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Fact Sheet About The Bush Administration’s Proposal
to Gut the Clean Air Act’s Power Plant Clean Up Provisions
- The Bush Proposal Will Result in Significant Additional Premature
Deaths, Asthma and other Chronic Respiratory Conditions, and Significant
Associated Societal Costs, as Compared with Implementation of the
Clean Air Act’s PSD Provisions as Congress Intended.
EPA’s Modelling
Runs for
this Proposal are Flawed and Misleading. They compare emissions outcomes
under the proposal with a “do nothing” scenario
that assumes the Act’s PSD provisions will not yield any emissions
reductions benefits, and therefore that the proposal will not create
environmental
or public health damage. But the “do nothing” scenario is
not legal. A meaningful comparison of the proposal, with an all BACT scenario,
shows that the proposal will result in significant environmental and
public
health damage:
- The Energy Information Agency modelled the emissions expected
in 2020 from applying BACT on the national fleet of older coal-fired
plants.
Comparing the results of that modelling to EPA’s proposal shows
that an additional 7 million tons of sulfur dioxide and
about 2.4 million
tons of nitrogen oxides per year would be emitted under the Bush
proposal
than if the Clean Air Act’s PSD provisions were implemented as
Congress intended.
- EPA’s own analysis of the public health benefits of achieving
levels of SO2 and NOx similar to those associated with administration
of
the Act’s PSD requirements as Congress intended would yield, by
2020, at
least:
• 24,000 avoided premature deaths per year
• 465,000 avoided asthma attacks per year
• 14,500 avoided cases of chronic bronchitis per year.
These benefits will not be realized under the Bush proposal.
The
loss of these benefits represents a cost to society of approximately
$6.32
billion dollars per year, in 2001 dollars.
- There Is No Legal Basis For the Bush Administration’s Cost-Based
or Like Kind Replacement Exclusions:
The language of the Clean Air Act requires an assessment of air pollution
increases resulting from changes made at existing facilities.
 The
Bush Proposal Does NOT.
Congress intended the PSD provisions of the Act to improve air quality and public
health over time, through eventual clean up at least to Best Available Control
Technology (BACT), or the retirement of heavily polluting older power plant and
other industrial facilities.
The Bush Proposal Is a Dirty Facility Immortality Rule.
The courts have said that exclusions for projects from these requirements can
be justified only case-by-case, for reasons of administrative necessity, or because
they would not yield significantly increased emissions.
The Bush Proposal Creates Blanket Exclusions That Will Result in Significant
Annual Emissions Increases.
- Record Evidence from the Tennessee Valley Authority Enforcement
Cases Illustrates that EPA’s Proposal Would Allow Major, Non-Routine,
Facility
Life Extending Construction Projects to Avoid PSD, and Pollution
Controls, Entirely.
One example (there are many others):
TVA Allen Plant
Unit 3
was refurbished in 1992-1993. According to TVA Management and Engineering
personnel, that refurbishment was neither
“routine” nor “maintenance.” The Act requires such projects to undergo
PSD review, and to apply BACT if total emissions would increase as
a result.
Cost of the Allen Plant Unit 3 Construction Project: $10.8 million.
Cost of replacing Allen Plant Unit 3: $ 430.65 million.
Cost of Project compared with unit replacement cost: 2.5%.
EPA’s lowest suggested RMRR utility industry percentage: 5%.
The Bush Proposal Would Allow Such Major Life Extension Projects to Routinely
Bypass Review – a Dirty Facility Immortality Guarantee.
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