EPA mercury rules for electricity generating units are based on false science and economics

Craig Rucker

The Environmental Protection Agency clams its “final proposed” Maximum Achievable Control Technology (MACT) rules will eliminate toxic pollution from electrical generating units, bring up to $140 billion in annual health benefits, and prevent thousands of premature deaths yearly - all for “only” $11 billion a year in compliance costs.

This may be true in the virtual reality of EPA computer models, linear extrapolations, cherry-picked health studies and statistics, government press releases and agency-generated public comments. However, in the real world inhabited by families, employers and other energy users, the new rules will bring few benefits, but will impose extensive costs that the agency chose to minimize or ignore in its analysis.

Emissions of mercury and other air toxics from power plants have been declining steadily for decades, as older generating units have been replaced with more efficient, less polluting systems or retrofitted with better pollution control technologies. While a few older plants still violate EPA’s draconian proposed rules - the new rules are not based on credible scientific and epidemiological studies.

As independent natural scientist Dr. Willie Soon and CFACT policy advisor Paul Driessen pointed out in their Wall Street Journal and Investor’s Business Daily articles, and in Dr. Soon’s 85-page critique of EPA’s draft rules, US power plants account for only 0.5% of the mercury in US air. Thus, even if EPA’s new rules eventually do eliminate 90% of mercury from power plant emission streams, that’s still only 90% of 0.5% - ie, almost zero reduction. The rest of the mercury in US air comes from natural and foreign sources, such as forest fires, Chinese power plants and the cremation of human remains (from tooth fillings that contain mercury and silver).

EPA fails to recognize that mercury is abundant in the earth’s crust. It is absorbed by trees through their roots - and released into the atmosphere when the trees are burned in forest fires, fireplaces and wood-burning stoves. In fact, US forest fires annually emit as much mercury as all US coal-burning electrical power plants. Mercury and other “pollutants” are also released by geysers, volcanoes and subsea vents, which tap directly into subsurface rock formations containing these substances.

The agency compounds these errors by claiming fish contain dangerous levels of mercury that threatens the health and mental acuity of babies and children. In making this claim, the agency commits four more grievous errors. First, it ignores the fact that selenium in fish tissue is strongly attracted to mercury molecules and thus protects people against buildups of methylmercury, mercury’s more toxic form.

Second, EPA based its toxicity claims on a study of Faroe Islanders, who eat few fruits and vegetables, but feast on pilot whale meat and blubber that is high in mercury and polychlorinated biphenyls (PCBs) - but very low in selenium. Third, it ignored a 17-year Seychelles Islands evaluation, which found “no measurable cognitive or behavioral effects” in children who eat five to twelve servings of fish per week.

Fourth, it used computer models to generate linear extrapolations from known or assumed toxic levels down to much lower levels. Not only is this method contrary to sound science and epidemiology; it resulted in politicized “safety” levels that are twice as restrictive as Canadian and World Health Organization mercury standards, three times more restrictive than US Agency for Toxic Substances and Disease Registry, and four times tougher than US Food and Drug Administration recommendations.  No wonder the Centers for Disease Control says blood mercury levels in US women and children are already well below excessively “safe” levels set by EPA.

Simply put, EPA grossly exaggerated the health benefits of its proposed mercury rules - and then claimed additional mercury benefits based on double counting of reductions in particulate matter. It also ignored the adverse effects that its rules will inflict. Not only is EPA’s anti-mercury campaign scaring mothers and children into not eating nutritious fish that is rich in Omega-3 fatty acids. It is also raising electricity heating, air conditioning and food costs, impairing electrical reliability, costing jobs, and thereby harming the health and welfare of countless Americans.

Energy analyst Roger Bezdek has calculated that utilities will have to spend $130 billion to retrofit older plants - and another $30 billion a year to operate, maintain and power the energy-intensive pollution control equipment they will be forced to install. Moreover, under its MACT rules, EPA intends to micromanage every aspect of power plant operations. It will now cite companies for violations even if emissions fully comply with air quality standards, if operators merely deviate from new agency “work practice standards” and “operational guidelines,” even under unusual weather conditions or equipment malfunctions that are beyond the operators’ control.

