Environmental Policy Question
Background:
In the U.S., pollutants are regulated differently depending
on the medium (air pollution or water pollution) and on the particular type of
chemical substance. Air pollution regulation is primarily determined by
the Clean Air Act (CAA), originally passed in 1971, and most recently amended
in 1990. The CAA designates some pollutants as “criteria pollutants”,
with one process for setting regulations. One of the criteria pollutants
is sulfur dioxide (SO2), which is regulated through a tradable
permit system since the 1990 CAAA. Other pollutants are labeled
“hazardous air pollutants” (HAPs), which have a different, more stringent
regulatory process.
Mercury is a toxic substance, with serious health impacts at
high enough doses, and is currently listed as a HAP. In order to reduce
the costs of regulation, the Bush administration has proposed recategorizing
mercury from a HAP to a criteria pollutant, and then using a market-based
approach for mercury emissions just as for sulfur.
This shift in approach to regulating mercury is extremely
controversial, both within the scientific community and among stakeholders in
the public debate. The controversy includes uncertainty in the pathways
from emissions to health impacts, and the appropriateness of using a
market-based approach for a toxic substance.
Your Client:
Your group is a policy task force within the EPA’s Office of
Air and Radiation. You have been asked by administrator Michael Leavitt
to prepare an analysis of the tradeoffs in shifting the category of mercury as
pollutant, and between regulatory approaches.
The Question:
How should EPA regulate mercury emissions from coal-fired
power plants, and if so, how should this regulation be designed and how large a
reduction should be mandated?
Additional information to get
started: