Nothing but provide jobs for Westerners. Don't take it from me -- read this interview with Michael Maren, a returned Peace Corps Volunteer who has spent the last 20 years working in development and journalism in Africa: A complete waste of money that succeeds primarily at keeping Westerners Employed
Read the whole thing.
Well, good news for me, anyway, since it will benefit our client's clients, and what's good for them is good for us. And good news for electricity, plastics and chemicals consumers in the U.S. because they'll be getting cheaper stuff. Good news all around, unless you like to breathe, right? And who does that anymore?
The EPA is relaxing some of its equipment replacement rules. Naturally the New York Times has a fit:
In one of its most far-reaching environmental actions, the Bush administration signed a rule that will allow thousands of power plants, refineries, pulp and paper mills, chemical plants and other industrial facilities to make extensive upgrades that increase pollutants without having to install new antipollution devices.
Those blackguards!
Fox News, on the other hand, is thrilled:
Thousands of older power plants, refineries and factories have been exempted from having to install costly clean air controls when they update equipment to improve efficiency, the Bush administration announced Wednesday.Strangely, though, Fox gives more time to the Natural Resources Defense Council than the New York Times.
"It's an accounting gimmick that eliminates any possibility of pollution controls," said John Walke, director of Natural Resources Defense Council's clean air program. "It's a total disaster. It's the effective repeal of this clean air program, through illegal administrative means."Whether that's because Fox thinks Mr. Walke has a funny-sounding name is left to the reader's discretion.
So I read the stupid fact sheet and I've skimmed the final rule. There are some choice quotes in the final rule, like this Clinton-bash
Specifically, some of the case-by-case determinations we have made, particularly over the past decade, and particularly in a series of enforcement actions, have been criticized for giving the exclusion a narrow scope that disallows replacement of significant plant components with identical or functionally equivalent components.
Here's my summary of the issue. The clean air act requires that a new plant must install state-of-the-art pollution control measures, under a provision called New Source Review (NSR). Old plants are grandfathered in and allowed to operate with their current equipment as long as they meet other applicable clean air standards. But if you upgrade an old plant in any way which results in an increase in pollutant output, you may run afoul of the NSR rules. It's expensive to get an NSR permit, it's risky to guess that your upgrade is in compliance, and it's expensive (though less expensive) to get a review that says NSR does not apply. This has led to silliness like upgraded plants being shut off for parts of the day or year so that their total pollutant output doesn't exceed their pre-upgrade output.
So under the new rule, replacement of parts with identical or functionally equivalent parts will not trigger NSR even if emissions increase unless the replacement effects a change to the design parameters of the plant.
Suppose your heat exchanger pump fails. Under the old rules, you're better off trying to repair it. If you replace it (even with the exact same model) and your emissions increase (even though you're under the legal limit), you run the risk of needing an NSR review, unless you can convince the EPA that the increase happened because of repair, maintenance, and routine replacement (RMRR). The EPA decides this on a case-by-case basis.
Under the new rules, you can replace the pump with the exact same model, or if you can't get the exact same model pump that you got back in 1971 when the plant was commissioned, you can put in a new pump. You're can no longer get into trouble if your emissions increase. There are still rules: the aggregate replacement cost for a year has to be less than 20% of your plant's value. You can't increase the maximum input or output capacity of your plant -- so you can't sneak in an extra turbine in this way. And of course you can't violate any existing emission limit.
This looks like a good and sensible change. But then, I'm an industry shill.
I don't have time to write a long thoughtful response to Colby's post about creeping totality, but I have to tell you -- and I mean this admiringly -- that he has produced the most impressive burst of wind on the subject that I have seen in a long time.
After all, what Colby says boils down to slippery slope. Enough people dislike smoking sections in restaurants that a majority of their elected representatives feels comfortable in banning them -- and this will inevitably lead to the total ban and destruction of pre-1978 literature.
As Colby himself pointed out last September, this has "the cognitive status of a fart".
Good night.