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The NESCAUM report attempted to quantify the marine exposure pathway but used assumptions that are not supported by the literature on marine fate and transport of Hg, likely resulting in an overestimate by an unknown amount. Chicago Tribune: Illinois and 14 other states are challenging the Bush administration's proposal for regulating mercury emissions from power plants, arguing the rule fails to adequately protect Americans from exposure to the toxic metal. Citing a recent Tribune series on mercury in fish, the states filed comments Monday taking issue with the U.S. Environmental Protection Agency's conclusion that pollution from coal-fired power plants has little effect on seafood. The states also pointed to a Harvard University study commissioned by the EPA that found the health benefits from reducing mercury emissions would be 100 times greater than the agency projected when it issued the rule earlier this year. By underestimating the benefits of reduced mercury pollution, the states said, the EPA gave utilities a break. If the rule takes effect, many power plant owners likely won't need to install new equipment to curb mercury emissions. ... They also cited a study by the Harvard Center for Risk Analysis, paid for by the EPA and co-written by an agency scientist, that concluded the health benefits from reducing mercury emissions would be far greater than the agency's estimates--$5 billion a year rather than $50 million. Consumer advocates and environmental groups have criticized the Harvard center as being "pro-industry," and the Bush administration has frequently cited its work on other regulatory matters. But the EPA said the mercury study was submitted too late to be considered in drafting the power plant rule. (December 20, 2005) Response: CT here implies that (1) the report produced by the Harvard Center for Risk Analysis (which was submitted to EPA by NESCAUM) was submitted too late to be considered in drafting the power plant rule and (2) EPA downplayed the benefits of reduced mercury emissions. First, the so-identified study is actually a non-peer-reviewed , yet-unpublished report signed by Glenn Rice, an EPA employee. Rice performed the analysis as part of his doctoral thesis, along with Dr. James Hammitt, Director of the Harvard Center for Risk Analysis. The report, Economic Valuation of Human Health Benefits of Controlling Mercury Emissions from U.S. Coal-Fired Power Plants" is dated February 2005, and was submitted to EPA's rulemaking docket (as item OAR-2002-0056-5749) by the Northeast States for Coordinated Air Use Management (NESCAUM) by February 22, 2005. Second, it is true that this study was funded by EPA through contract to NESCAUM. Third, it is an unsubstantiated view that EPA had not considered the study or been thoroughly informed about the NESCAUM report in time for its rule making decision published March 29, 2005: • Rice and Hammitt, presented to EPA officials a 41-pp. power point presentation entitled "Assessing Power Plant Mercury Control Issues" on August 19, 2004. Finally, section 9 entitled "Evaluation of NESCAUM Report" of EPA's Technical Support Document Revision of December 2000 Regulatory Finding on the Emissions of Hazardous Air Pollutants From Electric Utility Steam Generating Units; Standards of Performance; Proposed Rules dated October 21, 2005 clearly shows that EPA had considered and evaluated NESCAUM's health benefit analysis. Some of EPA's key criticisms of the NESCAUM report included: For example, the NESCAUM report attempted to quantify the marine exposure pathway but used assumptions that are not supported by the literature on marine fate and transport of Hg, likely resulting in an overestimate by an unknown amount. |
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