PM2.5 compliance, and whether or not they account at all for the mercury removal schemes required under Clear Skies. It would appear to me that there could be a wide range of variation here.
News update: energy bill canned. Guess they couldn’t kill the filibuster. Medicare bill passed though. Interestingly, McCain was against both of them.
Umm…link? The latest from CNN shows:
http://www.cnn.com/2003/ALLPOLITICS/11/24/energy.vote.ap/index.html
Judas Priest - over MTBE???
Oh wait, I found it:
http://www.foxnews.com/story/0,2933,103997,00.html
OK, so it’s not “dead”, just “sleeping”.
Well, jshore my man, looks like we can pick this up in January. I’ll bet you’ll be simply on the edge of your seat 'till them.
Una, I think I lost you on the first two paragraphs in the lingo there. What is PM2.5 exactly? I presume it is some new tighter level of Clean Air Act standards that automatically kick in the future?
I agree that the prediction of what will be required under the Clean Air Act sounds like it is not very straightforward to calculate. But, the EPA nonetheless did calculate what they felt would be required and presented it in their Sept 2001 presentation to EEI. I suppose it is possible that EEI came back and said, “We think your calculations of the limits that will effectively be required under the Clean Air Act are too severe and thus you have set the caps in your straw man too draconian.” I don’t know how we could find out if this was part of their argument and how much evidence they had to support such a claim.
At any rate, I assume that everyone would agree that the Clean Air Act requirements will be significantly tighter than the so-called “Rip Van Winkle” scenario assumes, which is what both the Administration and EEI have taken to comparing Clear Skies limits too.
Actually, I noticed that even the Clear Skies limits are kind of confusing because a cap of, say, 4.5 million tons SO2 in 2010 does not mean that they really have to get down to that amount in 2010. Rather, they can “bank” up overcompliance between now and then (when the cap is higher…perhaps at 2001 levels or something; I wasn’t clear on that point) and then use those credits to undercomply in other years. I guess such a scheme makes some sense in order to insure that there is incentive to reduce right away rather than having “delta-function forces” at various times but it does make figuring out what will happen under Clear Skies not so trivial as one might expect. [This banking scheme was also in EPA’s original StrawMan proposal.]
Yeah…Speaking of Rip Van Winkle!!
Ummm…it’s the soot regulation that the sites you are linking to are talking about. I thought that was why you were posting the links you were. It’s referring to:
The 2009 deadline that your links refer to is assuming that PM2.5 is going to have a “setting” date of 2004 (as well as an 8-hour ozone standard), then the first “attainment” date is 5 years later, or 2009. However - the real question is - does the CAA mandate that the National Ambient Air Quality Standards for 8-hour ozone and PM2.5 actually be set in 2004? I’m having trouble finding a legal mandate for that - that was the administrative plan, but there does not seem to be legislation that forces that. If that is so, then the CAA does not actually require anything happen on those issues in 2004, and thus subsequently in 2009. Thus, I don’t know at this time if it’s fair to say that the CAA mandates stricter soot controls (as referenced on the sites you referenced) or not.
The thought is that reducing SO2 and NOx emissions would reduce the level of soot emitted from power plants, in addition to the photchemical smog. But the formation of the particualtes is a complicated mechanism, unlike quantifying SO2 and NOx, which is somewhat easier (well, OK, NOx isn’t that easy, but it’s not that hard either). The thing is, the understanding is that a lot of those very small particles are actually those escaping from electrostatic precipitators and poor fabric filter baghouse installations. Especially on plants which do not use wet scrubbers.
The NOx emissions are more closely tied to the ground-level ozone and the 8-hour standard, and I think that is much more clear. However, balancing out automobile VOC emissions and NOx emissions in cities with those from power plants is difficult, because ground-level ozone is a much more local phenomenon than something like acid rain. So even there it’s not clear to me how Clear Skies as applies to power plants is weaker than the CAA in effect.
Now, since the new regulations under any plan require large numbers of installations of wet scrubbers, and because one of the better ways to remove mercury is via a high-density fabric filter baghouse, it is believed as a result of testing mercury removal options that PM2.5 will not be hard to meet or exceed on units with mercury removal systems and/or wet scrubbers.
Well, I can’t deny that their caps became much more loose than their Fall 2001 report - that’s a plain fact. But what I’m questioning is whether either cap system is worse or better than the CAA business as usual. And if the bone of contention is PM2.5 and fine particulate removal, then I think that’s an issue that even industry “experts” are very divided on - in part because we don’t really know the best way to deal with the very fine particulate issue.
I believe I agree 100% with your assessment here.
