CATF Group CAIR Comments-- Corrected Appendices

The document consists of several appendices. Appendix A lists Class I areas not evaluated by the EPA. Appendix B compares SO2 and NOx reductions under CAIR versus the Best Available Retrofit Technology (BART) standard. Appendix C is a detailed scientific critique of the ARIES study, arguing that utility industry claims using ARIES to downplay the health risks of sulfates are not supported by the study's actual data or broader medical literature. Appendix D lists counties remaining in nonattainment for PM2.5 and ozone. Appendix E contains a statement from the Institute of Clean Air Companies on the achievability of NOx and SO2 limits. Appendices F through L provide detailed modeling data, cost summaries, and emission projections for various policy scenarios (CATF11, 18, 19, 21, 22, 23).

• The utility industry's interpretation of the ARIES study—claiming that sulfates from power plants do not cause significant health problems—is not supported by the study's scientific results or the broader body of medical literature.
• The ARIES mortality studies in Atlanta lacked sufficient statistical power to detect significant pollutant associations due to a limited study period (at most 25 months) and modest population size.
• A substantial body of evidence indicates that sulfate-containing particles from fossil fuel combustion are among the most toxic particles and are significantly associated with cardio-pulmonary and lung cancer mortality.
• The ARIES monitoring site in Atlanta was located next to an inner-city highway, which likely caused traffic pollution to obscure the signal from power plants and potentially underestimated aerosol acidity due to neutralizing ammonia emissions from vehicles.
• Comparing CAIR and BART for SO2 in the CAIR region, the implementation of both would result in 2015 emissions of 3.3 million tons, providing an additional reduction of 1.5 million tons compared to CAIR alone.
• For NOx, the additional implementation of BART (at a rate of 0.20 lbs per MMBTU) would result in a reduction of 0.1 million tons compared to CAIR only; a stricter rate of 0.15 lbs per MMBTU would yield a 0.15 million ton reduction.
• The Institute of Clean Air Companies asserts that the proposed NOx emission rate limit of 0.2 lb/mmBtu is easily achievable with current combustion or post-combustion controls.
• The document identifies 18 Class I areas, such as Boundary Waters Canoe Area and Everglades NP, that were not evaluated by the EPA in its "Better than BART" analysis for the proposed CAIR.
• Under the "Straw Scenario" (EPA August 2001 proposal), it is estimated that 11,100 lives would be saved in 2010 compared to the EPA Reference Case, with net benefits of $71.8 billion by 2019.

APA

Clean Air Task Force (2004). CATF Group CAIR Comments-- Corrected Appendices. https://cdn.catf.us/wp-content/uploads/2019/11/21093137/CATF_CAIR_Comments-Appendices.pdf

Chicago

Clean Air Task Force. CATF Group CAIR Comments-- Corrected Appendices. 2004. https://cdn.catf.us/wp-content/uploads/2019/11/21093137/CATF_CAIR_Comments-Appendices.pdf.

Wikipedia

{{cite press release |author=Clean Air Task Force |title=CATF Group CAIR Comments-- Corrected Appendices |date=21 July 2004 |url=https://cdn.catf.us/wp-content/uploads/2019/11/21093137/CATF_CAIR_Comments-Appendices.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{cleanairtaskforce2004catf, author = {{Clean Air Task Force}}, title = {{CATF Group CAIR Comments-- Corrected Appendices}}, publisher = {Clean Air Task Force}, year = {2004}, month = jul, url = {https://cdn.catf.us/wp-content/uploads/2019/11/21093137/CATF_CAIR_Comments-Appendices.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }