Leading Economists Give Industry Reports on EPA an Incomplete, D, two Fs

The economic impact of current policies for the American Destruction Agency, more commonly known as the Environmental Protection Agency (EPA), have been reviewed & graded by leading economists.

 

The conclusion? EPA Administrator Lisa Jackson should be riding the Short Bus!

From the National Resources Defense Council --

WASHINGTON  (October 28, 2010) -- Recent industry reports purporting to evaluate the economic impacts of policies to keep America’s air clean received unsatisfactory grades from leading economists. Economists from Dartmouth, the University of Wyoming and the University of California at Santa Barbara gave reports from the Manufacturers’ Alliance, IHS Global Insight and Fisher International an Incomplete, D and F respectively.

“These industry groups are attempting to shape vital public health policies with work that wouldn't pass muster in a college economics class,” said John Walke, senior attorney and director of NRDC’s Clean Air Program. “Industry lobbyists are resorting to shoddy economics and outright deception to block EPA rules that could reduce toxic air pollution from industrial plants and save nearly 5,000 lives a year and prevent thousands of cases of respiratory and heart disease. These lobbyists are going further and opposing more protective national smog standards that could save up to 12,000 lives each year.”

For the full reviews go to: http://docs.nrdc.org/legislation/files/leg_10102801a.pdf

Here are excerpts of the reviews from the economists grading these reports:

“Economic Implications of EPA’s Proposed Ozone Standard” - by Manufacturers’ Alliance (MAPI)
Evaluator: Richard B. Howarth, the Pat and John Rosenwald Professor in the Environmental Studies Program at Dartmouth College

Letter Grade -- Incomplete

“The MAPI report is fundamentally flawed, resting on an analytical framework that is scientifically unsound and inappropriate for use in policy evaluation.”

“The report fails to apply standard statistical techniques that are taught to students specializing in the fields of statistics and econometrics.”

“The report would warrant a grade of ‘incomplete’ if it were submitted as an undergraduate honors thesis or master’s thesis in an academic program focusing on environmental policy analysis.”

Evaluation of the Economic Impact of Proposed EPA Air Toxics Rule on Industrial, Commercial, and Institutional Boilers and Process Heaters – by IHS Global Insight
Evaluator: Jason F. Shogren, Professor, Department of Economics and Finance, University of Wyoming

Letter Grades -- D & F
Application -- D
“Lack of a serious accounting of economic behavior -- no attempt to account for the behavioral elasticities of demand, a high end cost estimation, one-to-one mapping of upgrade costs to demand reduction, not addressing impacts in non-sector gainers within the economy, no accounting for R&D and new technology innovations and entrepreneurship.”

Transparency -- F

“Weak discussion on the basic economic role of responsiveness and substitution possibilities, multiplier justification is unclear, abatement cost assumptions incomplete, unclear, and inadequately justified.”

“Economic Impact of Pending Air Regulations on the US Pulp and Paper Industry,” addressing EPA’s air toxics standards for industrial boilers, by Fisher International

Evaluator -Charles D. Kolstad, PhD, Professor and Chair, Department of Economics,
University of California at Santa Barbara

Letter Grade -- F

“If I were grading this, I would give it an F. The economics is all wrong (lack of an incidence analysis or acknowledgement of its importance; failure to draw on the relevant literature), which of course would be my main concern.”

“But the paper has some redeeming features -- the English grammar is decent and typically better than I see on a poor paper. Furthermore, I would want to encourage the student to work harder on the next assignment.”

For more on the EPA click here.

EPA Lays Out Five-Year Plan on Agency Priorities

From the EPA -- (or ADA -- American Destruction Agency)

The U.S. Environmental Protection Agency (EPA) has issued its fiscal year (FY) 2011 to 2015 strategic plan, which provides a blueprint for advancing EPA’s mission and Administrator Lisa P. Jackson’s priorities.

