"EPA cites coal plants"
August 7, 2007
Overview
There is an actual issue here but, typically, Hawthorne either doesn�t understand it or refuses to talk about it. Midwest Generation�s coal-fired plants are old. It was expected that they would be retired long ago. Unfortunately, it�s extremely difficult to open new power plants today, particularly in urban areas like Chicago, to replace them.
So Midwest Generation (and Commonwealth Edison, who used to own these plants) have faced a continuing choice: do they keep these plants going and invest in pollution control upgrades, or can they use our capital to build new, more efficient and cleaner plants? They have hoped to invest in the latter, but the regulatory environment has pushed them toward the first solution.
Hawthorne�s piece does not say that Midwest Generation�s plants operate without control, but it certainly leaves the reader with that impression. In fact, all of the plants cited have controls. They are older controls, to be sure, but they are controls that remove over 99 percent of the �soot� Hawthorne cites. It�s not a question of whether Midwest Generation should control these plants, it�s a question of whether the company needs to upgrade its existing controls.
Facts
1. Hawthorne says that soot and other forms of pollution combine to create smog. This is incorrect. He later, and correctly, defines smog as �ground level ozone.� Ground level ozone is created by a mixture of nitrogen oxides and volatile organic compounds. Soot�as particulate matter�does not enter into the equation.
2. Hawthorne says that plants that undergo major modifications are required to install pollution control devices under New Source Review. This is untrue. Plants that go through New Source Review must prove that they can meet specific, stringent emissions limits and that their controls meet the definition of Best Available Control Technology. It is not at all uncommon for a plant to meet those limits without installing new controls and for their existing controls to meet the �Best� definition. Adding or upgrading controls is simply an option.
Spin
1. Hawthorne calls Chicago air �dirty.� Really? Chicago air has gotten steadily cleaner for over 30 years. As it has cleaner, the EPA has tightened standards. The definition of �dirty,� therefore, has grown more and more stringent, as air quality continues to improve. Hawthorne either doesn�t understand this, or he chooses to ignore it.
It is as if your child went to a school where you need to average 90 percent to get an �A� grade. Your kid averages 91 percent, and receives the coveted grade. The next year, the school raises the �A� threshold to 93 percent. Your kid averages 92 percent, and dutifully gets a �B� grade. Did your child just get stupider?
2. Hawthorne says that Midwest Generation didn�t install controls required under the Clean Air Act. All of the Midwest Generation plants cited are controlled and meet permit limits. The implication that these plants are uncontrolled is incorrect. The only issue, as we discussed earlier, is whether the company should have upgraded those controls or not.
3. In discussing the cases that forced some power plants to upgrade their controls, Hawthorne says that these plants had been �upgraded, modified and expanded.� He does not tell you that those upgrades, modifications and expansions were permitted by regulatory authorities.
4. Hawthorne cites 7,600 pollution violations of Midwest Generation plants since 1999. Do these violations involve pollution, or do they involve paperwork? Do they represent instantaneous spikes in opacity, or are they continuing violations of air quality standards? We don't know, because Hawthorne doesn't tell us. If you look closely enough at any plant - not just a Midwest Generation plant - it's easy to rack up a list of violations. Whether those "violations" actually resulted in environmental harm is quite another matter.
5. Hawthorne talks about �bursts of soot� from Midwest Generation plants. No one can say whether these plants emitted �busts of soot� or not. Midwest Generation, like all power plants, monitors the opacity of its stack gases. This is a way of seeing how clean the gas stream is. When opacity spikes, that does not necessarily relate to a �burst of soot.� It can also relate to temperature changes, monitor fluctuations or plain old dirty lenses on the monitor.
6. Hawthorne says that the air in Chicagoland was �so bad� on Aug. 1 that Chicagoland exceeded limits for both smog and soot. Technically true, but there are a number of spin problems here
a). As noted earlier, limits have grown more stringent, while the air has gotten cleaner.
b.) Midwest Generation�s emissions do not, as we have seen, significantly contribute to local levels of ground level ozone (or �smog�). The biggest contributors to ground level ozone in the Chicago area are power plants located in states to the west of us and the trucks and automobiles on our streets. Midwest Gen has almost no effect on local levels of ozone.
c.) When Hawthorne refers to soot, he is presumably referring to PM-2.5, or �fine particulate.� A little perspective is needed here.
Initially, back in the 70s, the EPA regulated total particulate. Industry, including power plants, dutifully installed controls and quickly met those limits. Our air got a lot cleaner.
Once those standards were met, EPA published PM-10 standards. PM-10 is particulate matter less than 10 microns in diameter. (The average human hair is about 70 microns wide.) Again, we met those standards, with only a few, isolated, exceptions.
Now EPA is busy publishing standards to regulate particulate that is 2.5 microns in diameter or less. This is extremely tiny stuff. It�s so small that it�s not (for the most part) created directly. Certain chemicals combine in the atmosphere to make PM 2.5.
Since the air quality violation that Hawthorne cited occurred on August 1 and given the only recorded particulate violations on that date involved PM 2.5, one can only assume that he was talking about PM 2.5 when he talked about �soot.�
The spin violation here is that no contemplated control upgrade by Midwest Generation will result in a significant reduction of PM 2.5 concentrations in the Chicagoland area. Chicago has exceeded, and will continue to exceed, this new limit for a long time. The reasons have little to do with Midwest Generation.
7. Hawthorne says that the Bush administration has tried to rewrite the law to make it easier for utilities to upgrade their plants. Such a statement could have (and probably was) been written by the most extremist of environmental groups.
Hawthorne is talking about attempts to reform the New Source Review process. New Source Review is horrendously complicated. It is frequently cited as a prime example of the law of unintended consequences. Rather than go through New Source Review, many plant operators will keep aging, less environmentally efficient process limping along.
Attempts to streamline New Source Review were begun under the Clinton administration, a fact that Hawthorne ignores. The idea was not to make the process less stringent, but to eliminate the confusing, bureaucratic maze that the characterize the rule and the volume of guidance documents associated with it. New Source Review Reform did not become a "problem" until the Bush administration inherited the streamlining process that was begun under the Clinton administration.
Moreover, more stringent rules often trump New Source Review. Sulfur dioxide emissions in Illinois have declined from over a millions tons per year in 2000 to less than 500,000 tons per year last year. This is a result of strict application of the Acid Rain rule, which controls sulfur dioxide emissions on a nationwide basis. New Source Review did not come into play in any significant way.
The fact that Hawthorne parrots the positions of the most extreme environmental groups in this case, and with virtually every case, is further proof that any story published under his by-line is not to be trusted.
