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A Multi-Pollutant Strategy

An integrated approach could prove more effective for controlling emissions.

Fortnightly Magazine - January 2009

that EPA recently had promulgated in the NOx SIP Call.

EPA took that analysis and engaged in a dialogue with representatives of the power and mining industries that the Edison Electric Institute helped to organize. Analysis performed by the Energy Information Administration and others also played into the dialogue, along with increased interest in considering meaningful control levels and removing or reducing CAA requirements deemed duplicative or less effective.

In support of the dialogue, EPA staff put forth a hypothetical option in May 1999 to reduce SO 2, NOx, mercury and CO 2 over a 10- to 15-year timeframe. The proposal extended cap and trade for SO 2 and NO x, created a new cap-and-trade program for CO 2 and established mercury maximum achievable control technology (MACT) standards. Specifically, it proposed discussion caps six to eight years out from 1999 with an interim SO 2 cap as a step-down to a 50-65 percent reduction beyond Title IV by 2010; additional 50 percent non-ozone season NOx reductions in the East and year round in the West; a mercury MACT requiring a 65 to 90 percent reduction in mercury content in flue gas; and a CO 2 cap at 7 percent below 1990 levels with 5-year budget. 8 Further, it would have revised New Source Review to complement the new approach.

In this effort, there were more clear drivers in play: 1) the 1997 NAAQS revisions and related looming due dates for PM2.5 (particulate matter) and regional haze state implementation plans (SIPs); 2) the 1997 adoption of the Kyoto Protocol; and 3) increasingly advanced knowledge of the mercury problem. However, the initial appellate court decision in 1999 that remanded the 1997 NAAQS for ozone and fine particles led to an end of this particular dialogue.

Congress Joins the Game

Also in 1999, Senators Moynihan and Schumer, both of New York, introduced S.172, the Acid Deposition and Ozone Control Act. The bill would have cut annual SO 2 emissions by an additional 50 percent from Title IV levels six years out, beginning in 2005, and created a new cap-and-trade program for NOx to reduce power-sector emissions nationwide by approximately 60 percent below levels projected to result from Title IV (with provisions to encourage reductions in summer months). The bill also included mercury monitoring and reporting provisions.

In July 2000, EPA provided an analysis of the environmental impacts, costs, and benefits of S.172. The analysis found annualized monetized human health benefits from reductions in PM2.5 of close to $75 billion and visibility benefits of $1.5 billion annually as compared to a compliance cost of $6 billion in 2010. This analysis found the NO x and SO 2 reductions cost $1,220 and $830 per ton, respectively. 9 As found in the CAPI analysis, emissions of both pollutants were reduced significantly across the country, with the greatest reductions in areas with the highest baseline emissions of both pollutants.

A series of bills arose to require multi-pollutant emission reductions by the power sector in the first half of this decade. The Bush administration introduced Clear Skies in