The President of the International Society for Environmental Epidemiology (ISEE) has written to the Administrator of the US Environmental Protection Agency (EPA) criticising the EPA’s proposal (84 Fed. Reg. 2670, Feb. 7, 2019) to reverse a prior well-founded finding that it is “appropriate and necessary” to regulate the emissions of mercury and other toxic air pollutants from coal-fired power plants.
Excerpt from letter follows:
The original finding by the US EPA was promulgated to protect the public from health damaging pollution emissions from electric generating power plants, and was the basis for the 2012 Mercury and Air Toxics Standards (MATS). The EPA’s newly proposed approach is based primarily on a narrowing of the economic calculation of monetised benefits resulting from mercury exposure reduction measures, and now inappropriately ignores the multiple ancillary human health co-benefits that the current regulatory approach includes, making the regulation of Hg appear less justified than it is. Indeed, the proposed assessment would completely, and inappropriately, ignore the substantial monetised human health benefits to the US public that would result from reductions in non-target pollutants that would also occur as a result of the Hg control measures, such as co-reductions of fine particulate matter (PM2.5) air pollution.
As scientists who have studied the human health effects of PM2.5 and other air pollutants over the past few decades, we can state with scientifically-based certainty that the human health benefits that are now being ignored by the US EPA are large and significant to the public health.
…Thus, the human health co-benefits from the co-reduction of PM2.5 air pollution that will be achieved by going forward with the MATS rule (and other future EPA air quality rules) must not be ignored. Moreover, if the benefits analysis were to be properly conducted to include those public health co-benefits, it would be clear that the MATS rule should be left in place as originally proposed by the US EPA.
On behalf of the ISEE, we strongly urge that the US EPA withdraw this harmful proposal, and instead retain its prior sound finding that it is both appropriate and necessary to regulate hazardous air pollutant emissions from electric generating units under Section 112(n)(1) of the Clean Air Act.
Full letter here .
It is also worth noting that secondary formation of PM2.5 is not routinely considered in air quality assessments in New Zealand.