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EPA Proposes Rule Change That Would Let Power Plants Release More Toxic Pollution (npr.org)
The Trump administration announced on Friday a plan designed to make it easier for coal-fired power plants, after nearly a decade of restrictions, to release into the atmosphere more mercury and other pollutants linked to developmental disorders and respiratory illnesses [Editor's note: the link may be paywalled; alternative source].
From a report: The limits on mercury, set in 2011, were the first federal standards to restrict some of the most hazardous pollutants emitted by coal plants and were considered one of former President Barack Obama's signature environmental achievements. Since then, scientists have said, mercury pollution from power plants has declined more than 80 percent nationwide. President Trump's new proposal does not repeal the regulation, known as the Mercury and Air Toxics Standards, but it would lay the groundwork for doing so by weakening a key legal justification for the measure. The long-term impact would be significant: It would weaken the ability of the E.P.A. to impose new regulations in the future by adjusting the way the agency measures the benefits of curbing pollutants, giving less weight to the potential health gains.
In announcing the proposed rule, the Environmental Protection Agency said in a statement that the cost of cutting mercury from power plants "dwarfs" the monetary benefits. The proposal, which the acting E.P.A. administrator, Andrew Wheeler, signed on Thursday, is expected to appear in the federal register in the coming weeks. The public will have 60 days to comment on it before a final rule is issued. [...] Reworking the mercury rule, which the E.P.A. considers the priciest clean air regulation ever put forth in terms of annual cost to industry, would represent a victory for the coal industry, and in particular for Robert E. Murray, an important former client of Mr. Wheeler's from his days as a lobbyist.
In announcing the proposed rule, the Environmental Protection Agency said in a statement that the cost of cutting mercury from power plants "dwarfs" the monetary benefits. The proposal, which the acting E.P.A. administrator, Andrew Wheeler, signed on Thursday, is expected to appear in the federal register in the coming weeks. The public will have 60 days to comment on it before a final rule is issued. [...] Reworking the mercury rule, which the E.P.A. considers the priciest clean air regulation ever put forth in terms of annual cost to industry, would represent a victory for the coal industry, and in particular for Robert E. Murray, an important former client of Mr. Wheeler's from his days as a lobbyist.
is mentally ill.
Remember, the problem is always the ORANGE, never the GREEN.
Also, my DAMN balls, for u to suck
...if it is impossible to scientifically create 'clean coal', then king trump will simply declare coal to be clean
easy... peasy...
Will the regent simply declare away the $80 billion in annual health costs due to burning coal for energy?
...for a group (Republicans) who only care about life when it's yet to be born. After that, if you're not a member of the lucky sperm club, they could really give a bubbly fart about your life.
... it's a Trump'ish way of helping "big industry", "big coal", "big oil", etc.
I'm sure that Donnie Dipshit thinks that pollution is some kind of "Democrat conspiracy" designed to hurt those wonderful coal miners who cheer him at his rallies.
I don't respond to AC's.
Environmental Destruction Agency. Pollution is our solution!
Thank you social big boss
President Trump's new proposal does not repeal the regulation, known as the Mercury and Air Toxics Standards, but it would lay the groundwork for doing so by weakening a key legal justification for the measure. The long-term impact would be significant: It would weaken the ability of the E.P.A. to impose new regulations in the future by adjusting the way the agency measures the benefits of curbing pollutants, giving less weight to the potential health gains.
Either the headline is incorrect or the summary is wrong. Either way, once again I'll simply suggest that this is a good reason why bureaucracy shouldn't govern and that Congress should ultimately put forth all laws. Anything less is ultimately too susceptible to change and puts far too much power into the hands of the administration. We did away with kings for a reason.
Making the US a poisonous shithole would be a better anti-immigrant measure than a wall.
Why is an agency whose very name explicitly suggests its entire reason for existence is to *protect* the environment be making a rule that allows people to pollute *more* than they do right now?
If they are no longer doing that, then the agency should be discontinued.
File under 'M' for 'Manic ranting'
The EPA should be renamed because the whole premise of the agency was to protect our environment. As of late they're doing more to destroy the environment than protect it. EDA=Environment Destruction Agency.
The toxics could kill you!
Topic: Rule change that would let power plants release more toxic pollution.
Content: Rule change that doesn't let power plants release any more toxic pollution.
Comments: Trump is letting plants release more toxic pollution.
TDS in action.
For someone who has continually railed against the adverse health effects of Mercury poisoning and the illuminati scum turning our kids into sleeping zombies.... It will be interesting to hear what masturbation of reality AJ and friends invoke to applaud Trump for rolling back Mercury standards which disproportionately negatively affects Texans.
Yea more likely not even right wing crack whores will be touching this.
This is like shitting in your bed and being proud of it. Just like the morons that "roll coal" with their stupid trucks.
like EPA standards do you really want Congress to try and micromanage every little detail? Or would you rather have scientists doing that work. You know what they call a scientist who works for the government? A bureaucrat.
Also, you should start to question why you're so deeply opposed to bureaucracy. Why the word has such a negative connotation. Specifically, what has a bureaucrat done to you? The cop who gave you that ticket is not a bureaucrat. The clerk who made you wait at the DMV isn't the one who decided how many clerks they'd be. That's your state legislature.
What I'm getting at is that somebody, somewhere, has invested a lot of time and effort into eliciting a certain response to the words bureaucrat and bureaucracy from you.
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If you read the article, you'll see that slashdot's and the NYT's headline is false and misleading. The proposed change does not allow the release of more mercury or repeal existing regulations. It makes it harder for the EPA to implement more regulations beyond what already exists:
"It would weaken the ability of the E.P.A. to impose new regulations in the future by adjusting the way the agency measures the benefits of curbing pollutants, giving less weight to the potential health gains."
I'm sure the NYT knows this and is purposely being misleading or maybe they are brain dead enough to not understand what they are printing. Regardless this is exactly the kind of crap that makes people distrust the media. An argument on whether it's worth the economic costs to further reduce mercury emissions beyond the 80% reduction that has already occurred by wiping out the remaining coal plants is worth having, but it isn't possible to do that when the media is falsely reporting stuff like this and people don't take the time to carefully read and understand what is being said.
Also:
If this proposal is adopted the very next step is to allow more mercury in the air. So yeah, the proposal would let power plants release more toxic pollution. That's because the original executive order relies on indirect economic befits to exist and without considering those benefits can and will be struck down.
