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Utilities face huge costs of complying with new EPA standards.
Fortnightly Magazine - October 15 2001

activities that are based on values, views, perceptions, philosophies, all of which can be political as opposed to scientific.

Despite this concern, it appears that environmental policymaking is in fact moving toward being based in"precautionary" science rather than based in science.

Moreover, the current emphasis among environmental groups, the United Nations and the Swedes is on "precautionary" science, according to recent statements. "I would argue that every decision we make is based on precaution," Whitman said, in the interview. "But it doesn't mean that you make the decision first without understanding what actions are doing to denigrate the environment," she added.

For example, she affirms to McLaughlin that there is no scientific consensus that reducing the so-called human-created greenhouse gases will "stop" climate change.

She rightly admits-since human emissions alone will not stop global climate change, as they come from a number of sources-it is a presumption that reducing human emissions can have a significant impact on reducing the rate of climate change and reducing the concentrations. But this does not mean the EPA should lay idle until the science supports action, she says.

"We know how effective we've been with acid rain and the impact that it has had on health and the environment overall. We know we can take steps to make things better; it's a question of how dramatically do you make the changes before you know whether those are the changes that are really going to affect the problem of global climate change?" Whitman says, describing the problem in a nutshell.

Maybe because the utility industry has learned through experience that the EPA will have its way, they have chosen to cooperate with this recent round of proposed environmental controls. As one utility executive put it to me, "We never get anywhere when we pit our scientists against their scientists."

Instead, most arguments voiced to the EPA emphasize how environmental controls should not inhibit the competitiveness of market players by being too costly, bureaucratic or impeding reliability. Most utilities and IPPs have voiced their support for the new EPA proposals, even with the knowledge that they spent $40 billion in low-emission and emission control technologies on previous programs, and may be obligated to spend at least as much.

Meanwhile, the Clean Power Group, whose members include Calpine, El Paso, Enron, NiSource and Trigen, advocate a cap and trade program, with a cap reduction program on all four major pollutants, and removal of the New Source Review program.

The NSR is a preconstruction permit program for new or modified major stationary sources. The program ensures that when large, new facilities are built - or major modifications to existing facilities are made that result in a net emission increase - they include state-of-the-art emissions equipment. It is also a program that seems to be disliked by utilities and IPPs alike.

Paul King, executive vice president, power operations and fuels for Cinergy Power Generation Services, in a press statement, likened the NSR requirements to the EPA imposing additional emissions restrictions without seeking legislation. He said the EPA's current interpretation of NSR