The issues are just not that simple to be summed up as “web-bites” on either environmental advocacy or industry advocacy sites, jshore. And that is the problem - people want to find a quick summary “does this make things better or worse”, and except for a few glaring items on one side or the other, it’s really somewhat difficult to say.
According to Congressional Quarterly, the battle has now shifted to an intra-party dispute between Senate Energy and Natural Resources Committee Chairman Pete Domenici and House Majority Leader Tom DeLay.
I’m not comfortable reprinting much of the publication, but I’ll offer a quote from Domenici himself which was printed in one article this morning:
DeLay, apparently, is all in favor of just that.
Another example of how inability to compromise in Congress is exacly like blindfolded ballet dancing in a field full of rakes.
A note about the “trial lawyers” line. This looks like a perfect example of the "false dichotomy"argument used so deftly by the likes of blessedly-ex-Senator Slade Gordon in his “spotted owls or jobs” debates.
Una, I know lawyers and their blood-sucking ways pretty well by now, and I don’t specifically deny that a big MTBE class-action suit makes some trial lawyers drool (and probably, to a lesser extent, the horde of lawyers kept on retainer by the MTBE industry itself). However, as I said before the court cases in New Hampshire are in the process of evaluating responsibility. This waiver is specifically attempting to deny the ability to fairly assess blame, even when it looks to me like it was Uncle Sam who dropped the ball, not the MTBE producers.
It looks a little bit fishy to me.
I’m sure DeLay’s calculation went something like “trial lawyers give to Democrats”, “trial lawyers can make money off of MTBE lawsuits (maybe)”, therefore keep them from making money and giving even more to the Democrats.
Rather a straightforward political calculation. For him, it was probably the whole point of the bill.
Okay. Got it. My knowledge in this area is somewhat limited so I knew that the EPA felt that some regulation in the CAA would force reductions in SO2 and NOx to certain levels but I didn’t know exactly what the regulation was.
Okay, it does sound like the issue is quite complicated. However, we can simplify it in a few respects:
(1) All parties seem to be operating under the assumption that the big question is how much SO2, NOx and mercury emissions will go down under the various laws. You seem to argue that it may really be an oversimplification just to look at that, but at least at the moment, EEI, the White House, and Clear The Air all seem to use this as their starting point.
(2) Given that, we know that EPA tried to design a “straw man” proposal that would reduce these emissions comparably, or perhaps even a tad more, than they calculated (as best they could) they would be reduced under a “business-as-usual” assumption of enforcement of the Clean Air Act.
(3) The final Clear Skies Initiative proposal has considerably higher caps than the Straw Man proposal. Hence, we must infer that either new evidence was brought to light that the “business-as-usual” scenario would allow considerably higher emissions than the EPA had estimated in their Sept. 2001 report (evidence that I haven’t heard mention of anywhere but I admittedly haven’t searched that thoroughly) OR no new evidence was brought to light but this will somehow turn out to be true anyway OR the Clear Skies Initiative is a relaxation of the reductions in the total amount of emissions of these substances as compared to what a “business-as-usual” scenario would provide…i.e., it will result in higher emissions than under enforcement of the Clean Air Act.
(4) The comparison to the “Rip Van Winkle” scenario is a deceptive way of making emissions look like they will be cut more under Clear Skies than under the Clean Air Act, unless new evidence has come to light that somehow compliance with the Clean Air Act will not require any tightening of emissions standards from exactly how they exist today…which I haven’t seen anyone claim. What such a comparison says is only that Clear Skies would be better than what would be an upper bound on what emissions would be under the Clean Air Act, but this is an upper bound that there is no evidence to my knowledge is a very good (i.e., strong) upper bound, and the evidence from the EPA’s assessment of Sept 2001 is in fact that it is not.
So, while we may not be able to reach a definitive conclusion, I think the ball is certainly in the court of those of those claiming that Clear Skies is as good or better than business-as-usual to explain why this is the case and why this is at variance to what we would have to conclude based on the EPA’s Sept. 2001 report.
This may or may not be the last post for me before I go in-communicato over the Thanksgiving Holiday. Happy Holidays to all!
Well, Happy Holidays yourself! Hope you have a good turkey. We’re making a turkey with an Indian curry glaze/coating, and I plan on frightening the relatives by bringing a bright red turkey out of the oven.
We can talk about this later if you wish, or not. I think as this discussion has gone on we have explored a lot of the fine details ignored by the mainstream press (and even the focused advocacy press) and even if we are not in agreement, I hope that we have at least shown that there are a much larger range of issues at stake behind seemingly simple-sounding legislation and “web bites” opposing (or even in support) the Clear Skies and Energy Bill.