comment on all three of the posts on what you think is a weakness of the proposal and how it could be strengthened.
1)I think that a trade-able permit system would have the greatest success with decreasing mercury emissions of coal-fired power plants. The plan in place accounts for struggles in the 3 year transfer process from the Clean Air Act, and allows another year if the plant is struggling with technological advances. Municipal and Medical waste incinerators have decreased their mercury emissions both by at least 96%, while Nuclear power plants have decreased theirs by only 10. It is clear that the system in place does not incentivize decreased mercury emissions for Nuclear plants. This would stand to reason that the costs of abatement for Nuclear sites is much higher than other primary mercury emitters. It would help to be able to distribute abatement between the sites, since it seems that at least a few tried to decreases their emissions while the whole did not. I think the best way to allocate permits in this case would be to give permits to those who decreased their emissions during the Clean Air Act, those who didn’t have the highest probability of needing to purchase the permits. If the appropriate amount is allocated I believe this would be the best method to begin the circulation. Some difficulties that could come with this change are the need for increased technology, increased monitoring of emissions, and deciding a method for permit distribution. Many plants will need to do some R&D to be able to meet new standards, or to be able to decrease it enough to receive permits. In this permit system monitoring becomes much more important, accuracy is needed for the proper allocation of permits. If they do not circulate fluidly, then the system cannot work. This is the same reason that the allocation of permits is so important.
2.)Although I believe that all three of these current environmental issues could be reduced or fixed from introducing a trade-able permit system, I think the most beneficial issue to apply it to would be the emissions of mercury from power plants. Over the past few decades the emissions of mercury from power plants has not decreased by much compared to other forms, such as municipal and medical waste combustors. Power plant reduction has only increased by 10% while municipal and medical emissions has reduced by 96-98%. There are even standards in place today that are required for all plants to abide by that level the playing field when it comes to mercury emissions, “The Mercury and Air Toxics Standards.” This type of leveling for each plant is not necessarily the best method for reducing emissions, however. If some power plants are able to reduce emissions to an efficient level that is below the standard, it would be the most efficient for them to be able to ‘sell’ the rest of their emissions to a plant that must emit more mercury to sustain the area around it. This would incentivize lower cost plants to reduce below the standard and while larger plants have to pay for more emissions. This will make emissions from power more cost effective while keeping the efficiency of power to surrounding areas. Now to put this into effect, it most likely would not change the standard of emissions right away as most, if not all, plants are abiding by the MATS anyways. The plants that would receive permits would most likely be lower-emissions plants who would then be able to trade or sell them to higher emitting plants so that the higher emissions plants could emit more but supply more power. This would also incentivize those higher-emission plants to find alternatives and more efficient methods or technologies that would help in the reduction of emissions so they would not have to spend the extra charge that is to buy a permit. Probably the biggest challenge to overcome in implementing a system like this to the emissions of mercury from power plants is actually setting an efficient standard of emissions.
3)I think that focusing on the area of the mercury emissions from coal-fired power plants presents the greatest opportunity from shifting from a standard based regulation to a tradable permit system. I especially feel this way considering the fact that this area hasn’t done much to decrease their amount of emissions of mercury and the current pollution standard system being used doesn’t provide an incentive to decrease mercury emissions. In the article provided, titled “Mercury and Air Toxics Standards: Cleaner Power Plants”, it explains that power plants are currently the largest emitters of mercury in the United States with a total of 50%, the largest emitter of acid gases with a total of over 75% and then a total of 20 to 60% of emissions of other toxic metals in the United States. With that being said, the standard based regulation has not resulted in a large improvement, meaning a tradable permit system might be more beneficial to reducing the amount of emissions coming from these power plants. A brief description of how such a system might work in this case is distributing permits to those newer (and the significant percent of older) power plants who already control their emissions of mercury, acid cases, and other heavy metals. With this being the determinant factor of who is getting these permits and who is not within this new system, there would then be a new incentive created for a reduction in emissions by all power plants, rather than just the ones controlling their emissions currently. While yes, these newer power plants could very easily just purchase the new and advanced pollution control equipment, this new tradable permit system would be more cost-effective in the long run. If a plant is able to reduce their amount of emissions, they are then in a new position of being able to sell any additional permits of theirs to other plants that aren’t controlling their amount of emissions as well, potentially resulting in a new net benefit/gain. With that in mind, plants having a hard time with controlling their amount of emissions can buy more permits, which could potentially result in a loss – again, this being an incentive to reduce emissions to save money.
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