Environmental Protection Agency

The Environmental Protection Agency (EPA) is seeking comments on its proposed rule, “Increasing Consistency and Transparency in

The Environmental Protection Agency (EPA) is proposing new source performance standards (NSPS) for residential wood heaters, wood-fueled pellet heaters, Hydronic Heaters, Forced-Air Furnaces, and Residential Masonry Heaters. According to the EPA, these new lower-emission standards will generate improvements to the environment and to public health, primarily through the lowering of the emissions of pollutants like particulate matter, carbon monoxide, and volatile organic compounds. The EPA believes these pollutants contribute to increases in human mortality and other health problems.

The proposed regulatory changes generally lower permitted wastewater discharges. For most existing sources of wastewater entering surface water, the same requirements are applied by each of the EPA’s four preferred regulatory alternatives, which differ in terms of the requirements applicable to existing discharges of pollutants found in two waste streams. The EPA estimates different levels of costs for the four alternatives. One criticism of starting with just four alternatives is that the alternatives being considered are, in fact, quite narrow. The major provisions of the alternatives for both existing sources and new sources of pollutants are summarized below, along with proposals for the control of new wastewater sources, for which there really are no alternative regulatory proposals. The EPA manages to count a total of eight alternatives for old and new sources by matching the proposals for new sources to the alternatives for existing sources. This is misleading because the proposals for new sources are just minor tweaks to the four alternatives for existing sources. In proposing ELGs, the EPA’s principal focus is on the application of economically attainable best available technologies (BAT). These are the second most stringent standards possible (the EPA could instead use an average of best performances within an industry and then exercise considerable discretion in constructing the standards). The EPA decides exactly how it will combine factors such as age of plant, location, and non-water environmental impacts in identifying a BAT. The current approach does not identify any reason to impose standards that are available within the industry upon firms in the industry that are not using those standards. There is no fully developed benefit-cost analysis properly incorporating considerations of externalities. Rather, there is a hazy view of external costs that might exist, but are not accurately quantified.

The Environmental Protection Agency (EPA) is proposing new vehicle emissions standards and a reduction in the sulfur content legally permitted in gasoline. According to the EPA, these new standards will generate improvements to the environment and to public health, primarily by lowering the emissions of pollutants, like particulate matter (PM) and ozone. The EPA believes these pollutants contribute to increases in human mortality and other health problems. We find that the EPA has failed to acknowledge the high degree of uncertainty surrounding its estimates of benefits from this regulation. A growing literature calls into question the causal link between the total concentration of ambient particulate matter and mortality levels, especially at the low doses that exist today in many parts of the United States. Additionally, the EPA failed to consider other adverse effects of its rules, such as impacts on low-income individuals and adverse employment effects that were overlooked in the EPA’s scant employment impact analysis.

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EPA is proposing to make certain revisions to the 1988 underground storage tank (UST) technical, financial responsibility, and state program approval regulations. These changes establish federal requirements that are similar to key portions of the Energy Policy Act of 2005; they also update certain 1988 UST regulations. Proposed changes include: Adding secondary containment requirements for new and replaced tanks and piping; adding operator training requirements; adding periodic operation and maintenance requirements for UST systems; removing certain deferrals; adding new release prevention and detection technologies; updating codes of practice; making editorial and technical corrections; and updating state program approval requirements to incorporate these new changes. These changes will likely protect human health and the environment by increasing the number of prevented UST releases and quickly detecting them, if they occur.

Score: 33 / 60

Score: 33 / 60

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Score: 31 / 60