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  • Drawing the Fires

    Posted by David Foster on August 25th, 2010 (All posts by )

    The EPA has drafted a new set of regulations for emissions from industrial boilers, via imposition of “Maximum Achievable Control Technology.” The National Association of Manufacturers has raised serious concerns about the advisability of imposing these regulations, particularly at this point in time: a very detailed analysis is here

    Industrial boiler regulation may sound like a pretty esoteric topic, but actually I think it is an important one, both in terms of tangible impact on the economy and in terms of what it symbolizes about the way we are heading as a society.


    As the NAM paper points out, industrial boilers and process heaters are vital to a wide variety of industries, including the chemical, auto manufacturing, metalworking, petroleum refining, steel, cement, and forest and paper sectors. All of these industries would be subject to stringent new regulations, about which NAM says that EPA has proposed MACT standards for industrial boilers and process heaters that are based on individual pollutant-by-pollutant – rather than source-by-source – analyses in patent violation of the Clean Air Act. EPA has set limits for the suite of HAPs that reflect the “best performing source” for each individual HAP. Put differently, EPA has “cherry picked” the best data in setting each HAP standard, without regard for the sources from which the data come. This results in a combined set of standards for purely hypothetical boilers that may never have actually been achieved by any single, real world source.

    I have only skimmed the NAM paper, but it certainly appears that the EPA proposal shows signs of a highly-theoretical approach, and one that does not recognize the reality that life is largely about tradeoffs. Yes, reducing mercury pollution is a very good thing. But so is having a manufacturing industry in the United States. It’s no secret that we are now facing a dismal economic climate and that many people are suffering severely–see this horrifying animated unemployment map, for example–but too many Obama administration officials act as if this situation is irrelevant to them. Indeed, Obama’s preferred style of regulators do not seem to care who they hurt in their headlong rush toward their vision of a green utopia.

    These proposed boiler emissions standards need a lot more public attention, analysis, and discussion than they’ve gotten. How much would these regulations increase the cost of various manufactured products? How many manufacturers would move offshore, or never start operations in the U.S. in the first place? This post is intended as a contribution in the direction of encouraging such discussion. Above and beyond the issues of individual regulatory proposals, however, it’s impossible not to sense a generalized hostility toward industry on the part of Obama and his crew–however much they may talk about the need for “good manufacturing jobs.”

    For thousands of years, fire has been a symbol of civilization. Has our society simply become too effete to continue activities which center around the use of fire, whether as coal or gas fires for factory or powerplant boilers, or blast furnaces, or forge and foundry operations?

    Hephaestus, god of the forge, will not stay where he is not wanted, but will depart for more welcoming lands.

     

    18 Responses to “Drawing the Fires”

    1. Mike H Says:

      The SCAQMD goes national baby!

    2. Robert Schwartz Says:

      ‘Hephaestus, god of the forge, will not stay where he is not wanted, but will depart for more welcoming lands.”

      He is long gone. Headed over the Pacific.

      We will not be able to revive the economy until the last environmentalist is strangled with the entrails of the last lawyer.

    3. Michael Kennedy Says:

      We are dealing with an administration that lives in a world where law professors designs automobiles. I am a long way from being a Talmudic scholar but it strikes me that this is the approach. One of my favorite authors of fiction is Neville Shute who was an engineer and who knew how things worked. There is an increasing number of articles about people who don’t know the basics about how things work. They see no problem with plucking a number from a system and applying it to another unrelated system. I’m not sure they even understand mathematics.

    4. Trent Telenko Says:

      “Irrational regimes behave more so under pressure.”

      This will get worse after Democrats get defeated in November 2010, rather than better.

    5. Trent Telenko Says:

      Obama Administration Exhibit 47B of “Irrational regimes behave more so under pressure” –

      http://www.nssfblog.com/epa-considering-ban-on-traditional-ammunition-take-action-now/

      The EPA decision on this is timed for the day before the November 2010 election.

      This is the NRA’s best fund raising opportunity since 1994.

    6. Dan from Madison Says:

      We just dodged a huge bullet of this type that in HVAC. R-410a is now the standard refrigerant being installed in most residential and light commercial air conditioning applications. Before Jan 1 of this year it was R-22. Starting January 1 no manufacturer is allowed to manufacture R-22 bearing units (R-22 is also used in commercial refrigeration). In their final ruling the EPA stated that not just new air conditioners, but many replacement parts were not going to be able to be sold after January 1 so that the tens of millions of R-22 units out there could essentially never be serviced. Imagine your car needing an oil change and finding out that there is no oil, thus you need a new car – it is almost an exact analogy.

