Jan Jarrett, vice president, before the House Environmental Resources and Energy Committee Informational Meeting on Mercury Emissions

Good Morning Chairman Adolph, Chairman George and members of the committee. Citizens for Pennsylvania 's Future, commonly known as PennFuture, appreciates the opportunity to testify before you regarding this important topic.

 

 

PennFuture is a statewide public interest membership organization that advances policies to protect and improve the state's environment and economy. With offices in Harrisburg , Philadelphia , Pittsburgh and West Chester , PennFuture's activities include litigating cases before regulatory bodies and in local, state and federal courts, advocating and advancing legislative action on a state and federal level, public education and assisting citizens in public advocacy.

 

The Department of Environmental Protection (DEP) decided to develop a state-specific mercury rule in response to a petition to the Environmental Quality Board (EQB) that PennFuture filed in August 2004. PennFuture filed the petition on behalf of a broad coalition of healthcare professionals, environmental organizations, children's advocates, and faith-based, sporting and women's rights groups. They include the Pennsylvania Federation of Sportsmen's Clubs, the Pennsylvania State Nurses Association, the Pennsylvania PTA, the Maternity Care Coalition, and the Pennsylvania Council of Churches - the list now totals more than 60 groups.

 

We took this action because the mercury rules proposed by the United States Environmental Protection Agency (EPA) do not sufficiently protect human health, wildlife, the environment and Pennsylvania 's economy. We believe that EPA's Clean Air Mercury Rule (CAMR) is illegal because the Clean Air Act requires mercury to be regulated like the toxic that it is. CAMR would allow power plants to emit mercury pollution at high levels for more than a decade. It would also set up a trading system for mercury that would allow a power plant to buy credits rather than cut its emissions, a system that works well for sulfur dioxide, but is inappropriate for a toxic like mercury.

 

Pennsylvania has a pervasive mercury contamination problem. The Fish and Boat Commission and DEP have issued advisories cautioning people to limit eating fish caught in any of the Commonwealth's lakes, rivers or streams because of mercury contamination. Pennsylvania power plants are the largest source of mercury pollution in the state and they are the second highest mercury emitters in the nation.

 

Mercury is a powerful neurotoxin that poses a special threat to the proper development of babies' brains. Mercury easily crosses the placenta and once in the womb, mercury concentrations in fetal blood rise by 30 percent over the concentrations in the mother's blood. Mercury is concentrated in the brain of the developing fetus because the metal is absorbed quickly and is not excreted efficiently. Between 300,000 and 600,000 babies are born each year with blood levels of mercury high enough to affect development. Nursing infants can also be exposed through mother's milk. Exposure to mercury can lead to children born with learning disabilities and attention deficit disorders, problems with coordination, lower IQ and even mental retardation.

 

90 Percent Reductions in Mercury Emissions Can Be Achieved at Minimal Cost
Commercially viable technology is readily available to reduce mercury emissions by 90 percent. This is documented in the November 2004 NESCAUM study by the air quality management agencies in seven Northeastern states; a comprehensive 2004 report by the National Wildlife Federation based on the latest science and test results from power plants across the country; and even the EPA in 2001 before the agency dramatically and illegally reversed course on mercury emissions.

 

The proposed 90 percent reductions in mercury emissions can be achieved at minimal cost. The National Wildlife Federation report concluded that a 90 percent reduction in mercury emissions at Pennsylvania power plants is achievable and affordable today. This report utilized current EPA cost estimates for mercury control on power plants with different sizes, configurations and coal types. Every boiler at the state's 36 power plants could be retrofitted to achieve 90 percent control, while costing Pennsylvania consumers only $1.08 more on their monthly electric bills, if every penny was recovered from customers. Pennsylvania businesses would pay approximately $6.42 extra per month on their bills according to the study, and industrial customers would pay approximately $107 extra per month. Both estimates again assume that every penny would be passed through to consumers and that assumption is almost certainly wrong. The overall cost of compliance for Pennsylvania utilities was calculated to be approximately two percent of annual revenues.

 

In fact, Pennsylvania consumers will probably never see even these small increases in costs. In Pennsylvania and other states in the PJM interconnection pool, costs to reduce mercury cannot automatically be passed on to electric customers since electric prices are set in a competitive wholesale electricity market. The costs of reducing mercury at power plants will either increase prices very minimally or reduce power plant profits. Ultimately, the small costs to clean up mercury may mean no more than a small decrease in the large profits of coal plants that today are making substantial profits.

 

Most coal plants in Pennsylvania today are baseload plants that run during all hours. These plants have paid off their original capital costs and are like a house where the mortgage has been fully paid.

 

Even more importantly, most of these coal plants are highly profitable because of high wholesale market prices for electricity. Increasingly, the wholesale market price for electricity is being determined by the market bids of natural gas-fired plants that are on the margin and so set the price at high levels for all plants in the market. Put simply, coal plants produce electricity at costs that are lower than the price owners of coal plants can sell electricity for.

 

While coal plant owners may see a decrease in their high profits, reducing mercury emissions will result in numerous savings and benefits in other areas. Investments in state of the art mercury control technologies are also proven to reduce other types of emissions such as sulfur dioxide, nitrogen oxide and particulates. Pennsylvania utilities will be required to reduce these emissions in the future, thus making overall emissions reductions more cost-effective if mercury is included.

 

Economic Benefits I: Reducing Healthcare Costs and Productivity Losses
 Pennsylvania 's citizens, environment and economy will receive great benefits from a strong mercury rule. One will be the reduction of the social and economic (and moral) costs of learning disabilities and loss of intelligence, special education, healthcare costs, the loss of income and taxation, and squandered human capital and creative potential. Several recent studies have attempted to calculate the impact of mercury pollution that causes brain damage and impaired neurological development in children. A study by the Mount Sinai School of Medicine's Center for Children's Health and the Environment calculated that the loses $2 billion annually due to the impact of mercury on children's brain development. One estimate of the special education costs for damage caused by methyl mercury exposure is $4.6 billion per year based on data complied by the National Research Council.

 

Economic Benefits II: Jobs
Installing mercury controls will create of hundreds of good-paying, often union jobs for boilermakers, carpenters, sheet metal workers, electricians and others in the building trades. This is based on extrapolating from the results of a study done by the Clean Air Companies, which found that about 4,000 direct and indirect jobs would be created nationally by strict mercury controls.

 

A recent press release from PPL regarding the installation of scrubbers at two generating units of the Brunner Island coal-fired plant drives this point home. It says that the "scrubber projects at Brunner Island will create jobshundreds of temporary construction jobs while they are being built, and a number of permanent PPL jobs because additional employees are required to operate the equipment."

 

Fishing in Pennsylvania is an $800 million dollar industry, including licenses, bait and tackle, boats, food and lodging. It is threatened by the fact that every body of water in Pennsylvania is under a fish consumption advisory of one serving per week due to mercury. Many anglers want to eat what they catch, and will seek out alternative destinations where they can do so.

 

Economic Benefits III: Creating a Climate where Health is Paramount
Finally, we ask that you consider the small costs of dramatically reducing mercury emissions from power plants in the larger picture of improving Pennsylvania as a worthwhile place to live, work, raise a family, invest in a business, and recreate. It is an opportunity for the Commonwealth to create a climate where public health is paramount. Reducing mercury will send a strong and unmistakable signal to those who would stay, move to, or invest in our state that Pennsylvania is serious about creating a future where a clean environment, healthy communities and a high quality of life are inseparable assets.