Rarely is an example of moral clarity so perfectly presented as is the EPA’s new mercury emissions rule. Following 20 years of study, the EPA finally has established controls over mercury emissions from coal-fired power plants. This new rule, the MATS rule for Mercury and Air Toxics Standards (aka the Hazardous Air Pollution Rule), is being discussed only in the periphery of the presidential campaign as part of the “War on Coal.” But the discussion to be found in newspapers, blog posts, and political circles is so void of any recognizable ethical framework that I struggle even to bring an ethical case to the issue.
The MATS rule has been in the planning stages since the 1990 Clean Air Act (CAA) Amendments, when President G.W.H. Bush gave EPA authority to regulate sources of mercury emissions. The EPA tackled two of the largest sources of emissions – municipal waste disposal and medical waste incineration – and brought total mercury emissions down by 45 percent. But coal-fired power plants, the largest remaining source, responsible for 50 percent of total mercury emissions, escaped regulation while the EPA conducted extensive studies.
But no longer. The EPA’s MATS rule will take effect in 2015, and will require emission controls on power plants that EPA estimates will reduce mercury emissions by 90 percent. The rule is not without costs: the estimates, which are all over the place, generally say that MATS will be the most expensive rule ever written for power plants.
Predictably, given the ethical state in which we find ourselves, costs have become the focus of the debate over MATS. According to EPA’s math, the benefits due to reductions in illness and death far exceed the rule’s costs. Industry is saying that the rule will force the retirement of 20 percent of our power plants, and will drive up electricity costs for consumers while decreasing the availability and reliability of remaining electricity generation. The costs, up to $10 billion a year, are not worth the benefits, detractors say:
“Governor Romney has made clear that he opposes the Utility MACT, which costs more than $1,500 for every one dollar reduction in mercury pollution,” Romney spokesperson Andrea Saul said in a statement.
Such is the state of our moral confusion: The entire debate about mercury – a known toxin (in the form of methylmercury) in the environment – is being fought on the balance sheet. Do the costs outweigh the benefits, and by benefits they mean the price tag they put on human health and lives. We never stop to consider whether our lifestyle, based on cheap electricity, is worth the destruction to our environment and the damage to our health.We never once ask whether we should be pumping mercury into the atmosphere, whether this is the behavior of an ethical society.
I want to go back to Mitt Romney for a moment. The man is not unethical; he has a moral compass. Consider the following response he gave in his first presidential debate:
Good. I’m glad you raised that, and it’s a — it’s a critical issue. I think it’s not just an economic issue, I think it’s a moral issue. I think it’s, frankly, not moral for my generation to keep spending massively more than we take in, knowing those burdens are going to be passed on to the next generation and they’re going to be paying the interest and the principal all their lives. And the amount of debt we’re adding, at a trillion a year, is simply not moral.
This was Romney’s response to a question about our federal debt, and it is a response I, as the father of two young children, wholeheartedly share. But under what ethical paradigm do we live in which we cringe at our moral failings to control the debt, but blithely skip past our moral obligations to control toxic pollutants? Is the dumping of debt onto our children any different than the dumping of toxins into the atmosphere and our nation’s lakes and streams? Should we not leave to our heirs a nation unfouled by both a crushing debt burden, and an environment laden with pollutants? I think it is far past time that we as a nation add environmental quality to the housing of our moral compass.