Wednesday, October 17, 2007

Politics of air pollution control, Massachusetts

Environment Massachusetts, part of the Massachusetts Public Interest Research Group, organized a Clean Air coalition in 1997 to reduce emissions from what it called the "filthy five" -- large electricity generation plants in the state. Participants in western Massachusetts soon discovered that MassPIRG had omitted the Mount Tom coal-fired plant run by Holyoke Water Power, perhaps because the U.S. Environmental Protection Agency's 1996 State/Plant Index Page left the name of the facility blank. The "filthy five" became six during a multi-year campaign.

Taking advantage of fractured state politics -- Republican governors since 1991, with Democrats occupying over three-fourths of the legislature, the entire Congressional delegation and a great majority of other offices -- the coalition brought pressure on then-acting Gov. Cellucci. Cellucci ordered a review of power-plant emission standards. A Cellucci administration statement in June, 1998, estimated that by 2003 actions already underway would reduce nitrogen oxide emissions to 29 percent of 1990 levels and said that new actions could cut 7 more percentage points and could reduce mercury emissions by half. The statement made no estimates for reducing sulfur dioxide, known to be more difficult.

In April, 2001, during the administration of Republican acting Gov. Swift, the state Department of Environmental Protection issued new regulations, setting performance limits that applied to the six major power-plants, at 1.5 lb/MWh for nitrogen oxides and 3.0 lb/MWh for sulfur dioxide. Future action was promised on limits for mercury, particulates and carbon dioxide. The Clean Air coalition asked for stricter standards on nitrogen oxides and sulfur dioxide but did not organize vigorously around a specific proposal. After the April, 2001, regulations it dropped those issues and spent most of its subsequent efforts on carbon dioxide limits.

By 1997 Massachusetts already enjoyed lower power-plant emissions than most of the United States. Fuel shifts from coal to oil and natural gas had eliminated about 60 percent of the nitrogen and sulfur oxide emissions of a decade before. However, no significant improvement had occurred in generators that remained coal-fired. The new Massachusetts regulations would require operators of those units to implement controls. New operating permits for the six major plants were issued in 2002.

The six major plants took different approaches. The Mystic plant in Everett, oldest and largest in the state, had opened as a coal-fired plant in 1943, later converting to oil. It was renovated with natural gas, combined cycle generators. One remaining conventional unit in the plant is fired by oil or natural gas but used only during peak demands, since it has lower efficiency. Once a very dirty plant, Mystic now has the state's highest fuel efficiency and best emission performance. The Canal plant in Sandwich, currently all oil-fired, continues to operate much as before, with some added controls to reduce nitrogen oxides.

The four other plants remain mainly coal-fired, with two of them using partly oil to reduce their emissions. The Somerset plant, which has been using partly oil, is installing coal gasification, expected to provide high efficiency and low emissions of nitrogen and sulfur oxides while burning all coal. The Brayton Point plant, also in Somerset and second largest in the state, is installing enough emission controls to meet its requirements but no more. Only part of its equipment is being upgraded. The Salem plant has been in and out of bankruptcy but is now being outfitted to meet requirements, running partly on oil. The Mount Tom plant in Holyoke is making minor changes, using lower-sulfur coal and purchasing emission allocations to meet requirements.

Final permit requirements for nitrogen oxides and sulfur dioxide begin in October, 2008, and it will take two to three years after that before data become available for operations and emissions. However, one can estimate 2009 emissions and examine data for 2004 which have recently been released. They can be compared to performance of new coal-fired plants, which has evolved under the Best Available Control Technologies standard specified by the federal Clean Air Act of 1990. A 2007 draft permit from Arkansas [1] for a new 616 MW coal-fired plant proposed in Hempstead County provides a current, practical example of emissions under the BACT standard.

Annual emissions and electricity generation for the 1999-2001 period and for 2004 are from records of the U.S. Environmental Protection Agency [2]. Estimates for 2009 and for plants of the Hempstead County design are based on generation levels of the six Massachusetts power-plants in 2004, using for 2009 the maximum Massachusetts emission permit levels. Actual emissions for 2009 might be lower because of technologies at the Mystic, Canal and Somerset plants, but since other plants are able to purchase sulfur dioxide allowances from them instead of making reductions, permit levels probably provide realistic estimates.

Basing its approach on its knowledge from the late 1990s, Massachusetts demanded and already has partly achieved emission reductions for six major power-plants. By October, 2008, nitrogen oxide emissions are estimated to be reduced 39 percent and sulfur dioxide emissions are estimated to be reduced 66 percent below the 1999-2001 levels, just before new regulations. However, if Massachusetts standards matched those of the recent Hempstead County permit in Arkansas, both types of emissions in October, 2008, would be about one-fourth as much as the emissions now estimated. Massachusetts is making significant progress, but the state falls well short of Best Available Control Technology for new coal-fired power-plants.

Should Massachusetts have waited before acting? Clean Air coalition participants would likely say no. Political activists engage in causes when they think they can win, not when other conditions are optimum. Massachusetts might still have set more stringent standards. In 1999 the Clinton administration began to file lawsuits against power-plant operators who were skirting New Source Review under the Clean Air Act amendments of 1977 by making incremental improvements to existing plants. See "Legal victories for cleaner power," October 9, 2007.

The first settlements were announced in 2000 with Tampa Electric and Cinergy, but information made available that year [3] did not provide enough detail to guide regulations. The next Clean Air Act settlement [4], announced in January, 2001, showed it was practical for a utility to reduce nitrogen oxide emissions from coal-fired plants by 80 percent and sulfur dioxide emissions by 90 percent. The Massachusetts explanations for new regulations [5] fail to mention any of these events. That may not be surprising. Federal Clean Air Act settlements were late products of a Democratic administration. Massachusetts regulations were products of Republican administrations reacting to political pressure. Since the Clean Air Act of 1970, air pollution control has been influenced at least as much by politics as by technology.

[1] Arkansas Department of Environmental Quality, July, 2007, Draft Operating Air Permit 2123-AOP-R0, See p. 29.

[2] U.S. Environmental Protection Agency, Emissions and Generation Resource Integrated Database, 2007,

[3] U.S. Energy Information Administration, December, 2000, Analysis of Strategies for Reducing Multiple Emissions from Power Plants: Sulfur Dioxide, Nitrogen Oxides, and Carbon Dioxide, Report SR/OIAF/2000-05,

[4] U.S. Environmental Protection Agency, January 24, 2001, United States and New Jersey Announce Clean Air Act Coal-Fired Power Plant Settlement with PSEG Fossil,!OpenDocument.

[5] Massachusetts Department of Environmental Protection, April, 2001, Statement of Reasons and Response to Comments for 310 CMR 7.29, Emission Standards for Power Plants,

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