Microsoft Word - Chapter II.6.28.Final.doc

The Clean Air Task Force (CATF) contends that the EPA's proposed MACT standards for coal-fired utility units violate the Clean Air Act (CAA) by using arbitrary subcategories based on coal rank and flawed statistical methods to inflate emission floors. CATF argues that the EPA has ignored available, cost-effective technologies—such as activated carbon injection and fabric filters—that could achieve significantly higher mercury removal rates. The document further asserts that the EPA is legally obligated to regulate all HAPs emitted by these units, not just mercury and nickel, and that proposed compliance extensions are unauthorized and unnecessary given available labor and equipment resources.

• The EPA's proposal to subcategorize coal-fired utility units by coal rank is described as "unlawful, arbitrary, and capricious" because boilers are often designed to burn multiple coal types and the choice of combustion technology is not strongly driven by coal rank.
• CATF calculates that a proper MACT standard, by eliminating unlawful subcategories and variability analysis, would result in an existing source "floor" level mercury standard of 0.42 lb/TBtu, achieving a 92 percent reduction from current levels.
• The EPA's variability analysis is criticized for inflating emission rates by using the 97.5th percentile of emissions for each unit and then applying a 97.5 percent upper confidence limit of the mean, which CATF claims represents the "worst of the worst of the best."
• The document asserts that the EPA is legally required to establish emission standards for all hazardous air pollutants (HAPs) listed in section 112(b) of the CAA that are emitted by utility units, rather than limiting regulation to mercury and nickel.
• Activated carbon injection (ACI) combined with fabric filters is identified as a commercially available technology capable of achieving over 90 percent mercury removal for bituminous, subbituminous, and lignite coals.
• The EPA's request for a one-year global compliance extension is argued to be beyond its statutory authority, as section 112(i)(3) contemplates source-specific exceptions rather than blanket extensions for an entire category.
• Analysis of boilermaker labor supply suggests that there are sufficient resources to implement both the Interstate Air Quality Rule (IAQR) and more stringent MACT requirements by 2008, contradicting EPA's concerns about labor shortages.
• The document claims the EPA failed to meaningfully consult with its own Utility Working Group, ignoring recommendations that would have resulted in national mercury emissions between 2 and 28 tons, compared to the EPA's projected 34 tons.

APA

Clean Air Task Force (n.d.). Microsoft Word - Chapter II.6.28.Final.doc. https://cdn.catf.us/wp-content/uploads/2019/11/21093025/20040629-2.pdf

Chicago

Clean Air Task Force. Microsoft Word - Chapter II.6.28.Final.doc. n.d. https://cdn.catf.us/wp-content/uploads/2019/11/21093025/20040629-2.pdf.

Wikipedia

{{cite press release |author=Clean Air Task Force |title=Microsoft Word - Chapter II.6.28.Final.doc |url=https://cdn.catf.us/wp-content/uploads/2019/11/21093025/20040629-2.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{cleanairtaskforcendmicrosoft, author = {{Clean Air Task Force}}, title = {{Microsoft Word - Chapter II.6.28.Final.doc}}, publisher = {Clean Air Task Force}, url = {https://cdn.catf.us/wp-content/uploads/2019/11/21093025/20040629-2.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }