EPA Mercury MACT [Maximum Achievable Control Technology] Rulemaking Not Justified by Science

The White Paper:

EPA Mercury MACT [Maximum Achievable Control Technology] Rulemaking Not Justified by Science. W. Soon and R. Ferguson.
http://ff.org/centers/csspp/pdf/mercurywhitepaper.pdf

Review This White Paper’s Executive Summary / Overview:
http://ff.org/centers/csspp/pdf/mercurywhitepaper.pdf

The Purpose of this White Paper:
These authors review whether they believe that the EPA is properly developing reasonable and effective rules that will require the U.S. electric utility industry to install controls to reduce mercury emissions from coal-fired and oil-fired power plants in the United States.

Some Background, Methods, Results, Caveats, and Other Select Points:

• This is not a peer-reviewed, scientific paper.
  
• The year this white paper was first publicly distributed is not given in this white paper.
  
• These authors state that they believe that mercury that comes directly from power plant smokestacks does not harm people who are exposed to these mercury emissions into the air. These authors believe that for mercury to even be a potential human health hazard, the mercury must first undergo a complex chain of chemical changes before mercury is actually in the form of methylmercury. Methylmercury is the certain chemical which must be eaten by people – primarily by eating certain types and amounts of certain fish – to be harmful to people.
  
• These authors state that the EPA in its Notice of Regulatory Finding states that our own EPA cannot measure just how much methylmercury found in fish actually starts-out in waste gas emissions from U.S. coal-fired and oil-fired electric power plants.
  
• These authors believe that there appears to be no scientific basis to believe that coal-fired and oil-fired, electric power plant mercury emissions are large and/or threaten the U.S. public health and/or welfare. These authors base these beliefs on: 1) various studies they have reviewed about mercury emissions sources; 2) transport and deposition patterns; and 3) certain types of scientific studies.

A Bottom Line:
These particular authors believe that certain mercury emission regulations are not needed in the United States because these federal government regulations are supposed to follow certain congressional directions to the EPA to study the reasonably-anticipated, public health hazards caused by hazardous air pollutants (including mercury) emissions from coal-fired and oil-fired, electric utility, steam-generating, electric power plants. The EPA is then supposed to put together certain control standards for U.S. coal-fired and oil-fired, electric power plants only if the required studies show that such mercury emissions regulations standards are appropriate and necessary.

• These two authors believe that the available scientific facts indicate that this particular EPA mercury emissions regulatory rulemaking is not now needed in the United States.
  
• These authors believe that their perceived EPA failure to provide a reasonable and comprehensive scientific basis for its EPA methylmercury emission regulatory rulemaking violates actually what the Congress meant and intended when the Congress stated that science should rule when the federal government regulates mercury emissions from U.S., coal-fired and oil-fired, electric utility companies.

Find This White Paper for Your Review:
EPA Mercury MACT [Maximum Achievable Control Technology] Rulemaking Not Justified by Science.
http://ff.org/centers/csspp/pdf/mercurywhitepaper.pdf