Just because it's a->b->c to to get to c (more toxins) doesn't mean b isn't important. Especially when c doesn't happen without b.
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I notice we're all quibbling on the headline instead of discussion the fact that this administration would like very much to increase the amount of mercury in the air.
Article says it's down 80% since the rule went into place, and I'll remind you that there is no safe level of mercury exposure. It builds up over time. Buddy of mine found that out the hard way getting mercury poisoning from tuna...
Once again, we've got our priorities ass backwards.
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The Trump administration weakened the CFPB to the point where it does nothing now - but they didn't eliminate it!
And you know that. And CONGREE created the EPA which is well in their power granted by the constitution and it is what they are supposed to do.
Do you really think you're fooling anyone with that post? Ah, mod'ed up to 5 - I guess you are.
Years ago when I worked those types of jobs they would shut them off at night especially if it was raining. You could always tell when a precipitator went offline. Its not just power plants that do this. Paper mills will also power off their pollution control devices. Even if they are more passive systems like a baghouse.
but the point is that the justification for the current rule is large scale savings due to better health outcomes due to lower exposure to mercury.
This rule change says that only direct savings can be considered, which throws out $80 billion in savings from better health.
The next step will be to declare that the cost of the program relative to it's benefit is too high and eliminate it, which in turn will allow the EPA to overturn the Obama era ruling.
The reason for doing this is so when they're inevitably sued by environmental watchdogs they can win in court.
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this is ground work to defend against a lawsuit. As I pointed out the original justification, as per TFA, was cost savings due to improved health outcomes. This ruling says that those cost savings cannot be taken into account, which in turn means the original rule can and should be over turned. When it's challenged in court if the first ruling about cost savings (the one their doing now) is upheld then the second ruling goes down.
The reason Trump hasn't done more damage is folks have been fighting against him. He tried to end Obamacare and with it pre-existing condition protection. He was stopped only because of a massive backlash. He's tried to spend $30 billion of my tax dollars (and yours if you're American) and a wall/fence that not one expert agrees would make the slightest difference in protecting our boarders. Again, folks fought against that.
And Musk doens't have anything to do with it. That's a red herring.
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Also, you should start to question why you're so deeply opposed to bureaucracy. Why the word has such a negative connotation.
Start to question? This is from years of learned experience pal.
Specifically, what has a bureaucrat done to you? The cop who gave you that ticket is not a bureaucrat.
Here I'll help you understand: The cop was not a bureaucrat. But the people who set the speed limit deliberately much lower than traffic was. The people who mandated the cops had to get a certain number of tickets at the end of the month were.
The clerk who made you wait at the DMV isn't the one who decided how many clerks they'd be. That's your state legislature.
Wrong. They merely set budget - it's again bureaucrats who decide they are better off getting a nice large paycheck rather than adding more front line DMV personnel...
Unseen: The countless ways bureaucrats have hurt you very much indeed by preventing things that might have been.
"There is more worth loving than we have strength to love." - Brian Jay Stanley
A theoretical wall could cost $30 billion, and last for a 100 years. Ramping up ICE and border patrol would be more effective, and expensive. 200,000 ICE agents could cost $40 billion per year, and be more effective at deporting that ~10+ million illegal aliens.
YouRepublicans have shown they don't need to take the political hits with repealing laws. They can just ignore enforcing the parts of the law that makes them legally justifiable. This allows the laws to be removed by the courts and they can then use the court rulings to claim laws are unconstitutional.
It's clever because it works for current laws and sets future precedent. Most voters are too moronic to understand this or are already so deep into the cult they will ignore these moves that truly mock our constitution.
Americans want to poison themselves.
When it is literally true that they are gravely mentally ill, in more than one way.
Yes, both "parties". All managers and lobbyists... err, I mean "politicians".
And most of the citizens too, I unfortunately have to tell you. No offense(TM).
Coal plants will be extinct soon anyway. Remember: Nuclear fusion is "only 20-30 years away". Soon we'll be buying fusion generators from China as fast as they can buy our treasury bonds so we can "pay" for them.
I'm not sure if you read the summary vs just the clickbait headline, but this makes no changes to mercury emissions. What has changed is that in the future, the EPA will comply with the law, as ordered by court order from 2015 regarding how they document the reasons for their decisions.
The proposed change is that in the future the EPA will publish certain data (as already required by law), rather than obscuring the data by lumping unrelated things together.
The summary hints at what's actually going on when the summary says:
-- ...
President Trump's new proposal does not repeal the regulation, known as the Mercury and Air Toxics Standards.
a key legal justification for the measure. The long-term impact would be significant: It would weaken the ability of the E.P.A. to impose new regulations in the future [without publishing their data regarding the new regulation they made up]
---
Here's what happened. Under the Obama administration, certain people in the White House asked the EPA to put new regulations on coal. By law, when making new regulations, the EPA has to publish an analysis of the week benefits and costs. Their analysis concluded that further reducing mercury emissions would cost $9.6 billion and the benefits would be - minimal. Oops, that's a problem. It would be much more effective to spend $9.6 billion on nutritional education, anti-smoking, or any of many other choices, if you wanted to improve public health. Instead of having the coal plants pay $10 billion for mercury filters, it would have worked a heck a lot better to make them pay $10 billion for other, more effective, health related programs, Obama's EPA found.
But the White House wanted regulations on coal, not breastfeeding related programs or anything else that would have been more effective, get more bang for the buck. So what's the EPA to do? Issue the regulation while attaching their studies showing that their regulation was stupid?
The way the EPA dealt with this problem is they guessed that if they required more mercury reduction, coal plants *might* ALSO make drastic reductions to other emissions, including particulates and many others. The EPA study said that if the plants greatly reduced all of these other things, that would be good for public health. These other possible benefits that have nothing whatsoever to do with mercury would be significant, far greater than the minimal benefit related to mercury. So the EPA published numbers showing a) the cost of mercury reduction and b) the total benefits of greatly reducing particulates, nitrogen oxides, sulfur dioxide, etc. They didn't publish their numbers for mercury because they were embarrassingly low.
In 2015 the court ruled that the EPA hadn't followed the law. If they are going to make a regulation on mercury emissions, they have to publish their estimates of the cost and benefits of mercury emissions reduction. They can't hide it by adding in a bunch of unrelated stuff and lumping it all together, the court ruled.
