Costly Change to Mercury Emission Standards
On December 28, 2018, the Trump administration announced that the Mercury and Air Toxic Standards (MATS) that restrict mercury emissions were too costly and without enough benefits to make them necessary. Those in favor of the restrictions argue that the real cost comes from changing the standards.
Why is mercury an issue?
Mercury is a heavy metal that is released into the atmosphere from a variety of sources, with coal burning power plants being one fo the primary sources. Once mercury is released into the air, rain and snow send it to the waterways, where it converts to the toxic methyl mercury. From there, it contaminates the water we drink and begins to work its way up the food chain beginning with smaller fish and accumulating at higher amounts in larger fish, such as salmon or tuna exposing humans to further risk.
Difference in cost-benefit analysis
The debate about the restrictions e. centered around the cost-benefit analysis of MATS, and specifically around what should be considered a co-benefit.
The original analysis issued by the EPA in 2011 factored in the co-benefits [JG1] of reducing particulate matter (PM) as well as the direct benefit from cutting back on hazardous air pollutant (HAP) emissions. In this analysis, the projected health savings were $59 billion to $140 billion annually. This more than offset the estimated $10.9 billion annual cost of regulating emissions.
Some of the health benefits identified include preventing:
- 6,800-17,000 premature deaths
- 120,000 cases of aggravated asthma
- 850,000 days of people missing work
- 5.1 million days of restricted activity
In 2018, though, the Environmental Protection Agency (EPA) produced a Supplemental Cost Finding proposing that including co-benefits related to PM is flawed, and the analysis should only consider quantifiable benefits from HAP reductions.
Using this revised approach, the health-related co-benefits would only be $4 to $6 million annually. Compared to the billions needed to enact the regulations, the new finding claims that it is not “appropriate or necessary” to regulate emissions, since it’s not cost-effective.
The proposal also indicates that while there are other benefits, they are unquantified and not enough to support the stricter standards.
Timing and intent
One of the surprises of the revised analysis is the timing. When MATS was passed, facilities had up to 5 years to meet the standards. This means that the majority have already paid to install the necessary technology to reduce emissions. Changing the standards now won’t give them that money back. On the other hand, many utilities are already recouping their investment through regulated pricing.
This has raised some questions about the intent of the supplemental analysis and who would benefit from the change.
Benefiting the coal industry
Power plants are the primary source of most pollutants, and within the power sector, coal-fired plants produce 99% of mercury emissions. They also generate the majority of other pollutants. As a result, they’re the most impacted by MATS.
Those coal plants would therefore stand to gain the most. It’s uncertain how helpful this would be, however, given that coal-fired power generation has fallen more than 40% since 2007.
Opening the door to health problems
Changing the cost-benefit approach could set a dangerous precedent. It could set a new standard the way health benefits are considered for all future standards and environmental rulings. Such a change is significant because of the potential damages.
Mercury is a neurotoxin that can damage the brains and nervous systems of unborn babies and young children. As a result, consuming fish with high mercury levels can cause serious harm, especially for children, nursing mothers, and women who are pregnant or might become so. The EPA estimates that each year, more than 300,000 newborns may have a higher percent of learning disabilities due to mercury exposure.
Other health impacts can affect all ages and include damage to the brain, heart, kidneys, liver, and immune systems. This can lead to muscle weakness, loss of peripheral vision, lack of coordination, speech impairment, and impaired hearing and walking.
Mercury is widespread – including in Maine
What makes the health implications even more worrisome is that mercury is widespread, and it lingers for a long time. A study by the EPA in 2009 found that 48% of lakes and reservoirs nationwide had levels of mercury exceeding the guidelines (0.3 parts per million).
Maine is far from immune, since prevailing winds bring mercury emissions from coal-powered plants in the west. The state of Maine already warns people that due to pollutants, they should not have more than two servings of fresh-caught fish per month, depending on where fish are caught.
But restrictions on mercury emissions have been making a difference. According to research done by Nicholas Fischer of Stony Brook University in New York, mercury has been decreasing in the Gulf of Maine. This has also led to lower levels of mercury in tuna, declining at the rate of 2% per year.
Rolling back standards has potential for increased costs in several areas
Those gains would likely be lost, though, if the new proposal goes through. Also, while the coal industry might have a reduction in costs, other sectors – such as recreation, education, and employment – could see higher costs.
For example, the original cost-benefit analysis pointed to 5.1 million days of restricted activity due to emissions. Those impacted won’t be out skiing, hiking, hunting, or fishing, something that hurts states like Maine who have economies that are dependent upon eco-tourism.
The cost impacts on education is another factor. Mercury negatively impacts the brainmdevelopment of young children who are exposed to it; children effected by mercury exposure will need extra care and support in educational settings. According to the National Education Association, a student who needs this sort of assistance can cost $9,369 more to educate than a student who does not need assistance.
When these students become adults, their opportunity for employment and earnings will likely be reduced by those early health impacts.
Mercury levels also have implications for the fishing industry. Bluefin tuna are only now beginning to make a comeback after conservation efforts. They’ve recovered enough to allow some fishing in the Gulf of Maine, including an 801-pound catch in 2018. Ttheir economic impact is considerable. In 2013, a single bluefin sold for more than $1.75 million at a Japanese auction.
Unfortunately, these tuna are also likely to have elevated levels of mercury, especially if emissions increase. If the fish become more dangerous to consume, they’ll be less viable in the Maine economy.
Additionally, mercury has a negative health impact directly on fish. Elevated mercury levels can slow growth and development in wildlife and fish, and reduce their rate of reproduction. That doesn’t bode well for an economy that relies heavily on fishing and brought in $616.50 million in 2015.
Conclusion
Although the health benefits from reduced emissions are not easily quantifiable, they are still significant and shouldn’t be discounted. It also seems counter-productive to remove standards when the costs of implementing them have already been paid. The Trump administration would do better to leave the standards in place so the people of Maine, and the rest of the country, can enjoy the benefits.
[JG1]Define co-benefit 8