While it is true that older power plants are more significant sources of toxic air emissions, those plants are mostly in key manufacturing states that burn coal to generate 48-98% of their electricity. Many utility companies cannot justify those huge costs - and thus plan to close dozens of units, representing tens of thousands of megawatts - enough to electrify tens of millions of homes and small businesses. Illinois alone will lose nearly 3,500 MW of reliable, affordable, baseload electricity - with little to replace it.

Electricity consumers could pay at least 20% more in many states within a few years. According to the Chicago Tribune, Illinois families and businesses will pay 40-60% more. That will severely affect business investment, production and hiring - and family plans to repair cars and homes, save for college and retirement, take vacations, or have health physicals or surgery.

Chicago public schools will have to pay an additional $2.7 million annually for electricity by 2014, says the Tribune. Hospitals, factories and other major electricity users will also be hard hit. Many poor and minority families will find it increasingly hard to afford proper heating and air conditioning. Further job losses and economic stress will lead to further reductions in living standards and nutrition, more foreclosures and homelessness, and additional drug, alcohol, spousal and child abuse.

The very reliability of America’s electricity grid could be at risk, if multiple power plants shut down. Brownouts, blackouts and power interruptions will affect factory production lines, hospital, school, farm and office operations, employment, and the quality of food, products and services.

The impact on people’s health and welfare is patently obvious. But EPA considered none of this.

EPA insists there was strong public support for its rules. However, its rules were clearly based on false, biased or even fraudulent information. Furthermore, EPA itself generated much of that public support.

The agency recruited, guided and financed activist groups that promoted its rulemaking. Over the past decade, it gave nearly $4 billion to the American Lung Association and other advocacy organizations and various “environmental justice” groups, according to a Heritage Foundation study. EPA Administrator Lisa Jackson and members of her staff also visited historically black and other colleges - giving speeches about “toxic emissions,” providing templates for scare-mongering posters and postcards, and making it easy for students to send pro-rulemaking comments via click-and-submit buttons on websites.

This EPA action does nothing to improve environmental quality or human health. In fact, by advancing President Obama’s goal of shutting down power plants and raising electricity costs, it impairs job creation, economic recovery, and public health and welfare. It is intrusive government at its worst.

It is a massive power grab that threatens to give EPA nearly unfettered power over the electrical power we need to support our livelihoods and living standards.

Congress, states, utility companies, affected industries, school districts and hospitals, and families and citizen groups should immediately take action to postpone the MACT rules’ implementation. Otherwise, their harmful impacts will be felt long and hard in states that depend on coal for their electricity.

Craig Rucker is CEO of the Committee For A Constructive Tomorrow. 

By Brendan O’Neill, ABC Drum

What is it about freakishly cold winters that so agitates intolerant moralists?

In Europe 500 years ago, any sign of a dip in the winter weather would be greeted by much gnashing of teeth from the morality police. Sometimes they’d even burn at the stake “witches” who were said to have caused the extreme cold through their wicked behaviour and sorcery.

Fast-forward to the 21st century and still there’s nothing like a bitingly cold winter to drive moralists mad with priestly fury. Only today, in a more PC, less pyromaniacal version of what their forebears did, they don’t burn people at the stake for causing cold winters - no, they prefer to hector us with op-eds and insults instead.

The last couple of winters in western Europe have been bitterly cold. Last year the British Isles were coated in thick snow, causing chaos. This winter is shaping up to be a bit warmer, though cold snaps are expected in the new year.

All this iciness has put green-leaning moralists in a tailspin. They scour the press and the blogs for any whiff of a hint of a suggestion that perhaps these cold winters disprove the global-warming thesis, and inform us that, actually, extreme coldness is yet another side-effect of man’s constant farting of CO2 into the environment.

