Environment Canada urges faster action by EPA on mercury from coal-fired plantsThe U.S. government should move faster to reduce mercury emissions from coal-fired power plants, says a submission from Environment Canada (EC) to the U.S. Environmental Protection Agency (EPA). This, says EC, would better protect the health and environment of Canadians, and would make the U.S. standard comparable to the Canada-Wide Standard (CWS) for mercury emissions from coal-fired power plants being developed by the Canadian Council of Ministers of Environment (CCME).
EC presented its comments March 30 in response to the EPA's proposed rule titled "National Emission Standards for Hazardous Air Pollutants; and, in the Alternative, Proposed Standards of Performance for New and Existing Stationary Sources: Electric Utility Steam Generating Units." The EPA proposes two options for reducing mercury emissions from U.S. power plants: a standard which would cut emissions by 30% by 2007; or a two-stage approach with targets of 30% by 2010 and 70% by 2018.
EC's submission reinforces its support for the efforts being made by the EPA to limit emissions of mercury. At the same time, notes EC, the department's modelling indicates that approximately 10% of the mercury deposited in Canada each year comes from U.S. sources. Within the Great Lakes region, home to more than nine million Canadians, the percentage rises to 38%.
Mercury also has a serious and disproportionate impact on Canada's northern and Arctic communities. As a result, the submission argues that mercury reductions in the United States are needed to help protect human health and the environment in Canada.
The department expresses concern that both the Maximum Achievable Control Technology (MACT) proposal and Phase I of the cap-and-trade proposal fall short of the emissions reductions that are achievable with current and emerging control technologies.
The Canadian view is based on:
* a review of current literature which suggests that it is possible to achieve a 60-90% capture rate for mercury from bituminous and sub-bituminous coal-fired power plants, and possibly lignite-fired plants;
* consensus agreement among the federal, provincial and territorial governments to set, by 2005, a Canada-Wide Standard for mercury emissions from coal-fired power plants whose target will be "the national capture of mercury from coal burned in the range of 60-90%," by 2010; and
* a recommended mercury standard for Alberta power plants based on activated carbon injection and fabric filters, by 2009.
Specifically, Environment Canada recommends and urges the U.S. EPA to:
* consider a more stringent MACT standard for mercury which would bring the national capture rate for mercury from coal burned to the 60-90% range, or
* set a lower Phase I cap (for 2010) in the cap-and-trade option which would bring the national capture rate for mercury from coal burned to the 60-90% range.
Environment Canada also notes that its efforts to promote the reduction of mercury emissions from coal-fired power plants are not confined to North America but also includes working with other countries, such as China, to encourage them to take action to cut mercury emissions. More than 20% of the airborne mercury that falls on Canada annually comes from Asia.
At the same time, Environment Canada also submitted its opinion to the EPA on its "Proposed Rule to Reduce Interstate Transport of Fine Particulate Matter and Ozone (Interstate Air Quality Rule, IAQR)." The proposed IAQR is intended to reduce long-range and interstate transport of fine particulate matter (PM2.5) and ozone. It would also further reduce emissions of SO2 and NOx from electric generating units in the 29 eastern and midwestern States and the District of Columbia by about 65% by 2015.
EC's submission commends U.S. efforts to update its rules and views the IAQR as a positive step toward further reducing acid deposition; it will also be helpful in improving air quality in some regions of Canada.
At the same time, Environment Canada encourages the EPA to finalize the caps with targets and timetables that are as aggressive as possible, and are implemented as early as possible. In 2000, notes the submission, Canada put in place CWS for PM2.5 and ozone, setting out ambient levels for these pollutants to be achieved by 2010.
While the department recognizes the benefits of the proposed U.S. reductions of 65% from Title IV allocations, it notes that ultimately, further reductions will be required to reduce the impact of acid deposition, with a goal of achieving a 75% reduction in SO2 emissions from Title IV levels. The department adds that advancing the timing of the second stage reductions from 2015 would provide additional benefits to both countries.
The Canadian view is based on an acid rain research and monitoring program in Canada, which indicates that about 70% of the sulfate and nitrate deposition in Canada each year comes from U.S. sources. Even with full implementation of the proposed IAQR, watersheds and forests in eastern Canada will continue to be damaged by acid rain. Reducing emissions further and at a faster rate will slow the acidification of Canadian soils and prevent the continued acidification of Canadian watersheds, says the submission.
EC recognizes that, when fully implemented, the proposed IAQR would yield cumulative reductions of up to 34 million tons of NOx and SO2 between now and 2015 (based on EPA projections from early this year). Those emissions reductions will result in significant health and environmental benefits for Canadians and Americans. Further, Environment Canada estimates that, if the U.S. were to advance the caps such that both Phase I and Phase II were fully implemented by 2010, the environment would be spared more than two million additional tons of SO2 and almost one million additional tons of NOx for the five-year period.
Copies of the two submissions, "Proposed National Emission Standards for Hazardous Air Pollutants; and, in the alternative, proposed standards of performance for new and existing stationary sources: Electric Utility Steam Generating Units" and "Proposed rule to reduce interstate transport of fine particulate matter and ozone (Interstate Air Quality rule)" may be viewed on Environment Canada's Web site, www.ec.gc.ca/pdb/can_us/canus_trans_e.cfm.