The EPA now proposes to follow the law, as they have been to ordered by the court, and publish their estimates for the costs and benefits of any new regulations - and only for the regulation, not a lump sum assuming a bunch of other new regulations.
Just curious, how is having the EPA publish their scientific data, as already required by law, anti-intellectual?
The court ruled when the Obama EPA lumped totally unrelated things together in a deliberate effort to obscure the results their study, that was hiding the scientific facts. To me, that's what seems anti-intellectual.
Unless you mean anti pseudo-intellectual?
he just says whatever gets him votes. He's not immoral, he's amoral.
That said, the folks around him (especially Pence, who's a Christian Dominionist) absolutely want that, and it's scary as hell to me at least. During the campaign Trump asked "What do you got to lose" but as soon as he picked Pence we got the answer: Separation to church and state.
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The Obama Administration put tight limits on pollutants, which coal power plants, with scrubbers, can not reasonably meet. Up to date coal scrubber technology has come a long ways since the 1960s. Today's scrubber technology does not meet the limits imposed by the Obama Admin.
Artificially low natural gas prices are discouraging the use of cruddy electricity sources, such as wind, nuclear, and coal. Technology for a fully renewable power grid still needs to be developed.
Jesus is coming and profit.
They CAN publish ancillary possible benefits that could happen with additional regulation, but they are legally REQUIRED to publish their study of mercury levels. It's *illegal* for them to promulgate a regulation without publishing the data they used for that regulation, in this case their study related to mercury levels. That's why the court ordered them to release it and they eventually did so.
I don't think Trump card one but about stopping sewage from Tijuana. You think the wall is good to be sewage proof?
This was actually started under Clinton and was to happen in 2001. But W postponed it until 2016. Oddly, had this happened in the 00s, most coal plants would have elected to clean up. It was the fact that nat. Gas was so cheap, that caused american coal plants to replace most of the dirtiest ones. Many of the ones closed will stay closed, BUT, it is probable that EVs are going to cause a number of these to reopen. Hopefully, trump pushes nuke SMR fast.
I prefer the "u" in honour as it seems to be missing these days.
Btw of you read up on the case, you will also find that they *knew* that what they were doing was unlawful and improper, but they did so at the insistence of a White House VIP.
If you really want to argue that the EPA administrators are wrong, that they only thought it was wrong to intentionally obscure legally required disclosures based on political pressure, I suppose you can try to make some logical argument why that's the right thing to do. Until you do so, I'm inclined to believe the people who did it, who should be experts at their job, when they decided this was improper so they should avoid mentioning the name of the White House VIP in any written correspondence. The judge who saw all of the evidence indicated it was not only unlawfully done, but knowingly unlawful.
I'll be happy to read any reasoned argument you have to make to the contrary, or view any evidence. Do you perhaps have some evidence that the court didn't see, suggesting that anyone involved thought that hiding the data was proper or even legal?
by passing an anti-speed trap law.
And it wasn't a bureaucrat who created the speed trap, it was, again, a politician. Specifically one who didn't want to pay his taxes so he used speeding tickets from folks outside his district to pay for maintaining police, fire dept, etc.
Again, your anger is misplaced. And that's not by accident. Somebody is working really hard to make you distrust government (while making sure to use gov't for their own benefit). Think harder. You can figure this out. I know you can. And when you do you can join us in making the world better for real. I mean that.
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So no mention that this rule was originally passed without a cost-benefit analysis?
Nor a mention that the cost is over $9 Billion dollars, but the actual benefit from mercury reduction is $4 - $6 Million?
Nothing about the Supreme Court kicking it back and saying an analysis has to be done?
Or that the benefits calculated in the new analysis is a sham? Where 99% of the benefits are "co-benefits" and are a by-product of mercury reduction?
If the government wants to regulate and achieve those co-benefits, then that's what they should say. Otherwise, if they say they're regulating X, but 99% of the benefits are not because of the regulation of X specifically, then that's not transparent. That's something that is easily manipulated. That's not accountable. That's not how government should operate.
Aside from transparency and accountability, we shouldn't want government passing health and safety regulations regardless of the cost.
The problem is that this would prevent the EPA from using public health studies in drafting regulations unless the study authors release data that would identify individuals' health issues.
Post may contain irony: discontinue use if experiencing mood swings, nausea or elevated blood pressure.
I think in all cases these releases were not only approved but requested of the relevant authorities
https://www.ucsusa.org/clean-e...
I don't respond to AC's.
Lets all screw the planet for more profit
That would be the first prosecution In nearly 200 years. The act is likely unconstitutional as well.
You lying fuck. This rule was forced by a 2015 Supreme Court decision. It's a consequence of the Obama administration playing fast and loose with rule making. The Trump administration had very little to do with this. Rulemaking regulations drove it.
That's exactly the problem, we don't get clear air and water.
We get dirtier, more dangerous emissions when the EPA, under political pressure, lies / distorts the facts about which regulations would best provide clean air and water at a given cost.
Had the EPA released the data as required, some environmentalists, such as those working at environmental action groups, would have read the study and seen that the EPA study said X would help the environment, but instead the EPA did Y. They would point this out and many laypersons who care about the environment would then demand that the EPA put in place the regulations that would actually make a significant improvement.
The public doesn't win by lying about which regulations will do a lot of good and which will not.
What you are referring to is a different issue entirely.
This isn't about personal data.
In this case, someone at the White House asked the EPA to put forth some new regulations on coal that would be hard to comply with. Reducing mercury levels by another 90% would be difficult and expensive ($10 billion / year, according to the EPA under Obama), so that's what the White House person asked the EPA to do. Before making that rule, the EPA is legally required to release the results of their analysis of the costs and benefits of mercury reduction at those levels.
It turns out, the EPA analysis found that further mercury reduction wasn't the best way to improve public health - not by a long shot. It would be far better to reduce the levels of sulfur dioxide, nitrogen oxides, and particulates, the EPA analysis found. That presented a problem for the EPA. Particulates can be reduced with a simple passive filter - they are literally particles. That wasn't what the White House VIP* wanted, but if the EPA released their analysis about mercury levels as required it would make their new regulation look stupid. So the EPA had a problem - release their study and look stupid, or not issue the regulation and piss off White House VIP.
Their solution was to draft an analysis of the cost of mercury reduction and the benefits of reducing particulates, sulfur dioxide, nitrogen oxides, and mercury. Less than 10% of the expected benefits were from reducing mercury, which was what the new regulation required.