This week, a top Welsh scientist highlighted one of the key problems associated with very cold winters - no, not the possibility of elderly people going hypothermia or an increased risk of car accidents on slushy roads, but the danger that the dumb public will think all this snow proves hot-headed environmentalists wrong.

Professor Michael Hambrey of the University of Aberystwyth said “the public must not be misled into believing that a series of cold winters are evidence that climate change is a myth”.

Echoing green activists, who get strangely defensive during very cold winters, Professor Hambrey reminded us that climate change is not only going to make the world hellishly hotter but will also lead to a situation where “more extreme winters become the norm”.

Last year, during Britain’s big freeze, greens incessantly lectured us about how cold winters are just as much the fault of greedy, hubristic, polluting man as recent heatwaves and droughts have been.

A writer for The Times said anyone who seizes the opportunity of a wicked winter to ask “what happened to global warming?” is an “idiot”, because nobody ever claimed that climate change would “make Britain hotter in the long run”. (Er, yes they did.)

A headline in the Guardian informed us that: “The snow outside is what global warming looks like”, and the reason the plebs and simpletons who make up modern Britain can’t understand this fact is because they are:

“simple, earthy creatures, governed by the senses… What [they] see and taste and feel overrides analysis. The cold has reason in a deathly grip.”

Perhaps. Or perhaps the reason the public’s cynicism towards environmentalism goes up a notch whenever it snows is because for the past 10 years, before the recent big freezes set in, environmentalists told us we’d never see snow again.

“Snow is starting to disappear from our lives”, declared the Independent in March 2000, quoting an expert from the Climatic Research Unit at the University of East Anglia - a major producer of climate-change info - saying that “children just aren’t going to know what snow is”.

Mark Lynas, one of Britain’s chief climate-change alarmists, told us in 2004 to prepare for life on a “hotter planet” in which “the traditional British winter [is] probably gone for good”.

And yet today, any mortal who dares to wonder out loud why it’s snowing so much if the planet is supposed to be getting hotter is told to shut up, branded an “idiot”, pityingly looked upon as a “simple creature” lacking reason. Weird wintry weather is as manmade as hotness is, we’re told. In short, snow, like floods and droughts and plagues of locusts, is another by-product of our destructive behaviour.

These greens don’t seem to realise how much they sound like medieval witch-hunters. In the Dark Ages, before man enlightened himself, witches were frequently hunted and burned on the basis that they were causing climate change - specifically very cold winters.

One of the driving forces behind the witch-hunting mania in Europe between the 15th and 17th centuries was the idea that these peculiar creatures had warped the weather.

As the German historian Wolfgang Behringer argued in his 2004 book, Witches and Witch-Hunts, “large-scale persecutions were clearly linked to years of extreme hardship and in particular the type of misery related to extreme climatic events”.

So during the Little Ice Age, the period of unusual coldness that started around the mid-1500s, there was an upsurge in witch-hunting. There was another outburst in 1628, described by historians as “the year without a summer”, because once again people’s crops failed and they were desperate to find someone to blame. As Behringer puts it, when the “climate stayed unfavourable or ‘unnatural’ the demand for persecutions persisted”.

Johann Weyer, the 16th-century physicist who spoke out against witch-hunting, described how one woman was forced to confess to causing climate change:

“[A] poor old woman was driven by torture to confess - as she was about to be offered to Vulcan’s flames - that she had caused the incredible severity of the previous winter of 1565, and the extreme cold, and the lasting ice.”

Pointy-hatted Witchfinder Generals were convinced that foul, immoral people, through the magic of their thoughts and words, had conjured up climatic mayhem and icy conditions. Sound familiar? Yep - today, too, hectoring moralists hold wicked human beings responsible for causing unusual coldness.

In the old witch-hunting era, it was a powerful sense of social uncertainty and fear of the future which led the priestly class to view mysterious individuals as being culpable for climate change. Today, too, a similarly profound social and moral malaise has led elite greens to claim that the throng, with its reckless ways and insatiable material desires, is causing dangerously freezing/hot conditions.