This plan presents five strategic goals for advancing the agency’s environmental and human-health mission, accompanied by five cross-cutting fundamental strategies that seek to adapt the EPA’s work inside and outside of the agency to meet the growing environmental protection needs of the day. The plan will guide the agency to foster a renewed commitment to new possibilities for achieving the vision of a cleaner, greener, and more sustainable environment.

The five-year plan includes new benchmarks that track progress against Administrator Jackson’s seven priorities such as taking action to reduce emissions of greenhouse gases and adapt to climate change, protecting America’s waters, increasing the use of smart growth and sustainable development strategies in communities, building and maintaining strong state and tribal partnerships, working for environmental justice, and ensuring that chemical health and safety information is available to the public.

The five strategic goals for advancing the agency’s environmental and human-health mission are:

• Taking action on climate change and improving air quality
• Protecting America’s waters
• Cleaning up communities and advancing sustainable development
• Ensuring the safety of chemicals and preventing pollution
• Enforcing environmental laws

The Administrator has committed the agency to pursuing these priorities in the years ahead to fulfill EPA’s mission to protect human health and the environment. In addressing these priorities, EPA will continue to affirm the core values of science, transparency and the rule of law. The agency sent notification letters to more than 800 organizations and individuals requesting comment on the draft plan.

Congress requires all federal agencies to develop a strategic plan covering a five year period, which is updated every three years. EPA developed the FY 2011-2015 strategic plan after receiving extensive comments from stakeholders and the public. The plan is prepared in accordance with the Government Performance and Results Act of 1993.

More information on the strategic plan: http://www.epa.gov/ocfo/plan/plan.htm  

Dust Bunnies Be Warned -- the EPA is coming after you!

Again acting as the Secret Police for the Administration' agenda, the out-of-control goose-stepper's at the EPA (or ADA -- American Destruction Agency) are launching another attack through nanny state regulation.  This time the target is the farmers & ranchers....

Today, U.S. Representative Cynthia Lummis (R-Wyo.), along with the support of 74 bipartisan colleagues, sent a letter urging Environmental Protection Agency (EPA) Administrator Lisa Jackson to refrain from imposing burdensome farm dust regulations on America’s farmers and ranchers. Lummis released the following statement regarding the EPA’s review:

“The Obama EPA’s unprecedented attempts to regulate dust on farms and ranches is just another example of how out-of-touch this administration is. Clear evidence acknowledges that the dust standard revision is unnecessary. Yet despite results from scientific studies, the EPA is continuing its attempts to control the day-to-day operations on ranches and farms.

“This unreasonable requirement will cause extreme hardship to farmers, livestock producers and other resource-based industries throughout rural America. People in the West and those in dry climates will be hit especially hard. It’s time the EPA rethink the consequences the farm dust regulation will have on the people who feed us.”

 Background:

The Environmental Protection Agency (EPA) is reviewing the National Ambient Air Quality Standards (NAAQS) for particulate matter (PM). The review is required every five years under the Clean Air Act. The Second Draft Policy Assessment (PA) for PM released on July 8, 2010 in the Federal Register lays the foundation for establishing the most stringent and unparalleled regulation of dust in our nation’s history. Presently, scientific studies do not support the need for revising the dust standard. In fact, according to the PA, the science would justify leaving it as is. Yet, the Obama administration is signaling its intent to proceed with the new standard.

EPA Now Targeting Dental Offices

Patriots, as we can see the EPA is again goose-stepping even more into our every day lives with arbitrary edicts. 

From the EPA --

Release date: 09/27/2010

Contact Information: Jalil Isa, isa.jalil@epa.gov, 202-564-3226, 202-564-4355

WASHINGTON – The U.S. Environmental Protection Agency (EPA) today announced it intends to propose a rule to reduce mercury waste from dental offices. Dental amalgams, or fillings containing mercury, account for 3.7 tons of mercury discharged from dental offices each year. The mercury waste results when old mercury fillings are replaced with new ones. The mercury in dental fillings is flushed into chair-side drains and enters the wastewater systems, making its way into the environment through discharges to rivers and lakes, incineration or land application of sewage sludge. Mercury released through amalgam discharges can be easily managed and prevented.

EPA expects to propose a rule next year and finalize it in 2012. Dental offices will be able to use existing technology to meet the proposed requirements. Amalgam separators can separate out 95 percent of the mercury normally discharged to the local waste treatment plant. The separator captures the mercury, which is then recycled and reused.

Until the rule is final, EPA encourages dental offices to voluntarily install amalgam separators. Twelve states and several municipalities already require the installation of amalgam separators in dental offices.

Approximately 50 percent of mercury entering local waste treatment plants comes from dental amalgam waste. Once deposited, certain microorganisms can change elemental mercury into methylmercury, a highly toxic form that builds up in fish, shellfish and animals that eat fish.

Fish and shellfish are the main sources of methylmercury exposure to humans. Methylmercury can damage children’s developing brains and nervous systems even before they are born.

More information on mercury from dental offices: water.epa.gov/scitech/wastetech/guide/dental/index.cfm.  More information on mercury and the environment: www.epa.gov/mercury/index.html.  

Congressman Hal Rogers (KY-05) Introduces Bill to Stop the EPA’s War on Coal

Standing up to the EPA's continued attacks on the coal industry through regulation & the purposeful bureaucratic delay of issuing permits, Congressman Hal Rogers (KY-05) has introduced HR 6113, The Electric Reliability Protection Act.....

Washington, DC, Sep 15 - Today, U.S. Congressman Hal Rogers (KY-05) spoke at the FACES of Coal rally on Capitol Hill and energized hundreds of coal miners who traveled from all over Appalachia to make sure their voices were heard. Rogers spoke out against the EPA’s war on coal and introduced legislation, H.R. 6113, the Electric Reliability Protection Act, which would stop the EPA and Administration’s attempt to regulate coal mining out of business.

“At a time when our nation faces 9.6% unemployment, bureaucrats in Washington are trying to put an entire sector of our economy out of business,” said Rogers. “From the devastating Cap and Trade bill, to the EPA’s absurd directives on carbon dioxide, to continued delays in the coal mining permitting process, the Administration is threatening 1 out of every 4 Appalachian coal mining jobs. Because of these political games, 2 billion tons of coal are going untapped – that is enough to power the nation for two years.

In effect, this bill would stop the Czar like tactics of EPA Director Lisa Jackson and would force the EPA to allow the public a chance to voice our opinion on the heavy-handed regulatory tactics being implemented to destroy not only the coal industry -- but small business which are being stealthily attacked under the guise of the Integrated Urban Air Toxics Strategy.

Helping to enable these guerrilla-like tactics by the EPA are Congressman Dennis Kucinich, Congresswoman Betty Sutton (OH -13) & Congressman John Boccieri (OH-16) -- all supporters of the House Cap & Trade bill. With Ohio bleeding jobs and a predicted $8 billion bust in our state budget (thanks to Governor Strickland) one would think these three Pelosi puppets would do everything in their power to do what is best for OH. But we see that is not the case and it appears they would rather see our state unemployment rate and your electric rates go higher than the national debt!

Please contact these N/E Ohio Congresscritters, urge them to sign on in support of the Electric Reliability Protection Act and if they don't.... remind them November is coming!

