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. @EPA's own Science Advisory Board out with a strong critique of the pending proposal "Mercury and Air Toxics Standards for Power Plants Residual Risk and Technology Review and Cost Review"
https://yosemite.epa.gov/sab/sabproduct.nsf/LookupWebReportsLastMonthBOARD/4908A62FD4C0DE2285258549005B8797/$File/EPA-SAB-20-004+.pdf
https://yosemite.epa.gov/sab/sabproduct.nsf/LookupWebReportsLastMonthBOARD/4908A62FD4C0DE2285258549005B8797/$File/EPA-SAB-20-004+.pdf
"The SAB notes that the EPA’s benefit-cost analysis of the proposed action categorically excludes co-benefits. That departs from the Agency’s long-standing practice and is contrary to both the Agency’s guidance document on economic analysis (U.S. EPA 2014)
"and to the recommendations of the Office of Management and Budget (U.S. OMB 2003).7 As the Agency’s guidance has been previously reviewed by the SAB, excluding co-benefits is a departure from the Board’s recommended practice.
"The SAB has specific concerns regarding the human health risk assessment that was conducted
by the EPA for the Residual Risk Assessment (Section 2.5 of the Residual Risk Assessment document)."
by the EPA for the Residual Risk Assessment (Section 2.5 of the Residual Risk Assessment document)."
After a discussion of the latest science on mercury exposure, the SAB recommends that "the EPA should prepare a new exposure estimate that
accounts for total exposure.
accounts for total exposure.
"Methylmercury exposure for local populations should consider both exposure from U.S. power plants as well as overall exposure, particularly from ocean
fish.
fish.
"In addition, the EPA should consider accounting for the incremental exposure that this
sector contributes to overall exposure for the entire population."
sector contributes to overall exposure for the entire population."
For some additional background on mercury and EPA's pending MATS proposal over all listen to @kflambert here: https://eelp.law.harvard.edu/2019/03/kathy-fallon-lambert-and-joe-goffman-discuss-mats-and-ace/