Of course, in one important way today’s green moaners are more enlightened than the witch-hunters of old: they don’t hurl anyone on to “Vulcan’s flames”. But in another sense they’re more backward than the medieval moralists since they don’t only old a few sad old women responsible for climatic disarray, but rather point the finger of blame at everyone - all the “idiots” and “simple creatures” whose desire for stuff and wealth and holidays is apparently causing both cruel summers and harsh winters. In the eyes of the green lobby, we are all witches now.

By Anthony Watts

The post below on Dr. Roy Spencer’s blog that contains responses from Spencer and Christy deserves wide distribution and attention, because it shows just how badly Ben Santer and John Abraham want to squelch this dataset. Particularly amusing is the labeling of a graph in an Andrew Freedman article at WaPo as a listing of “corrections”, when in fact it is nothing more than the advance of the trend in step with the graph below (enlarged).

Addressing Criticisms of the UAH Temperature Dataset at 1/3 Century
by Roy W. Spencer, Ph. D.

The UAH satellite-based global temperature dataset has reached 1/3 of a century in length, a milestone we marked with a press release in the last week (e.g. covered here).

As a result of that press release, a Capital Weather Gang blog post by Andrew Freedman was dutifully dispatched as damage control, since we had inconveniently noted the continuing disagreement between climate models used to predict global warming and the satellite observations.

What follows is a response by John Christy, who has been producing these datasets with me for the last 20 years:

Many of you are aware that as a matter of preference I do not use the blogosphere to report information about climate or to correct the considerable amount of misinformation that appears out there related to our work. My general rule is never to get in a fight with someone who owns an obnoxious website, because you are simply a tool of the gatekeeper at that point.

However, I thought I would do so here because a number of folks have requested an explanation about a blog post connected to the Washington Post that appeared on 20 Dec. Unfortunately, some of the issues are complicated, so the comments here will probably not satisfy those who want the details and I don’t have time to address all of its errors.

Earlier this week we reported on the latest monthly global temperature update, as we do every month, which is distributed to dozens of news outlets. With 33 years of satellite data now in the hopper (essentially a third of a century) we decided to comment on the long-term character, noting that the overall temperature trend of the bulk troposphere is less than that of the IPCC AR4 climate model projections for the same period. This has been noted in several publications, and to us is not a new or unusual statement.

Suggesting that the actual climate is at odds with model projections does not sit well with those who desire that climate model output be granted high credibility. I was alerted to this blog post within which are, what I can only call, “myths” about the UAH lower tropospheric dataset and model simulations. I’m unfamiliar with the author (Andrew Freedman) but the piece was clearly designed to present a series of assertions about the UAH data and model evaluation, to which we were not asked to respond. Without such a knowledgeable response from the expert creators of the UAH dataset, the mythology of the post may be preserved.

The first issue I want to address deals the relationship between temperature trends of observations versus model output. I often see such posts refer to an old CCSP document (2006) which, as I’ve reported in congressional testimony, was not very accurate to begin with, but which has been superseded and contradicted by several more recent publications.

These publications specifically document the fact that bulk atmospheric temperatures in the climate system are warming at only 1/2 to 1/4 the rate of the IPCC AR4 model trends. Indeed actual upper air temperatures are warming the same or less than the observed surface temperatures (most obvious in the tropics) which is in clear and significant contradiction to model projections, which suggest warming should be amplified with altitude.

The blog post even indicates one of its quoted scientists, Ben Santer, agrees that the upper air is warming less than the surface - a result with which no model agrees. So, the model vs. observational issue was not presented accurately in the post. This has been addressed in the peer reviewed literature by us and others (Christy et al. 2007, 2010, 2011, McKitrick et al. 2010, Klotzbach et al. 2009, 2010.)

