Research Journal

  • October 14, 2020

    Mercury and Air Toxics Standards (MATS)

    EPA Announced Mercury and Air Toxics Standards (MATS) for Power Plants

    December 21, 2011: EPA press release announced standards to limit mercury, acid gases and other toxic pollution from power plants.
    Until now there have been no federal standards that require power plants to limit their emissions of toxic air pollutants like mercury, arsenic and metals – despite the availability of proven control technologies, and the more than 20 years since the 1990 Clean Air Act Amendments passed.

    • The final rule sets standards for all hazardous air pollutants (HAPs) emitted by coal- and oil-fired electric generating units (EGUs) with a capacity of 25 megawatts or greater.
    • All regulated EGUs are considered major under the final rule. EPA did not identify any size, design or engineering distinction between major and area sources.
    • Existing sources generally will have up to 4 years if they need it to comply with MATS.
      • This includes the 3 years provided to all sources by the Clean Air Act. EPAs analysis continues to demonstrate that this will be sufficient time for most, if not all, sources to comply.
      • Under the Clean Air Act, state permitting authorities can also grant an additional year as needed for technology installation. EPA expects this option to be broadly available.
    • EPA issued MATS under a Consent Decree of the D.C. Court of Appeals requiring EPA to issue a proposal by March 16, 2011, and a final rule in December 16, 2011.
    • In 2000, after years of study, EPA issued a scientific and legal determination that it was “appropriate and necessary” to control mercury emissions from power plants. The prior administration finalized a rule to cut mercury pollution from power plants, but the D.C. Circuit struck the rule down and required EPA to develop standards that follow the law and the science in order to protect human health and the environment.

    “Gutting” MATS April 16, 2020: EPA press release

    Today, the U.S. Environmental Protection Agency (EPA) corrected flaws in the 2016 Supplemental Cost Finding for the Mercury and Air Toxics Standards (MATS) for coal- and oil-fired power plants, consistent with a 2015 U.S. Supreme Court decision. The agency also completed the Clean Air Act-required residual risk and technology review (RTR) for MATS. Power plants are already complying with the standards that limit emissions of mercury and other hazardous air pollutants (HAPs), and this final action leaves those emission limits in place and unchanged.

    April 2020 Report from
    explaining how the new ruling affects MATS regulation. Wheeler, head of EPA says CBA was wrong and it is no longer necessary to enforce, as we emit only 2% of the world’s mercury form coal. Earth Justice is suing.

    Until the Mercury and Air Toxics Standards came on line, they accounted for half of the total man-made emissions of mercury in America and more than half of all arsenic, hydrochloric acid, hydrogen fluoride, and selenium emissions. They are also among the worst emitters of other toxics, including lead (think Flint, Michigan) and chromium (think Erin Brockovich).

    Initially established in late 2011 after decades of effort by Earthjustice and others, the Mercury and Air Toxics Standards became the first set of federal regulations to limit mercury and other air toxics emitted by power plants. It also was the first rule to require meaningful reductions of pollution from many older coal plants that had been allowed to dodge pollution control requirements for decades.

    “The idea of the Mercury and Air Toxics Standards is to get all the air toxics out of power plants, not just mercury,” says Earthjustice Attorney Jim Pew.
    Once the Mercury and Air Toxics Standards was enacted, the worst emitting power plants had to choose between shutting down or installing pollution control equipment such as baghouses and scrubbers. The results were stunning.
    Mercury emissions from power plants dropped by 81.7 percent from 2011 through 2017, according a recent analysis by the Center for American Progress. And, contrary to dire predictions by lobbyists for the power industry, power plants are continuing to operate and the lights remain on.
    “The reductions were very significant; everything worked very smoothly,” Pew says. “Right now, the rule is working just fine.”

    Murray Energy, which claims to be the “largest underground coal mining company in America,” continued to challenge the standards in court. And now with Andrew Wheeler, Murray  Energy’s former lobbyist and current administrator of Trump’s EPA, the agency wants to undermine the Mercury and Air Toxics Standards and let more toxic pollution into the air.

    Under Wheeler, the EPA’s new argument is that the Mercury and Air Toxics Standards is not “appropriate” because its costs outweigh its benefits. But that claim rests on some very dodgy accounting.

    FIRST, the EPA considers only the benefits of pollution reduction that have been “monetized” — i.e., reduced to a monetary value. For example, the EPA doesn’t count the benefit of eliminating vast quantities of mercury from our air, water, and fish because those benefits have never been monetized. Likewise, the EPA assigns no value at all to eliminating tons of emissions of lead, arsenic, and chromium emitted by power plants. Instead, the EPA’s new analysis considers only the monetized value of the IQ points it anticipates will be lost by children who are exposed to mercury in freshwater fish.

    SECOND, the EPA dismisses the value of benefits that have been monetized. It is undisputed that the Mercury and Air Toxics Standards also will eliminate the emissions of thousands of tons of fine particulate matter emissions, along with power plants’ emissions of mercury, lead, and other hazardous air pollutants. The EPA has robust data on the health benefits — and the monetary value — of the reduction of particulate matter emissions. It will prevent:

    • up to 11,000 premature deaths from respiratory and cardiovascular illness;
    • 3,100 emergency room visits for children with asthma;
    • more than 250,000 fewer cases of respiratory symptoms and asthma exacerbation in children;
    • and 4,700 non-fatal heart attacks.

    All that adds up monetarily to $90 billion. The total cost of the rule is about $9 billion — dimes to dollars.

    Edison Electric Institute, the association that represents all U.S. investor-owned electric companies, and other utilities have written letters to the EPA saying just that.

    “They’ve already spent the money to comply, they don’t want a disruption by having the deregulation, and they don’t want the bad actors like Murray Energy to get a competitive advantage from this,” Pew says.

    If Wheeler’s proposal could establish dangerous precedent for future regulations. The new rule could create a higher threshold for future regulations by narrowing the range of benefits the agency can consider when devising new rules. This would make it nearly impossible for the EPA to justify new life-saving protections.

    “What an amazing effort to snatch defeat from the jaws of victory,” Pew says. “Wheeler’s con game will benefit no one but his former clients and, if successful, it will release tons of toxic pollution into the air and cause thousands of people to die unnecessarily every year.

  • October 14, 2020

    Metabolic Selves

    A new video, produced by the RCA architecture group called Metabolic Selves, in conjunction with the Serpentine Gallery in London, offers the view that we should not look at toxins and pollutants as external entities, as things/effects/assemblages outside of ourselves. Our insides and outsides are subject to the same “chemical influxes that we have exerted on our environment… When we ingest matter, we also ingest a chain of political, cultural, and economic signifiers.” The collective Metabolic Selves promulgates a new paradigm which begins with humans acknowledging that we actively and always are “metabolizing bodies and conjunctions.”

  • October 9, 2020


    Responses to John Hultgren’s essay “Those Who Bring From the Earth: Anti-Environmentalism and the Trope of the White Male Worker” (2018)

    We are the party of America’s growers, producers, farmers, ranchers, foresters, miners, commercial fishermen, and all those who bring from the earth the crops, minerals, energy, and the bounties of our seas that are the lifeblood of our economy. Their labor and ingenuity, their determination in bad times and love of the land at all times, powers our economy, creates millions of jobs, and feeds billions of people around the world. Only a few years ago, a bipartisan consensus in government valued the role of extractive industries and rewarded their enterprise by minimizing its interference with their work. That has radically changed. We look in vain within the Democratic Party for leaders who will speak for the people of agriculture, energy and mineral production.
    Republican Party Platform Committee 2016

  • October 5, 2020


    There has been a plethora of studies, scholarly research articles and popular essays connecting masculinity, homophobia, and an aversion to environmental concerns, which emotionally skew as feminine (sissy, frankly). I would argue that women who identify as living contentedly inside a patriarchal societal structure are also party to this attitude. Is it the same group who do not wear masks to avoid COVID-19?


  • October 4, 2020

    Depressing concrete poetry

    I love glossaries like this, as formal things.
    In this case (from the BCA document linked above),
    a powerful anthropocene poem (SISNOSE!)–

  • October 1, 2020

    Cost benefit analysis

    Cost Benefit Analysis Federal Regulation: Cost-benefit analysis (CBA) is a tool used by regulatory decision makers to identify the costs and benefits, in financial terms, of a regulation to society as a whole. Persons preparing a CBA attempt to assign a monetary value (also know as monetizing) to all the predicted costs and benefits of a regulation.

    Because this is such a long post, and was a process unfolding, I’m putting my main questions up here:

    1. Did the 2020 proposed amendment to CBA at the EPA get passed? (Proposed Rule: Increasing Consistency in Considering Benefits and Costs in the Clean Air Act Rulemaking Process)

    2. Do public hearings have any effect on the passing of a proposed ruling?
    Federal register FAQ (seems Kafkaesque, entirely based on subjective assessment as to the import of public comments)

    – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – –

    It seems that the elimination of co-benefits is the biggest (and sneakiest) adjustment to the Clean Air Act. The call for “transparency” is another way of taking a linear approach that refuses to factor true cost (which is often systemic, not object oriented (in this case an “object” is a single pollutant). This object approach (is there a better term for it?) serves only the polluters and associated industries who do not want to be regulated because it costs them too much, and not people–especially poor people–who are subject to the toxic, often complex and systemic results of pollution as a result of living in proximity to pollution-producing industrial practices (be those factories, power plants, dumps).

    Seems like MATS (Mercury and Toxic Air Standards) was scapegoated by those in support of the new ruling:

  • October 1, 2020

    No Mans Land

    David Byars’ 2018 documentary No Mans Land is an account of occupation of Oregon’s Malheur Wildlife Refuge in 2016. It is the story of those on the inside of this movement, attempting to uncover what draws Americans — the ideologues, the disenfranchised, and the dangerously quixotic — to the edge of revolution. 

    Coarse observations:
    – Aamon Bundy and several other activists occupying Malheur are compelling, intelligent and sympathetic characters. The film made little attempt to starkly contrast their self-perceptions with other local stakeholder’s perspectives
    – Prayer is embodied in the vein of “soldiers” doing God’s work.
    – Gender roles are distinct and stereotypical (for the most part)
    – After the trial, a Black interviewee stated: Bundy asserted that the USA is a white utopia. And the jury agreed…

    Add’l resource: a brief survey of US mini-rebellions and political stands with a notable section on the double-standards in the land-use war between Bundy’s militia and the indigenous Paiute community in Burns, for whom Malheur is part of their sacred tribal lands:

  • September 28, 2020

    Market-based solutions (chapter 14, Layzer)

    EPA NAPAP page
    USGS reports page

    To answer question 2:
    Just for fun: Sabine Hossenfelder’s piss take “follow the science
    How can science play a greater role without participating in politics?

    Also discuss:
    * Cost benefit analysis shortcomings in breadth, timescale, inputs

    I think scientists need to be HIRED in gov’t agencies (not fired or muzzled). They are hired as civil servants in gov’t agencies, not appointees who represent the government’s spin on any issue the public is imperiled by.

  • September 27, 2020

    First World political ecology: lessons from the Wise Use Movement

    James McCarthy demonstrates, through a case study of theWise Use movement, that the insights and tools of political ecology have much to offer in the study of First World resource conflicts. He uses theories and methods drawn from the literature concerning political ecology and moral economies to argue that many assumptions regarding state capacity, individual and collective identities and motivations, and economic and historical relations in advanced capitalist countries are mistaken or incomplete in ways that have led to important dimensions of environmental conflicts in such locales being overlooked.

    Some preliminary thoughts:
    1. environmentalists and artists need to get on the land, interview stakeholders, understand systems at work in order to have any legitimacy as critics, or offer “fair” input.
    2. Malheur and Bundy’s local claims in Nevada seem maniacal, but their rage is fueled by a sense of dispossession and deep buy-in to the stories they have been told and continue to promulgate about ancestral rights. The Wise Use arguments (stories) are masterfully edited to omit several key “figures,” primarily indigenous land use and lives, and their complexly dependent relationship to BLM land leases, which, contrary to the myths they prop up, are still being rented to them at 1980’s rates (thus the ugly term “Welfare Ranching.”)
    3. Rebecca Solnit in her book River of Shadows asserts that “time in the nineteenth century was transformed from a phenomenon which linked humans to the cosmos to one linking industrial activities to each other. This transformation changed the way humans imagined their world.” (sparknotes) The rise of technological/land/ed identity can be seen in the westward expansion of trains, in the rise of the proto-entertainment industry (the book is focused on the works of Eadweard Muybridge, and his contributions to the formation of the West’s image, and its export back east. This image gives rise to Western identity (or possibly identities). This is a hunch on my part: time, the synchronization of time, which of course has exploded into a capital G Global sensibility is at odds with the mythos of the West that persists.

  • September 27, 2020

    Race, Nation, Nature

    Responses to the eponymous McCarthy and Hague text,  

    Race, Nation, and Nature: The Cultural Politics of “Celtic” Identification in the AmericanWest
    Author(s): James McCarthy and Euan Hague
    Source: Annals of the Association of American Geographers, Vol. 94, No. 2 (Jun., 2004)

    An examination of the claims of Celtic identity by Wise Use activists in NM in the 1990s. The claim of a coherent ethnic identity has given white settlers a way to describe themselves as oppressed and in resistance to the state, thereby
    afforded them symbolic resources in negotiating the challenges of both multiculturalism and neoliberalism…while retaining the benefits of white privilege.

    Whiteness as a study has been catching up with the study of marginalized groups, by
    tracing how the exclusion and inclusion of various ethnic groups from the category “white” served both to legitimize colonialism and to divide and control the working class

    …identity (is not) as a stable property or objective descriptor of individuals and groups and towards understanding it as constructed, changeable, fragmented, and often internally contradictory.
    racial identity plays as important, if less apparent, a role in the geographies of rural, mainly’ “white” areas, places that are -to some eyes, at least- “less obvious sites of difference” 
    Geography looks at the locales of hate groups and place-specific versions of whiteness.

    The construction of whiteness as motile requires analysis of all the variables that constitute this monolithic category (the podcast Seeing White addresses this in many different instances, when it’s convenient to include or exclude, for instance).