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.