Contact info;

Congressman Dennis Kucinich (OH-10)
(Click here for email)

Lakewood Office
14400 Detroit Avenue
Lakewood, Ohio 44107
Phone (216)228-8850 / Fax (216)228-6465

Parma Office
Parmatown Mall
7904 Day Drive
Parma, Ohio 44129
Phone (440)845-2707 / Fax (440)845-2743

Washington Office
2445 Rayburn HOB
Washington, DC 20515
Phone (202)225-5871 / Fax (202)225-5745

Congresswoman Betty Sutton (OH-13)
(Click here to email)

Summit County Office
39 E Market Street, LL #1
Akron, OH 44308
Phone: (330) 865-8450 / Fax: (330) 865-8470

Lorain County Office
St. Joseph's Community Center
205 West 20th Street, Room M230
Lorain, OH 44052
Phone: (440) 245-5350 / Fax: (440) 245-5355

Washington D.C. Office
1721 Longworth HOB
Washington, DC 20515
Phone: (202) 225-3401 / Fax: (202) 225-2266

Congressman John Boccieri (OH-16)
(Click here for email)

District Office
300 W Tuscarawas St.
Suite 716
Canton, OH 44702
Ph: (330) 489-4414 / Fax: (330) 489-4448

Washington D.C. Office
1516 Longworth HOB
Washington, D.C. 20515
Ph: (202) 225-3876 / Fax: (202) 225-3059
District Toll Free Help Number: 1-800-826-9015

EPA cranks up attacks on Small Business & Manufacturers

While we wait for Harry Reid to try and ram through a watered down version of a Cap & Trade bill through the Senate, the EPA is bypassing legislation & quitely imposing their will through regulation of the Clean Air Act.

With the failure to pass the Murkowski Resolution, the EPA, using the Clean Air Act & the Integrated Urban Air Toxic Strategy as their hammer, a stealth form of Cap & Trade is currently being imposed & expanded from attacks on the coal industry to the manufacturing sector and small businesses.

From National Assoc. of Manufacturers --

The National Association of Manufacturers (NAM) Vice President of Energy and Resources Policy Keith McCoy issued the following statement today regarding the Environmental Protection Agency’s (EPA) continued push to impose costly and unattainable regulations on industry:

“EPA’s drive to put costly new burdens on manufacturers continues to create uncertainty and harm manufacturers’ ability to compete in a global economy. Two of the EPA’s more recent regulatory actions include proposing lowering ozone limits and putting stricter emission standards on industrial boilers. According to two new studies, the EPA’s current path and proposals will add costly new burdens to manufacturers and destroy millions of jobs.

Today the Manufacturers Alliance/MAPI released a study showing the EPA’s proposed ozone standards would cost 7.3 million jobs by 2020 and add $1 trillion in new regulatory costs per year between 2020 and 2030. And, while the EPA has publicly acknowledged that its own research shows there is no basis for proposing changing the ozone standards, the Agency continues to move ahead.

In addition, the Council of Industrial Boiler Owners (CIBO) today released a study that shows the EPA’s proposed rules to restrict emission limits on industrial and commercial boilers and process heaters could put 300,000 jobs at risk. The CIBO study also concludes that every $1 billion spent on compliance would jeopardize 16,000 jobs.

Our nation’s unemployment rate is 9.6 percent. We need more jobs, but the EPA is moving forward with regulations that will crush economic growth and manufacturers’ ability to hire. The NAM and the 18 million people who make up the manufacturing economy will continue to urge the EPA not to move forward with these job-killing proposals.”

Court settlement calls for EPA to set emission standards for 28 industries

Here is another example of how the administration is using regulation over legislation as a means of forcefully enacting Cap & Trade.

Combined with another little know provision in the Clean Air Act -- the Integrated Urban Air Toxics Strategy -- in which small "Mom & Pop" businesses will also become a target of the EPA, the below "consent decree" will allow the ever growing power of the EPA to enact even more restrictions on private industries through regulation....

From Earth Justice -- (emphasis added)

The U.S. Environmental Protection Agency has now agreed to review and make all necessary updates to hazardous air pollution rules covering 28 types of industrial facilities, including pesticide production operations, lead smelters, aerospace facilities and pharmaceutical plants, among others. The proposed consent decree lodged today in federal court is the result of a Jan. 2009 lawsuit filed by Earthjustice on behalf of Sierra Club, which sought to end years of delay by the Bush administration in updating air pollution rules for industries that pollute neighborhoods with toxic emissions.

