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The Clean Air Task Force (CATF) asserts that the EPA's proposed MACT regulations for utility units lack rigorous economic analysis and fail to protect children from mercury risks. By modeling an 'Alternate Mercury Control Scenario' using the EPA's own Integrated Planning Model (IPM), CATF demonstrates that more stringent mercury emission limits are cost-effective, providing substantial health benefits—specifically avoided premature deaths from PM2.5 exposure—that far outweigh the incremental costs to the power sector. The document further claims the EPA misled the public regarding its compliance with Executive Order 13045 concerning environmental health risks to children.

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  • The EPA failed to conduct a rigorous economic analysis of alternative MACT regulatory options as required by Executive Order 12866, neglecting to evaluate alternative approaches to the MACT floor or above-the-floor options for most Utility Units.

Cite the original document

APA
Clean Air Task Force (n.d.). Microsoft Word - Chapter V.FINAL.doc. https://cdn.catf.us/wp-content/uploads/2019/11/21093021/20040629-5.pdf
Chicago
Clean Air Task Force. Microsoft Word - Chapter V.FINAL.doc. n.d. https://cdn.catf.us/wp-content/uploads/2019/11/21093021/20040629-5.pdf.
Wikipedia
{{cite press release |author=Clean Air Task Force |title=Microsoft Word - Chapter V.FINAL.doc |url=https://cdn.catf.us/wp-content/uploads/2019/11/21093021/20040629-5.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
BibTeX
@misc{cleanairtaskforcendmicrosoft, author = {{Clean Air Task Force}}, title = {{Microsoft Word - Chapter V.FINAL.doc}}, publisher = {Clean Air Task Force}, url = {https://cdn.catf.us/wp-content/uploads/2019/11/21093021/20040629-5.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }

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