Then, some people find comfort in simply denigrating the uncooperative UAH data (about which there have been many validation studies.) We were the first to develop a microwave-based global temperature product. We have sought to produce the most accurate representation of the real world possible with these data - there is no premium in generating problematic data. When problems with various instruments or processes are discovered, we characterize, fix and publish the information. That adjustments are required through time is obvious as no one can predict when an instrument might run into problems, and the development of such a dataset from satellites was uncharted territory before we developed the first methods.

The Freedman blog post is completely wrong when it states that “when the problems are fixed, the trend always goes up.” Indeed, there have been a number of corrections that adjusted for spurious warming, leading to a reduction in the warming trend. That the scientists quoted in the post didn’t mention this says something about their bias.

The most significant of these problems we discovered in the late 1990’s in which the calibration of the radiometer was found to be influenced by the temperature of the instrument itself (due to variable solar shadowing effects on a drifting polar orbiting spacecraft.) Both positive and negative adjustments were listed in the CCSP report mentioned above.

We are always working to provide the best products, and we may soon have another adjustment to account for an apparent spurious warming in the last few years of the aging Aqua AMSU (see operational notes here). We know the data are not perfect (no data are), but we have documented the relatively small error bounds of the reported trends using internal and external evidence (Christy et al. 2011.)

A further misunderstanding in the blog post is promoted by the embedded figure (below, with credit given to a John Abraham, no affiliation). The figure is not, as claimed in the caption, a listing of “corrections”:

The major result of this diagram is simply how the trend of the data, which started in 1979, changed as time progressed (with minor satellite adjustments included.) The largest effect one sees here is due to the spike in warming from the super El Nino of 1998 that tilted the trend to be much more positive after that date. (Note that the diamonds are incorrectly placed on the publication dates, rather than the date of the last year in the trend reported in the corresponding paper - so the diamonds should be shifted to the left by about a year. The 33 year trend through 2011 is +0.14C/decade.)

The notion in the blog post that surface temperature datasets are somehow robust and pristine is remarkable. I encourage readers to check out papers such as my examination of the Central California and East African temperature records. Here I show, by using 10 times as many stations utilized in the popular surface temperature datasets, that recent surface temperature trends are highly overstated in these regions (Christy et al. 2006; 2009). We also document how surface development disrupts the formation of the nocturnal boundary layer in many ways, leading to warming nighttime temperatures.

That’s enough for now. The Washington Post blogger, in my view, is writing as a convinced advocate, not as a curious scientist or impartial journalist. But, you already knew that.

In addition to the above, I (Roy) would like to address comments made by Ben Santer in the Washington Post blog:

A second misleading claim the (UAH) press release makes is that it’s simply not possible to identify the human contribution to global warming, despite the publication of studies that have done just that. “While many scientists believe it [warming] is almost entirely due to humans, that view cannot be proved scientifically,” Spencer states.

Ben Santer, a climate researcher at Lawrence Livermore National Laboratory in California, said Spencer and Christy are mistaken. “People who claim (like Roy Spencer did) that it is “impossible” to separate human from natural influences on climate are seriously misinformed,” he wrote via email. “They are ignoring several decades of relevant research and literature. They are embracing ignorance.” “Many dozens of scientific studies have identified a human “fingerprint” in observations of surface and lower tropospheric temperature change,” Santer stated.

In my opinion, the supposed “fingerprint” evidence of human-caused warming continues to be one of the great pseudo-scientific frauds of the global warming debate. There is no way to distinguish warming caused by increasing carbon dioxide from warming caused by a more humid atmosphere responding to (say) naturally warming oceans responding to a slight decrease in maritime cloud cover (see, for example, “Oceanic Influences on Recent continental Warming").

Many papers indeed have claimed to find a human “fingerprint”, but upon close examination the evidence is simply consistent with human caused warming - while conveniently neglecting to point out that the evidence would also be consistent with naturally caused warming. This disingenuous sleight-of-hand is just one more example of why the public is increasingly distrustful of the climate scientists they support with their tax dollars.