"For too many years, Americans have waited for the EPA to update and strengthen these standards. Now EPA Administrator Lisa Jackson is committing to act on a long list of air toxics standards to protect people from serious health problems caused by air pollution," said Jane Williams, Chair of the Sierra Club National Air Toxics Taskforce. "We applaud her decision to take action so that people exposed every day to toxic industrial pollution will finally have the chance to receive the basic health protections promised by the Clean Air Act."

The industries affected by this settlement emit hazardous air pollutants which are associated with cancer, birth defects, anemia, lung and respiratory harm, damage to the nervous system, and other health disorders as well as environmental damage like contamination of the natural food chain.

There will be a public comment period and final agency review for the proposed agreement before the EPA and Sierra Club submit the final agreement to the Court for approval later this year. The EPA will be scheduled to take the first action under the agreement by mid-September 2010, and additional rulemakings on toxic air pollution standards for various industries will follow regularly over the next few years.

The EPA is required by the Clean Air Act to set industry air pollution standards that are up-to-date. The EPA must ensure that the standards reflect newly available technology and provide ample protection for human health and the environment. The EPA missed the mandatory 8-year review deadline to evaluate the "residual risk," that is, the remaining risk to public health and to the environment that is not addressed by emission standards on the books created years ago. As a result, numerous standards may be too weak or too technologically outdated to provide the public protections that are legally required under the Clean Air Act.

Details of the proposed decree:

• The U.S. EPA will review and, as necessary, revise the national emission standards for hazardous air pollution to control toxic air emissions for 28 industrial sources, hold a public rulemaking and issue a final determination as required by law.

• The agency also will hold a rulemaking to set "residual risk" safety standards if required to protect public health and the environment.

• The U.S. EPA will begin taking action this September and will complete all rulemakings in the next few years.

• For each of the 28 industrial categories covered by the agreement, the public will have the ability to review the EPA's proposed rule or determination and offer comments to ensure that the agency hears fully from local communities.

• The U.S. Environmental Protection Agency will soon publish a notice in the Federal Register and accept public comments regarding the proposed consent decree.

To review the decree visit: http://www.earthjustice.org/library/legal_docs/sierra-club-112-final-cdpdf.pdf

Contact:
Jane Williams, Sierra Club, (661) 256-2101
Emma Cheuse, Earthjustice, (202) 667-4500, ext. 220
Jim Pew, Earthjustice, (202) 667-4500, ext. 214
Raviya Ismail, Earthjustice, (202) 667-4500, ext. 221

EPA will use Clean Air Act to Attack Small Business

Applauding the defeat of the Murkowski Resolution, EPA Administrator Lisa P. Jackson released a statement consistent with the White House's "just lie" policy....

The Murkowski resolution also undermines EPA's common sense strategy for cutting greenhouse gases. Our carefully constructed approach exempts small businesses, homes, farms, and other small sources from regulation. We know that the local coffee shop or the backyard grill is no place to look for meaningful CO2 reductions. We're tackling our largest polluters and calling on Congress to pass a comprehensive energy and climate law -- one that would extend the protection of small businesses. (Read complete statement here.)

Targeting the largest polluters? Really?

With the failure to pass the Murkowski Resolution, through the EPA & an over reaching use of the Clean Air Act, Cap & Trade has been effectively enacted through regulation over legislation. Besides killing the coal industry & causing utility prices to skyrocket, the EPA will be targeting small business' Jackson claims to be exempting from these draconian measures.

A little know provision of the Clean Air Act -- the Integrated Urban Air Toxics Strategy -- small businesses will also become a target of the Green Energy Goon's at the EPA & the administration's quest for control....

From NYT -- (emphasis added)

The Environmental Protection Agency is 10 years behind schedule in setting guidelines for a host of toxic air pollutants, according to a report from the agency’s inspector general.