This went to court in 2015 and the court ruled that the law says the EPA has to release their analysis of mercury levels. They aren't allowed to obscure the facts they came up with by mixing in benefits if particulates were also reduced, and sulfur dioxide, etc. When they issue a regulation saying mercury has to be reduced by 90%, they are legally required to release their analysis of what benefits and costs reduced mercury levels would have.
* If you thought about who in the White House was trying to punish coal-producing states and guessed that White House VIP was expected to become the next president, you've made the same guess a lot of people have.
The "arbitrary and capricious" standard has been around for much longer than OP implies. See also Citizens to Preserve Overton Park v. Volpe (1971)
And it wasn't a bureaucrat who created the speed trap, it was, again, a politician
No, the people that dictate what police do with their days are the bureaucrats that run the police force.
Again, your anger is misplaced.
I am puzzled you think there is anger involved. I am simply telling you how the world works.
"There is more worth loving than we have strength to love." - Brian Jay Stanley
If I want to hear from as asshole, I'll fart. STFU.
This is why nobody trusts the press in the United States anymore. Trump Derangement Syndrome is real and it's absolutely devastating to one's ability to distinguish dreams, wishful thinking, and fear from actual reality.
First, this proposed rule wasn't initiated by Trump or his cronies - it was the result of a court order from 2015 that REQUIRED this change.
Second, the proposed change doesn't allow anyone to do anything their not already allowed to do. It does NOT allow power plants to "release more toxic pollution." The article itself says as much:
The EPA says it is keeping the 2012 restrictions in place for now, in large part because utilities have already spent billions to comply with them. But environmental groups worry the move is a step toward repealing the limits and could make it harder to impose other regulations in the future.
Does anybody see that? THE EPA IS KEEPING THE 2012 RESTRICTIONS IN PLACE. That directly contradicts the headline. All of the hyperventilating is over people projecting about the future.
MsMash should seek treatment for TDS.
So you're suggesting that because it's been the law for a long time, that makes it okay for your favorite president to violate the law? His administration only has to follow *recent" law?
I guess that kind of goes along with his reasoning "since Congress refused to give me the changes to immigration law I wanted, I am therefore empowered to unilaterally make up new laws myself". The EPA / coal thing probably didn't have anything to do with Obama, though. We don't know for sure who "White House VIP" is, but we do know one senior official at the time who was pretty public about wanting to punish coal-producing states, and we know that official has a decades-long record of being conniving, and they've admitted on TV that they make it a point to avoid putting things in writing due to open records requests. They would therefore only be known as White House VIP, since they made a point of not writing their name on things they could be confronted with later.
"Did you keep a lot of notes?", the interviewer asked.
"Oh heavens no! They could be subpoenaed!", our favorite official answers on television. That's not Obama.
"the Environmental Protection Agency said in a statement that the cost of cutting mercury from power plants "dwarfs" the monetary benefits. "
So, what does that mean? The power plant spends $25 million to "clean up" mercury, and it means that 13 people do not contract some dread disease or debilitating condition or whatever that would only cost a few hundred thousand dollars to treat? That is like the famous car safety nazis requiring $1000's to strengthen a door with a steel beam, but it would only save X people, whereas the $1000's spent on the steel beam could instead be spent on enhanced emergency medical services and save many times more people than the steel beams could.
There's a thing that's known as penny wise and pound foolish, and we have to be careful when we're mandating this and mandating that so that we don't spend money in foolish ways. Spend it the way that benefits the most people to the most degree. Beating up on power plants with expensive modifications, maybe just because you don't like power plants, could be a foolish waste.
The court ruled when the Obama EPA lumped totally unrelated things together in a deliberate effort to obscure the results their study, that was hiding the scientific facts. To me, that's what seems anti-intellectual.
As near as I can tell the real world implication of what Obummer did saves way more in aggregate healthcare costs borne by OTHERS even when applying a generous 100% discount on intangible cost of human suffering far in excess of some 10 billion spent on scrubbers.
Those arguing against reality seem to be making an entirely pedantic process argument asserting only benefits related specifically to mercury reduction should matter therefore actual reality reflecting actual implications of Obummers changes should be ignored because politically motivated accounting bullshit trumps reality?
Is this your argument?
Is it intellectually sound to hold political characterizations above actual reality?
Any time this Administration wants to do something deplorable, some idiot always frames it as, "they are just trying to enforce the law!" And any time this Administration changes the law to something deplorable, some idiot tries to frame it as, "they are just enacting their campaign promises!"
Grow a pair. Good policy is good, and bad policy is bad. Stop trying to make it sound like someone else is doing deplorable things. We know perfectly well who is responsible, and why.
The Economic Protection Agency is in the thrall of the Big Giant Orange Head and cannot be relied upon to work for the environment. Not for the duration.
And now tell me that Trump isn't Koch brothers's bot.
It's not the same kind of pollutant as particulate, nitrogen oxides, sulphur dioxide etc..
It is consumed by animals and travels up the food chain. It is not metabolized nor broken down. It accumulates.
Is there amything in the UN UDHR that covers deliberate poisoning of the population?
It's a small world and it smells funny; I'd buy another if it wasn't for the money; Take back what I paid (SoM)
Democrats? Nixon was a Republican. You Russians aren't very good at American History eh.
e.g. some articles online or the like. I've mentioned this in other threads, but there is literally no safe level of mercury exposure. It builds up in the body over time. It's why pregnant women aren't supposed to eat fish.
Based on what I know about mercury (albeit not a huge amount) I'm with Obama on this one. But you seem to be implying Obama intentionally attacked the coal industry for some other reason. That's a pretty big accusation, but with the amount of lobbying going on you never know. Can you provide some links?
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but in case it gets missed, can I get some citations? You're implying Obama knew that reducing mercury levels wasn't worthwhile but forced the EPA to implement this rule anyway, presumable for less than honest reasons (e.g. solar or nuclear lobbyists paid him to attack coal production). That's possible.
Obama certainly wasn't above doing what his donors asked him (his cabinet was chock full of the same Goldman Sach's folks Clinton (Bill) and Bush's were.
That said, I keep saying this but there are _no_ safe level of mercury exposure. And again, as mentioned on another thread I know folks who got sever mercury poisoning from tuna fish for Pete's sake. So I'm very much inclined to side with Obama on this one.
Now, one other possibility is that it was easier to regulate mercury emissions than other emissions they actually wanted to regulate, so they target mercury to get at those. This isn't strictly on the up and up but it would make sense given how bad mercury is. Still, if the end result is less mercury in the air I'm all for it.
