July 13, 2011 6:00 AM
Shaw, Ph.D. is chairman of the Texas Commission on Environmental Quality.
On July 7, the EPA released the Cross-State Air Pollution Rule (CSAPR). This is another rule in an endless line of new federal regulations, all with the stated purpose of improving air quality. Like so many other regulations from the EPA, this rule is aimed at cutting Texas jobs, cutting Texas economic growth, increasing Texas energy costs and harming Texas energy security.
Most alarming is EPA’s conscious curtailment of the due process rights of Texas and its citizens by failing to provide proper notice and opportunity to provide meaningful comments on the rule. EPA continues to parrot that Texas was given proper notice, but we maintain that a lone sentence in a 256-page proposed rule can hardly be considered adequate notice. While the TCEQ was proactive and submitted comments on the CSAPR, those comments cannot be considered meaningful. Why? Because EPA did not provide Texas with proposed emission budgets, time frames, etc., that EPA provided to every other state included in the proposed rule. Nor did the EPA contact Texas officials to alert them to Texas’ inclusion in the final rule.
To add insult to injury, Texas power plant emissions did not significantly contribute to downwind particulate matter (PM) pollution, based on the modeling in support of EPA’s proposal. In other words, Texas did not cross EPA’s “contribution threshold” and therefore should be excluded from the rule. However, in the final rule, EPA’s revised modeling now links Texas emissions to Madison County, Ill.—quite a distance. And in another questionable decision, EPA is issuing a supplemental proposal to take comment on the inclusion of six additional states found to significantly contribute to downwind ozone in the same post-proposal modeling. But Texas was not afforded that same opportunity.
The disparate treatment of Texas is troubling and flies in the face of proper notice and comment. The EPA’s late decision to add Texas in the PM portion of the rule and lack of transparency in this decision brings to question the validity of the science used and whether federally mandated SO2 reductions in Texas are necessary for public health protection.
This rule will impose great costs on coal-fired power plants, causing some to shut down or curtail operations, threatening the state’s electrical capacity reserve margins needed to avoid power disruption during times of peak demand. Such a scenario could lead to blackouts, which create serious health risks to Texans dependent upon reliable energy. Despite EPA’s assurances, it is difficult to see how other sources of energy-natural gas-fired plants, solar, or wind energy-can compensate for these shutdowns, given the rule’s January 2012 compliance date. If power plants are forced to shut down or curtail operations, Texans and the Texas economy will suffer.
For many Texans, increased energy costs and increased consumer costs merely mean further tightening of budgets that are already stretched thin. But for fixed- and low-income populations, the prospect of hot Texas summers and skyrocketing electric bills is frightening. And particularly for the elderly, this may mean threats to their health with an increased incidence of heat stroke and heat stress.
Like so many of EPA’s proposed rules- extreme tightening of ozone limits, “global warming” control schemes, attempts to nullify Texas’ very successful flexible permitting program- this rule seems not so much intended to improve the environment as to impose unnecessary, expensive federal controls on industry and increase the costs of energy to consumers. And increased energy costs also increase the price of nearly everything consumers purchase. It seems even more peculiar to impose these higher costs on Americans during a lingering recession.
The EPA has once again gone beyond their mission by recreating their own science. As with the pending new ozone standard, EPA has “proven” that protective levels of any emission simply do not exist. Under this administration, the only acceptable emission limit of any pollutant is zero. This philosophy is in direct contrast to a healthy environment, healthy economy, and sound science.
http://www.oaoa.com/opinion/texas-68449-epa-rule.html
Most alarming is EPA’s conscious curtailment of the due process rights of Texas and its citizens by failing to provide proper notice and opportunity to provide meaningful comments on the rule. EPA continues to parrot that Texas was given proper notice, but we maintain that a lone sentence in a 256-page proposed rule can hardly be considered adequate notice. While the TCEQ was proactive and submitted comments on the CSAPR, those comments cannot be considered meaningful. Why? Because EPA did not provide Texas with proposed emission budgets, time frames, etc., that EPA provided to every other state included in the proposed rule. Nor did the EPA contact Texas officials to alert them to Texas’ inclusion in the final rule.
To add insult to injury, Texas power plant emissions did not significantly contribute to downwind particulate matter (PM) pollution, based on the modeling in support of EPA’s proposal. In other words, Texas did not cross EPA’s “contribution threshold” and therefore should be excluded from the rule. However, in the final rule, EPA’s revised modeling now links Texas emissions to Madison County, Ill.—quite a distance. And in another questionable decision, EPA is issuing a supplemental proposal to take comment on the inclusion of six additional states found to significantly contribute to downwind ozone in the same post-proposal modeling. But Texas was not afforded that same opportunity.
The disparate treatment of Texas is troubling and flies in the face of proper notice and comment. The EPA’s late decision to add Texas in the PM portion of the rule and lack of transparency in this decision brings to question the validity of the science used and whether federally mandated SO2 reductions in Texas are necessary for public health protection.
This rule will impose great costs on coal-fired power plants, causing some to shut down or curtail operations, threatening the state’s electrical capacity reserve margins needed to avoid power disruption during times of peak demand. Such a scenario could lead to blackouts, which create serious health risks to Texans dependent upon reliable energy. Despite EPA’s assurances, it is difficult to see how other sources of energy-natural gas-fired plants, solar, or wind energy-can compensate for these shutdowns, given the rule’s January 2012 compliance date. If power plants are forced to shut down or curtail operations, Texans and the Texas economy will suffer.
For many Texans, increased energy costs and increased consumer costs merely mean further tightening of budgets that are already stretched thin. But for fixed- and low-income populations, the prospect of hot Texas summers and skyrocketing electric bills is frightening. And particularly for the elderly, this may mean threats to their health with an increased incidence of heat stroke and heat stress.
Like so many of EPA’s proposed rules- extreme tightening of ozone limits, “global warming” control schemes, attempts to nullify Texas’ very successful flexible permitting program- this rule seems not so much intended to improve the environment as to impose unnecessary, expensive federal controls on industry and increase the costs of energy to consumers. And increased energy costs also increase the price of nearly everything consumers purchase. It seems even more peculiar to impose these higher costs on Americans during a lingering recession.
The EPA has once again gone beyond their mission by recreating their own science. As with the pending new ozone standard, EPA has “proven” that protective levels of any emission simply do not exist. Under this administration, the only acceptable emission limit of any pollutant is zero. This philosophy is in direct contrast to a healthy environment, healthy economy, and sound science.
http://www.oaoa.com/opinion/texas-68449-epa-rule.html
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