The report, which was released last week, found that the agency had failed to develop emissions standards, due in 2000, for some sources of hazardous air pollutants. These included smaller sites often located in urban areas, like dry cleaners and gas stations, but also some chemical manufacturers.

The inspector general also found that the agency had not met targets outlined in a 1999 planning document, the Integrated Urban Air Toxics Strategy, including tracking urban dwellers’ risk of developing health problems from exposure to pollutants.

For example, the agency’s last assessment of the risk of toxic air pollutants is based on emissions data from 2002. That analysis found that 1 in 28,000 people, or 36 in 1 million, could develop cancer from lifetime exposure to air toxics from outdoor sources. That number is an average, however, and people living in densely populated cities may face a higher risk.

Jeffrey Holmstead, who was assistant administrator for air and radiation at the E.P.A. from 2001 to 2005, said that even though Congress increased the agency’s budget when it passed significant amendments to the Clean Air Act in 1990, the E.P.A. still did not have enough money to fulfill all its requirements.

Some evidence suggests that there is now more attention being paid to this category of air pollutants within the E.P.A. The agency noted in its response to the report that for the first time in a decade, funds are shifting to the air toxics program this year to meet regulatory deadlines.

EPA Seeks Public Comment on Strategic Plan for 2011-2015

Patriots,

The EPA is taking public comments and suggestions on the draft of their Strategic Plan for FY 2011-2015. The EPA Draft Plan includes "strategic measures, the specific measurable environmental and human health outcomes the Agency will achieve over the next five years."

The EPA Draft Plan "introduces five cross-cutting fundamental strategies which set explicit expectations for changing the way EPA does business in achieving its mission results.

The five "cross-cutting fundemental strategies" include;

• Taking action on climate change and improving air quality
• Protecting America’s waters
• Cleaning up our communities
• Ensuring the safety of chemicals and preventing pollution
• Enforcing environmental laws

Due to recent actions by the current Administration and their use of govt. agencies to enact regulations as a way of circumventing legislation & the legislative process we urge everyone to submit their comments on the draft plan (details & links below).

From the EPA --

Release date: 06/18/2010

Contact Information: Enesta Jones, jones.enesta@epa.gov, 202-564-7873, 202-564-4355;

Contacto en español: Lina Younes, younes.lina@epa.gov, 202-564-9924, 202-564-4355

WASHINGTON - The U.S. Environmental Protection Agency (EPA) is seeking public comment on its draft FY 2011-2015 strategic plan, which helps advance Administrator Lisa P. Jackson’s priorities and the mission to protect human health and the environment. Administrator Jackson’s seven priorities are; taking action on climate change, improving air quality, protecting America’s waters, cleaning up our communities, assuring the safety of chemicals, expanding the conversation on environmentalism and working for environmental justice, and building strong state and tribal partnerships.

The draft plan identifies the measurable environmental and human health benefits the public can expect over the next five years and describes how EPA intends to achieve those results. The draft plan proposes five strategic goals and five cross-cutting fundamental strategies that aim to foster a renewed commitment to accountability, transparency and inclusion. The plan is prepared in accordance with the Government Performance and Results Act of 1993.

The public comment period begins June 18 and closes July 30. EPA will use stakeholder feedback to prepare the final strategic plan, which will be released by September 30. Comments on the draft strategic plan may be submitted through http://www.regulations.gov. The Docket ID number is EPA-HQ-OA-2010-0486.

For the first time, EPA is using a discussion forum to solicit ideas and feedback on the cross-cutting fundamental strategies, a new element of EPA’s strategic plan. The agency will use the feedback provided through https://blog.epa.gov/strategicplan as it implements the cross-cutting fundamental strategies and takes actions to change the way EPA does its work.

Information about the draft plan: http://www.epa.gov/ocfo/plan/plan.htm

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