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Environment Last.
So there you are. There are worse places for unrooted swamp creatures to go to than Washington D.C. After all, they have relatives and job opportunities there.
The more time passes, the more apparent it is that MAGA simply means the more (poor) people die, the better.
The less (rich) people remain, the more resources per capita are available.
Voila, you (few) are great again!
> But you seem to be implying Obama intentionally attacked the coal industry
I don't think White House VIP is Obama. So no, nothing to do with Obama. The identity of VIP isn't publicly known, but probably most people familiar with the evidence in the case think it's Hillary. Doesn't really matter now, what matters is that the government should follow the law they create for the rest of us to follow.
> no safe level of mercury exposure. It builds up in the body over time. It's why pregnant women aren't supposed to eat fish.
And yet you're not wearing a biohazard suit to protect yourself from mercury in the world. You've (quite reasonably) decided to expose yourself to mercury and a lot of other much more dangerous things. Pros and cons. You've made a reasonable decision that it's not worth it. You could also spend $50,000 sealing up your house to keep mercury out, but that would be silly because if you were going to spend $50,000 being safer, you'd spend it on a safer car, more smoke detectors, etc. You want to avoid mercury, and you've already done the reasonable things - like not using mercury oral thermometers. Spending half your salary every year to be even safer from mercury would be unreasonable, in your analysis.
> Based on what I know about mercury (albeit not a huge amount) I'm with Obama on this one.
Not knowing much about mercury isn't a problem in this discussion. You can decide this without knowing anything about mercury, because there is no question about mercury up for discussion. The question is whether the government should follow the law and reveal what they know. The EPA knows about mercury, they did a big analysis of studies about mercury. The question a whether they should unlawfully hide that analysis when the results aren't pleasing to White House VIP, whoever that is.
You asked for a citation. To start with, here's the Supreme Court ruling saying what the EPA did was unlawful.
https://www.supremecourt.gov/o...
The SCOTUS ruling talks a lot about law, and specifically the specific point of law that SCOTUS chose to address, after the trial court and appeals court handled other issues of law. Issues of fact are handled by the trial court. You can use the case title to find the documents from the trial court for further information on the facts.
Nobody is saying the EPA can't regulate mercury emissions. The law says that when they regulate something, they have to release their analysis, which has to at least arguably show three things, all the while giving the EPA the benefit of the doubt (the law assumes the EPA is right if the analysis shows it's debatable). The EPA has to show that:
They considered the benefits of the proposed regulation
The considered the costs
The proposed regulation could be reasonably be expected to accomplish a lawful goal of the agency
After releasing their analysis they then have to have a comment period in which the public may comment on the analysis, pointing out any major flaws such as if it missed the primary costs, pointing better wording that would be more effective, etc. It's illegal for them to put a regulation in place and say "we don't care what the costs are, and we're not going to give anyone a chance to see our analysis or comment on it. Someone from the White House wants this, so they're going to get it - scientific analysis and the law be damned". That's not legal.
I'm not the one who came up with the name White House VIP.
That's what the EPA bureaucrats called the person.
just said that the EPA has to consider costs, it has nothing to do with whether or not somebody in the Obama administration put forward unnecessary regulations for less than honest reasons. That's the thing I'm looking for a citation for. Do you have something for that?
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Emphasis added by me. By writing "improper" here directly after using the word "unlawful" the GP is implying that the ruling was done for less than honest reasons. The two words combined give that sense in English (I'll admit I'm not enough of a language expert to say why in detail, I can only say it's because of the context those words tend to be used).
GP than says an unnamed VIP (which on another thread somebody pointed out might have been Hilary) pushed the ruling. This implies that the VIP wanted to keep themselves secret. There was no reason to add this point otherwise. GP could have just said "The Obama Administration" since Obama was ultimately responsible for the ruling. This is again a tactic being used to cast doubt on the validity of the rule by implying the people responsible for it refused to own it.
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I'm really not trying to be an envirofag here, either. I understand that older, cheaper means of producing electricity is absolutely crucial... for third-world countries that can't afford any better, that is.
So why is the United States, one of the richest countries in the world, still so obsessed with choking their own air, when they could easily afford not to? Coal and gas plants are for dirt-poor countries. Wealthy countries show off by using nuclear, green and even experimental sources of energy. Besides, the U.S. is in a very favourable position when it comes to nuclear energy, in that they have full permission to use nuclear energy and they've got shitloads of aging warheads left over from the cold war that they could convert into energy with something equivalent to a CANDU reactor.
I think it's sad that the U.S. used to be one of the biggest innovators in the world, and now they're being outdone by Australia, Canada and Iceland when it comes to producing electricity. Is the U.S. really so poor, or at least in so much debt they can't afford to do better?
I'm not trying to call the GP out for all this. I do these sort of things all the time on /.. This is a web forum and there isn't time to support every little point in a post before losing interest (either in typing it or reading it). The goal is to get a point across, which the GP did. But at the same time I'd be interested in something that supports that point (e.g. that the original rule limiting mercury emissions was unnecessary and likely done without honest intentions).
:)
On the other hand it _is_ possible the GP's intentions are the best either, e.g. that they're supporting a pro-coal agenda for some reason. I doubt they're an astro turfer (we're too far away from an election for that) but they might have drunk some of the coal industry's kool-aid. As I mentioned, I'm pretty nervous about mercury all around.
Also, I am kinda fed up with companies externalizing their costs onto my health so that they can continue to run businesses that wouldn't be profitable if they had to pay to clean up their messes (or not make them in the first place). Finally, I'd like to see that "Green New Deal" the left is pushing. A massive infrastructure push is just what this country needs to tied us over until the next tech boom. So it's not like I don't have a horse in this race (or an Agenda, ooooo,scary....).
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right here that is how Trump is going to kill these regulations.
The TL;DR; is that the EPA is required to consider cost when implementing regulations, so if Trump wins this fight he can use that SCOTUS ruling to life the restrictions on mercury emissions. So yeah, the headline is spot on.
The article isn't all that well written though. I suspect it's hamstrung by the mainstream media's desperate attempts to seem "fair and balanced" and to present both sides of the issue to some extent. There really isn't two sides here though. Trump is fighting for more mercury in the air. That's all there is to it. The only argument is can we have more mercury without any noticeable health impacts.
