On January 15, the Colorado Department of Public Health and Environment (CDPHE) submitted to the General Assembly a State Implementation Plan (SIP) to comply with the Regional Haze provision of the Clean Air Act. The General Assembly must approve the SIP before it can be sent to the Environmental Protection Agency (EPA) for final review. The CDPHE will seek a rubber stamp, but the General Assembly must reject the proposed SIP, because costs far exceed benefits.
Opposition to the Regional Haze SIP is merited by the CDPHE’s treatment of Hayden Units 1 and 2 in Northwest Colorado. The SIP calls for almost than $140 million in nitrogen oxides (NOx) controls known as Selective Catalytic Reduction (SCR). Here’s why this is a bad deal for Coloradans:
- Costs exceed benefits by a 40:1 ratio
Regional haze is an aesthetic regulation. That is, it has nothing to do with health, and is meant only to improve visibility at national parks. In 2006, EPA Region 8 made a “ballpark” estimate that the value to Colorado residents of reducing a ton of NOx in order to comply with Regional Haze is $95. The CDPHE is mandating pollution controls that cost $3,385/ton NOx reduced at Hayden 1, and $4,064/ton NOx reduced at Hayden
- Even the EPA concedes that SCR is not cost effective
In the Regional Haze guidance document, the EPA stated, “we have not determined that SCR is generally cost-effective.”
- Neighboring states determined that SCR is not cost-effective
In Utah, the Department of Environmental Quality deemed that SCR was too costly, and instead proposed low NOx burners in its Regional Haze SIP. This technology is 95% less expensive than SCR.
- Evidence Suggests the CDPHE grossly overestimated visibility benefits
During the CDPHE deliberations on the Regional Haze SIP, Joseph S Scire, an environmental consultant, testified that the CDPHE’s overly simplistic visibility model “significantly overestimated…the predicted visibility benefits associated with SCR controls.” Such an overestimation would mean that the CDPHE’s preferred pollution controls are even less cost-effective.
Alternative technologies that would comply with the Regional Haze requirements of the Clean Air Act would cost 6%-10% of SCR at the Hayden power plants. In these difficult economic times, Coloradans should not be required to pay more than $100 million for the CDPHE’s excessive environmentalism.
The CDPHE claims that the General Assembly risks a federal takeover of Colorado’s air quality program unless lawmakers rubber stamp the SIP. In fact, the EPA has never threatened such a takeover, and it hasn’t yet even created a Federal Implementation Plan with which it could supersede Colorado’s SIP. Such a process would take a year, at least. That’s why Utah doesn’t intend on submitting its SIP until April. As such, the General Assembly has months to carefully consider what’s in the best interests of Coloradans.
William Yeatman is an energy policy analyst at the Competitive Enterprise Institute