Tuesday, September 25, 2012

DIRTY BUGS!! Could an EPA energy plan mean more deadly diesel fumes?

This seemingly endless political season has been a rough one for folks at the U.S. EPA. 

Unfairly branded during presidential debates as a "job killer." http://www.newsmax.com/InsideCover/Bachmann-GOP-debate-EPA/2011/06/14/id/400010

Attacked for waging a "war on coal." http://www.thedickinsonpress.com/event/article/id/61570/group/News/  

Even accused, most tastelessly, of launching a "regulatory jihad." http://republicans.transportation.house.gov/News/PRArticle.aspx?NewsID=1325U

So it's only natural that the agency occasionally might seek to appease some of its critics -- to siphon off some political pressure.

And that's what seems to have happened in the curious case of DIRTY BUGS -- Back-Up Generators powered by diesel engines.  In this case, however, there are real concerns that EPA political concessions will mean dirtier air.

At first glance, this seems like a very, very technical story.  It has been covered well in some of the more specialized publications such as Greenwire and Bloomberg BNA, though little if any in mass-circulation outlets.

But the basic idea is actually fairly simple.  And the air quality stakes are so high that it deserves more than cursory attention.

In a nutshell: no one wants to see blackouts or brownouts. So regulators in charge of electric system reliability have tried to promote "demand response" -- encouraging energy users to avoid electricity use during periods of high demand.  In fact, demand-response companies are doing a brisk business because of related financial incentives.  Note, for example,

This is all well and good.  The basic concept seems to make a lot of sense. But what is replacing the traditional sources of power, and what are the implications?  This is where the DIRTY BUGS come in.

Hospitals, office buildings, and many companies historically have used these backup generators in emergencies to ensure reliable electricity in case of a temporary loss of power from the grid.  But now, something different is happening as the so-called demand-response market evolves.  BUG owners can actually run their engines during non-emergency periods and sell power to the grid, displacing cleaner power. (The incentives can be a real windfall: owners get paid whether the engines run or not.)

And the real problem is that the EPA is encouraging the use of DIRTY BUGS by proposing an outrageous loophoole that would permit deadly diesel engines to spew emissions for many hours a year without any emission controls.

How'd this happen?  EPA initially did set pollution standards for BUGS, but industry groups sued, and EPA proposed permitting the loophole are part of a legal settlement.  http://www.epa.gov/ttn/atw/rice/ricepg.html  And, yes, the bureaucracy has come up with a truly mind-numbing way of describing this dangerous proposal. (Rules for reciprocating internal combustion engines, or RICE. But this isn't about a gluten-free diet.)

A final rule is expected to go to the White House Office of Management and Budget in the coming weeks or months. Public health groups are very wary about the DIRTY BUG loophole.

As the American Lung Association put it in official comments to EPA:

The EPA’s proposed rule will encourage the use of backup generators, including uncontrolled generators, as routine suppliers of power to the electric grid, supplanting the use of cleaner sources of energy and creating a loophole for backup generators that will displace the deployment of cleaner, low-, and non-emitting resources.

The expanded non-emergency use of such generators will contribute emissions that will likely increase ozone and particulate matter levels and make it harder for communities to meet national air quality standards. Furthermore, such use of these generators threatens communities already disproportionately burdened by air pollution.


State environmental agencies, having suffered through the smoggiest summer in five years http://blogforcleanair.blogspot.com/2012/09/gasping-for-air-clean-air-watch-reports.html

and fearful of toxic diesel emission problems, are also alarmed and raising great questions. These, for example, by the Northeastern States for Coordinated Air Use Management:

The number of [diesel generators]that may take advantage of the proposed rule’s pollution control exemptions: unknown.

· The locations of these sources: unknown.

· The times at which these sources may operate: unknown.

· The public’s exposure to increased levels of diesel exhaust and fine particulate matter from these sources: unknown.

· The resulting public health harms from the increased exposure to diesel emissions: unknown.

· The resulting impact on communities that may bear a disproportionate share of the negative environmental consequences resulting from industrial, governmental and commercial operations or policies: unknown.

· The resulting impact on the ability of states to attain and maintain the ozone and other air quality health standards: unknown.

· The impacts on future resource mixes in the electricity markets from allowing
uncontrolled RICE into economic demand response programs: unknown.

Absent this information, NESCAUM is unable to evaluate the proposed rule’s prospective impacts. And NESCAUM respectfully submits that neither can EPA.


Other state experts are predicting pollution increases in the next few years if the DIRTY BUG loophole is permitted to stand.

This presentation, for example, by the Mid-Atlantic Regional Air Management Association notes that pollution from DIRTY BUG engines would trump ongoing cleanup efforts:


The concern is not just from states in the Northeast or Mid-Atlantic.  The state of Michigan, for example, has also raised a red flag. http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2008-0708-0954

There is probably a simple fix to this mess.  Make sure that if these engines are used, that they have effective pollution controls.  As a spokesman for the pollution control industry noted at an EPA hearing in July, emission controls are readily available:
Indeed, the payback period for cleaning up is only one to two years.
History shows that demand-response companies can still make a healthy buck even if the DIRTY BUGS get cleaned up. http://www.enernoc.com/press/press-releases/2007/235-press/press-releases/2007/673-enernoc-expands-clean-gen-demand-reduction-program-with-san-diego-gas-a-electric


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