Given what I know about mercury poisoning (admittedly not a expert but I know folks with mercury poisoning from relatively small doses over time due to fish) I'd say no.
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> As near as I can tell the real world implication of what Obummer did saves way more in aggregate healthcare costs borne by OTHERS even when applying a generous 100% discount on intangible cost of human suffering far in excess of some 10 billion spent on scrubbers.
You're guessing the benefits are several thousand times higher than what the EPA analysis predicted. Do you have any evidence, any reason to think that?
What (Obama's) EPA analysia found was $10 billion a year in costs would have $20 million / year in benefits, including "human suffering". (You see why they didn't want to release their analysis).
You might wonder how the heck one can measure health problems, or "human suffering" as you put it, in dollars. That seems counterintuitive. Yet there's actually a really simple way to convert between dollars and health outcomes, for policy questions. There are plenty of studies about seatbelts and airbaga. We know about how much airbags have reduced traffic deaths, and various injuries. We know how much they cost. Simple division shows that seatbelts and airbags cost $500,000 per life saved. We know that CPC and OSHA regulations cost about $100,000 for every life saved. We've measured the cost and benefits of nutrition education, we know that $X spent on nutrition education reduces diabetes cases by Y%. EPA programs vary from $1 million to $10 million per life saved.
Our country has limited resources, of course. We can't spend $100 trillion / year on safety, because we don't have $100 trillion. So the question when making policy is which of these to put our resources toward:
Should we spend $10 million of workplace safety through OSHA and save 100 lives?
Should we spend that $10 million on traffic safety through DOT and save ten lives?
Should we instead spend that $10 million on benzene regulation through the EPA and save only one life?
We can save a life by spending a million dollars. Spending $10 billion on one thing means we don't have that $10 billion to spend on traffic safety or workplace safety. We lose the opportunity to save 10,000 lives. So *from a public policy perspective* that's the cost / value of a life - about a million dollars, because spending a million here means not spending that million somewhere else to save someone's life.
I cant answer any of those questions but I can say loud and clear that I do not like any of these arguments at all
I'm missing how your comment is connected to why the EPA should or should not unlawfully hide their analysis projecting benefits and costs of their proposed regulation.
Does "mercury is special" mean the public shouldn't be allo d to know that this regulation kills 10,000 people every year vs alternatives:
https://slashdot.org/comments....
> > it would have worked a heck a lot better to make them pay $10 billion for other, more effective, health related programs, Obama's EPA found.
> What? In what world would that make sense?
In a world where you don't want people to get sick and die, even if they disagree with you politically?
This particular regulation kills 10,000 people every year vs the alternatives. Personally, I think killing thousands of people is a bad thing.
As mentioned above, SCOTUS (and the appeals court) decides issues of law. Nobody testifies at the Supreme Court, no evidence is shown. The trial court deals with the facts of a case.
For the factual background, copy-paste the case title from the SCOTUS ruling (linked above) to get the trial court record.
You might wonder how the heck one can measure health problems, or "human suffering" as you put it, in dollars. That seems counterintuitive. Yet there's actually a really simple way to convert between dollars and health outcomes, for policy questions.
There are plenty of studies about seatbelts and airbags. We know about how much airbags have reduced traffic deaths, and various injuries. We know how much they cost. Simple division shows that seatbelts and airbags cost $500,000 per life saved. We know that CPC and OSHA regulations cost about $100,000 for every life saved. We've measured the cost and benefits of nutrition education, we know that $X spent on nutrition education reduces diabetes cases by Y%. EPA programs vary from $1 million to $100 million per life saved.
Our country has limited resources, of course. We can't spend $100 trillion / year on safety, because we don't have $100 trillion. So the dollar cost of a life (for policy purposes) is based on how many other people die because we spent the money on one thing and not on the other thing. We can save a life by spending a million on traffic safety, we can save a million dollars by not doing the traffic safety, but we'd lose a life. Dollars and lives are literally interchangeable at the rate of about a million dollars per life.
So the question when making policy is which of these to put our resources toward:
Should we spend $10 million of workplace safety through OSHA and save 100 lives?
Should we spend that $10 million on traffic safety through DOT and save ten lives?
Should we instead spend that $10 million on benzene regulation through the EPA and save only one life?
Common sense says we should save 100 lives by spending our time, attention, and money on workplace safety, rather than wasting our time worrying about benzene emissions. If we spend our time, money, and energy on benzene, that's time, money and energy we aren't being spent on workplace safety, so people die.
Clueless as always
He even wound up being disbarred. While I personally thought it was a bad move, it was well within the bounds of law. If the democrats are going to bring charges against the president's family based on it, you can expect the AG to do the same to most of the Democratic leadership.
John Kerry negotiating with Iran : Logan Act violation :Logan Act violation
Bill and Hillary taking Russian funds
Nancy Pelosi China: Logan Act violation
Just off the top of my head there.
Perhaps your concern is that for whatever reason we MUST spend our time, attention, and money on coal, rather than focusing on things that will save lives. Perhaps you for whatever reason you want coal companies to spend $10 billion / year on safety stuff directly related to coal.
If that's the case, you have a couple options:
A.
Ask OSHA to draft regulations for improved safety in the coal industry. Coal mining and handling coal is dangerous just because there's heavy equipment and all that, plus the dangers of coal dust. Studies show for every $million spent complying with OSHA regulations, about 2-10 people are saved. $10 billion would save about 3,500 people every year.
B.
Order the EPA to issue regulations on coal which cannot be met at a reasonable cost. If they chose reducing mercury emissions by 90% as the regulation, $10 billion spent will save about 10 lives, according to the EPA analysis.
Personally, I'd rather save 3,500 people than save 10 people. Call me crazy, but I'd rather not kill 3,490 people every year by being vindictive.
That's not true. Bureaucrats don't pass laws, they enforce them. You seem to be using the word "bureaucrat" as a stand in for "anyone in the government I don't like". That's not what a bureaucrat is, but it _is_ how a certain group of people in America would like to think. You're being taken advantage of.
As for anger, look that the language you employed in your post ("Here I'll help you understand", "Wrong", "Unseen"). Those are blunt, angry words. You have good reason to be upset, you're just pointed at the wrong target.
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I'm a conspiracy analyst :).
America has a ruling class. That ruling class uses propaganda against the working class. It is technically a conspiracy since the ruling class is doing this in concert.
Not all conspiracies are space aliens shooting JFK with magic bullets. A "conspiracy" is just two or more people getting together to plan and do something bad for their own profit.
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as soon as we funded the DMV and put enough clerks in place. There's still a bit of a wait for your kid's driver license. All told I think it took me a couple of hours IIRC. But you can get away with that because most folks do that 2, maybe 3 times in their lives (4 if you count when they were kids waiting).
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You're guessing the benefits are several thousand times higher than what the EPA analysis predicted. Do you have any evidence, any reason to think that?
From EPAs own website:
In 2016, these proposed rules would avoid:
6,800 â" 17,000 premature deaths
4,500 cases of chronic bronchitis
11,000 nonfatal heart attacks
12,200 hospital and emergency room visits
11,000 cases of acute bronchitis
220,000 cases of respiratory symptoms
850,000 days when people miss work
120,000 cases of aggravated asthma, and 5.1 million days when people must restrict their activities
EPA estimates the health benefits associated with reduced exposure to fine particles are $59 billion to $140 billion in 2016 (2007$).
Source:
https://www.epa.gov/sites/prod...
You copy-pasted from the document:
--
EPA estimates the health benefits associated with reduced exposure to fine particles are
--
Mercury is not a particulate. That's the problem.
Thousands of lives would be saved every year if Waffle Monster stopped posting on Slashdot and everyone stopped smoking.
30,000 people would be saved if Waffle Monster was kicked out of his house and there were no car accidents.
The law says they have to publish their cost/benefit analysis for each rule they make. The court ruled the law means what it says - to enforce the mercury rule, they have to publish their analysis of the costs and benefits of the mercury rule. They aren't allowed to hide the outcome of their mercury analysis by saying "if we enact the mercury rule and a particulate rule and a sulfur dioxide rule and a rule for nitrogen oxides ...". They did an analysis for mercury, they are required to release their analysis for mercury.
What (Obama's) EPA analysia found was $10 billion a year in costs would have $20 million / year in benefits, including "human suffering". (You see why they didn't want to release their analysis).
What I found interesting in TFA was the benefit analysis. The EPA estimates the actual harm caused by the actual mercury to be about $20 million. There's an additional benefit from reducing soot and other pollutants which aren't mercury of billions of dollars more.
What I find absolutely infuriating is that the EPA and other administration people would deliberately mislead people by claiming the issue is mercury! I don't believe that was an accident. I am certain the whole point of the mercury restrictions was not mercury, it was other pollutants. So for crying out loud, be honest about it. Mercury is an easy "Eeek! Scary neurotoxin heavy metals!" sales pitch but it's dishonest.
If you want to reduce soot or carbon dioxide or something else, just say so. Don't distract us with side issues because they're scarier. If you can't make your case on honest facts, perhaps you don't have a case.
Let me see if I follow your logic / claims. Tell me if I'm missing something.
Are you saying:
1. The measures taken to decrease mercury by 90%, at a cost of $10 billion / year, are the exact same measures required to meet the other rule regarding particulates. Therefore it's impossible to reduce particulates (as with a passive filter) without spending $10 billion / year and reducing mercury as a side effect.
2. Therefore the EPA *had* to combine the particulate analysis with the mercury analysis, because since you can't get rid of particulates without also getting rid of mercury.
3. They couldn't release their analysis of particulates, without first combining it with their mercury analysis, since you can't do one without the other.
Is that your reasoning? If that is not what you're saying, why exactly can't they release both their particulates analysis and their mercury analysis? Btw after the court order, the mercury analysis did in fact get out.
If that IS what you're saying, if you think that in fact reducing particulates with a filter necessarily also reduces mercury by 90%, does that not make the mercury rule redundant and unnecessary, given the particulate rule?
You think the wall is good to be sewage proof?
ITYM "You think the steel slats are going to be sewage proof?" Not only won't they hold back sewage, but the sewage will corrode them...
"You're right," Fisheye says. "I should have set it on 'whip' or 'chop.'"
> You're just making up lies because it was Obama, and there is "something" about him that causes you to lie when you see his name. I wonder what it could be?
As I've already said, I don't see any reason to believe Obama had anything to do with it. You're the one bringing up Obama. Are you one of these people who thinks that not only can he do no wrong, but no federal employee could possibly do anything wrong during a time when Obama was President? That's weird, but okay.
> Right here you'd doing a bait-and-switch and trying to imply that if you didn't publish financial numbers about the harms, then that somehow proves that the rule made the air "dirtier" and the emissions "more dangerous."
It's not financial numbers that are at issue. There are two issues. There is the legal issue that the EPA was supposed to release their mercury analysis. Secondly, you mentioned the issue that lying about what will result in clean air and water tends to make our efforts less effective. The first issue, the legal issue, I've covered throughly in other posts, so here I will address the issue you brought up, "made the air dirtier".
Under political pressure the EPA issued a rule saying coal plants had to spend $10 billion on mercury scrubbers. When challenged to produce their analysis of the costs and benefits of the reducing mercury by that amount, they released an analysis saying that spending a fraction of that money to reduce particulates and sulfur dioxide instead would have been far more effective, according to the EPA analysis. Spending it on workplace safety in the coal industry would have been even more effective - saving A HUNDRED TIMES as many lives.
The rule spent limited resources on something that doesn't have much effect INSTEAD OF using that money on something that would make us safer.
Lying to the public doesn't benefit the public - no matter who is president.
Trump tardation.
found the libtard, blame boogeyman russia for all problems created by democrat party!
The measures taken to decrease mercury by 90%, at a cost of $10 billion / year, are the exact same measures required to meet the other rule regarding particulates.
Therefore it's impossible to reduce particulates (as with a passive filter) without spending $10 billion / year and reducing mercury as a side effect.
I have no idea what the cost/benefit of different policy formulations that include or don't include mercury are.
Therefore the EPA *had* to combine the particulate analysis with the mercury analysis, because since you can't get rid of particulates without also getting rid of mercury.
They couldn't release their analysis of particulates, without first combining it with their mercury analysis, since you can't do one without the other.
I don't believe so. It's useful to have itemized and grouped costs and benefit estimates to inform policy decisions wherever possible. I suspect there are a number of practical challenges based on assumptions related to currently available technology.
I don't support hoarding analysis paid for by tax payers for political reasons to achieve political objectives.
I also don't support manifest bullshit like costing specific policy proposals based only on a specific criteria rather than real world aggregate effect it's predicted to have.