      Anyway, industry groups came together and with an extremely intense effort got that part written out of the final ruling, but it is another example of people who have no idea what they are doing writing laws that will in the end penalize everyone.

    7. David Foster Says:

      See also my related post powering down.

    8. tehag Says:

      “Obama administration officials act as if this situation is irrelevant to them”

      Of course it’s irrelevant to them. They admire Chavez, Castro, Mao, Lenin, et. al. Since when was the collapse of infrastructure, decay of cities, suffering of millions relevant to the creation of a socially just society, as in the past was enjoyed by the eastern Europeans and today is enjoyed in Cuba and Venezuela?

    9. David Foster Says:

      Tehag…I don’t think it’s useful to paint the opposition with such a broad brush. Not all of them are eager for widespread immiseration. Some are unrealistic, some are ignorant about the productive economy, some are overly dependent on biased media, many are just following along with what their friends are saying. Our objective should be to change minds and help save the country, and that requires segmentation and alliance-building.

    10. Petey Says:

      Wow. I never thought I’d see my profession on Chicago Boys. Industrial boilers, that is.

    11. John Says:

      “…the EPA proposal shows signs of a highly-theoretical approach, and one that does not recognize the reality that life is largely about tradeoffs. Yes, reducing mercury pollution is a very good thing. But so is having a manufacturing industry in the United States.”

      I may be mistaken, but I think the EPA has very little leeway in this regard. I think they have to do what the law says, not what they think fits the big picture.

      In which case, Congress is your target here. (The NAM seems to be simultaneously accusing EPA of following the law too closely in not taking economic impact into account and of not following it closely enough in how the standards are set.)

      Having said that, I personally think EPA opened up a huge can of worms when they tried to apply “absurd results” in another case recently. But, *that* was the mistake.

    12. David Foster Says:

      Petey…that’s the great thing about the blogosphere: discuss any subject, no matter how esoteric, and sooner or later somebody who actually *knows* something about it shows up.

      As opposed to the old media, where energy issues are regularly presented by writers who seem absolutely incapable of understanding the difference between a kilowatt and a kilowatt-hour.

    13. Petey Says:

      The reoccurring response in the comments seems to be “There is not a single gas-fired boiler or process heater that has been demonstrated in EPA’s record to meet all 5 of the numerical emission limits in this proposal at all times.” With “gas-fired boiler” and “process heater” being interchangeable with other units.

      We have some pretty wild designs that can drop CO2 and NOX emissions lower than even the emission standards in California, and boiler mfg’s constantly innovate to create competitive specifications to sell their products. I’m only through the the Chapter II and it’s already starting to sound like they consulted NASA on near-future air scrubbing technology.

    14. Mrs. Davis Says:

      All Regs should require Congressional approval by roll call vote.

    15. newrouter Says:

      Does the EPA serve a useful purpose to society anymore? If not why continue it’s existence.

    16. John Says:

      “We have some pretty wild designs that can drop CO2 and NOX emissions lower than even the emission standards in California, and boiler mfg’s constantly innovate to create competitive specifications to sell their products. I’m only through the the Chapter II and it’s already starting to sound like they consulted NASA on near-future air scrubbing technology.”

      Petey,

      Do you mean by this that the EPA sounds unreasonable, or that boiler technology is just moving ahead very rapidly?

    17. Dan from Madison Says:

      Newrouter – I think you have summed it up very nicely.

      “There is not a single gas-fired boiler or process heater that has been demonstrated in EPA’s record to meet all 5 of the numerical emission limits in this proposal at all times.” – I like this line. I am currently in a situation with a contractor who is halfway through a small air conditioning job for the State of Wisconsin who just found out that there is not a piece of equipment made in the world that meets the energy requirements laid out by the state.

    18. anna Says:

      I too have had my fair share of run-ins with the EPA/DEP and other regulatory krakens. I am in permitting hell on a current project right now and it keeps getting worse. I deal with getting environmental approvals on construction projects.

      The state DEP where I live is especially insensitive to real people, real projects, and real budgets. It thinks that because saving the environment is the highest aim of humans, then anything it does is justified. They furthermore have this idea that everyone is against them and that everyone hates them (ya think?) so they interpret any contact by an engineer as tantamount to a personal attack. To boot, they are rude on the phone and if they get back to you within a week of you calling, consider yourself lucky. If an engineer submits a plan that does not quite meet their byzantine rules, they automatically assume that this person personally eats endangered species and burns freon.

      The DEP has been itching to get some radical new anti-development laws passed but so far have not been successful (for reasons unknown to me, they usually get what they want). There has been this attitude of “Let’s get as much leftist crap through the legislature that we can while we still have the chance”. I wonder how many other bad laws are the result of this same attitude.