If you or industry goons running the EPA want to propose different competing policy formulations then I would hope each would be evaluated on the merits subject to appropriate political scrutiny with full consideration of ALL predicted outcomes NOT arbitrary primary vs incidental bullshit.
> > Therefore it's impossible to reduce particulates (as with a passive filter) without spending $10 billion / year and reducing mercury as a side effect.
> I have no idea what the cost/benefit of different policy formulations that include or don't include mercury are.
I will represent to you that when I typed my earlier reply to you, I was sitting next to a device that greatly reduces particulates in the air. It's known as a "HEPA filter" and doesn't cost $10 billion.
I will further represent to you that a simple filter, which does remove particulates, does NOT remove mercury vapor. Removing mercury vapor is an active process involving the use of bromine to oxidize the mercury vapor, then other equipment to remove the oxidized mercury. This is the process which the EPA says costs $10 billion.
Therefore it's entirely possible to filter out the particulates without removing the mercury, or any other gas or vapor. I'm doing it at my house right now.
Therefore the EPA didn't have to wait for a court order before releasing their analysis of particulate removal (very helpful and also pretty cheap) and also release their analysis of mercury scrubbing (very expensive for limited benefit). No need to artificially combine the analysis of inexpensive particulate filters with the analysis of far more experience mercury scrubbers.
"From where I sit" -- where you sit appears to be in a pile of festering shitty malevolent ignorance, mixed with some ludicrous denial that you're as vile as the Trump you kid yourself you don't support. You're two rancid racist peas in fucking pod, mate.
Justice was meant to be blind, but, whatever.
Why check first if you can always be wrong instead?
What (Obama's) EPA analysia found was $10 billion a year in costs would have $20 million / year in benefits, including "human suffering". (You see why they didn't want to release their analysis).
What I found interesting in TFA was the benefit analysis. The EPA estimates the actual harm caused by the actual mercury to be about $20 million. There's an additional benefit from reducing soot and other pollutants which aren't mercury of billions of dollars more.
What I find absolutely infuriating is that the EPA and other administration people would deliberately mislead people by claiming the issue is mercury! I don't believe that was an accident. I am certain the whole point of the mercury restrictions was not mercury, it was other pollutants. So for crying out loud, be honest about it. Mercury is an easy "Eeek! Scary neurotoxin heavy metals!" sales pitch but it's dishonest.
If you want to reduce soot or carbon dioxide or something else, just say so. Don't distract us with side issues because they're scarier. If you can't make your case on honest facts, perhaps you don't have a case.
I'm proud that this came out in the Slashdot discussion, rather than being drowned out by a deafening echo chamber. Both parties have attempted to abuse and pervert the EPA to their liking.
Even those who arrange and design shrubberies are under considerable economic stress at this period in history.
Let's assume that burning coal is really bad. I haven't researched clean coal and probably you haven't either, but for now let's just pretend that doesn't exist. Wouldn't that mean we should focus on burning less coal?
$10 billion / year is enough to build six new 600MW power plants every year. If we're going to spend $10 billion each year on something related to coal power plants, wouldn't we want to spend that money REPLACING them?
Any native speaker can spell non, where are you from? What is your language/agenda here?
NO, because they were taping russian/chinese SPIES.
Thats quite a bold statement to make with absolutely no evidence to back it up.
Checks username...
Oh it's WindBourne, the 100% honest and reliable holder of all the secret information.
Yea, I'm going to believe you...
We already know you hate people who point out your lies and idiocy. Eventually you will realise there is more than just one person who can spot your obvious lies.
Like I said before. In only 2 years (2020) no one will buy ICE anymore.
First off, new ICE cars will probably stop selling in about 2 more years.
--
WindBourne
Like I said before. In only 2 years (2020) no one will buy ICE anymore.
First off, new ICE cars will probably stop selling in about 2 more years.
--
WindBourne
I'm still not sure what you're point is.
I asked you why, exactly, the EPA should illegally hide their analysis and your reply seems to be a random copy-paste from Lloyd that doesn't have anything to do with the topic at hand. Did you "butt dial" that reply? Do you just like saying "the commons" a lot?
> When the regulations are changed, the money will *not* be redirected to other environmental controls. It will go to profits.
So it was impossible for them to be honest and release the analysis that showed which regulations WOULD be effective, and implement *those*? The EPA *has* to be either inept or corrupt? For some reason they *couldn't* regulate the more harmful stuff (sulfur dioxide, nitrogen oxides, etc), so they *have* to lie about mercury and issue pointless regulations?
Btw you're conflating organic and inorganic mercury. Organic gets in fish. Coal releases inorganic.
Instead of a wall, can you please build a dome over your country to keep your pollution in?
The quote is right there WindBourne, how can it be a lie?
Oh, you always call people a liar for making you look foolish. Carry on.
I will represent to you that when I typed my earlier reply to you, I was sitting next to a device that greatly reduces particulates in the air. It's known as a "HEPA filter" and doesn't cost $10 billion
Relevance?
Assume it costs $1/year per GW plant.
Assume it costs $1000000000000/year per GW plant.
Either way what difference does it make to the issue at hand?
Therefore the EPA didn't have to wait for a court order before releasing their analysis of particulate removal (very helpful and also pretty cheap) and also release their analysis of mercury scrubbing (very expensive for limited benefit). No need to artificially combine the analysis of inexpensive particulate filters with the analysis of far more experience mercury scrubbers.
Relevance?
The issue is NOT what previous administrations did.
The issue is NOT level of detail provided in supporting analysis.
The issue is ONLY whether it is rational policy to intentionally fail to consider all predictable impacts of a specific policy proposal.
If you have a competing proposal without mercury that is more cost effective don't let anyone stand in the way of you building consensus for it and having it judged fully on the merits. Don't judge it based on weighted bullshit with no purchase on objective reality.
> If you have a competing proposal without mercury that is more cost effective don't let anyone stand in the way of you building consensus for it and having it judged fully on the merits. Don't judge it based on weighted bullshit with no purchase
My proposal is to read the EPA's analysis of the mercury regulation, read their analysis of the particulates regulation, read their analysis of the sulfur dioxide / nitrogen oxides regulation, and do whatever makes sense based on the analysis they are legally required to provide. Fair enough?
That's not at all how it works. The fact you out sell China with ICE vehicles (less efficient ones too) is not a good thing it's a bad thing fool...
Idiots like you don't go much for thinking do you WindBourne...