Reducing mercury emissions - let’s do it right
The New Hampshire Legislature is considering a mercury reduction initiative that could increase electric rates substantially for PSNH customers. As written, Senate Bill 128 could add hundreds of millions of dollars to our energy production costs, and greatly diminish the fuel diversity and economical energy provided by our Merrimack Station in Bow. This plant produces about 50 percent of the energy provided to our customers from all of PSNH’s power plants. This is not an alarmist view, but a very real scenario provided in testimony to the Legislature. Unfortunately, SB 128 embraces a deeply flawed approach to reducing mercury, and would set in law targets and timelines that are unachievable. The state of New Hampshire estimates that about 650 pounds of mercury are emitted annually in the state from multiple sources. PSNH’s two coal-fired plants emit about 130 pounds annually, about 19 percent of the state’s total annual emissions. SB 128 focuses on PSNH power plants for reductions; for now, other sources, which collectively emit more than 80 percent of the state’s annual mercury emissions, are not addressed. In 2002, PSNH, the state, environmental groups and others made a commitment to reduce mercury emissions as part of the New Hampshire Clean Power Act. At that time, all parties agreed to let the U.S. Environmental Protection Agency take the lead in setting reduction targets and strategies, given that there were no federal standards yet regulating mercury emissions at power plants and that the science of reliably measuring and testing for mercury in power plant emissions was relatively new. The Clean Power Act also states that trading programs should be an integral part of any New Hampshire initiative to reduce mercury emissions. Trading essentially involves setting up a marketplace for buying and selling mercury credits - recognizing that mercury deposition in New Hampshire also comes from out-of-state sources. Trading programs have been successfully used to significantly and economically reduce other emissions, including nitrogen oxide (NOx), which is associated with ground level ozone, or smog. In March, the EPA issued new mercury regulations that would require PSNH to reduce its annual mercury emissions by more than 60 percent by 2018, from 130 pounds to 50 pounds. The EPA also proposes to set up a national “cap and trade” system on mercury emissions to help achieve the reduction targets cost-effectively. As written, SB 128 requires PSNH to reduce its annual mercury emissions to 50 pounds by 2009, and then to 24 pounds by 2013. Also, SB 128 does not allow participation in any trading programs, nor does it encourage the company’s participation in alternative mercury mitigation initiatives, such as school-based mercury cleanup programs or other community efforts for recycling household items containing mercury. We believe trading should be viewed as part of a solution — not the solution. If New Hampshire wants to set aggressive targets and timetables, it also needs to be willing to put all other reduction options in play. Without alternative mitigation and trading, the only option left to the company to meet the bill’s reduction targets is experimental technology which, in essence, is one of the major faults of SB 128. The fact is that there is no commercially available technology for coal-fired power plants that has been proven to achieve the level of mercury reduction required by SB 128. PSNH wants to implement worthwhile technologies; however, real questions exist as to whether any of these technologies alone can achieve the reductions called for in SB 128. PSNH is no different than any other business in demanding results. It is not reasonable to us, and certainly to our customers and regulators, to potentially invest hundreds of millions of dollars in hope that a selected technology might work. We look for and expect guarantees from our vendors that their equipment will perform and deliver results. We do not currently have such a guarantee to satisfy the requirements of SB 128. PSNH’s track record on environmental issues and creative problem solving speaks for itself. In the mid-1990s, we were the first utility in the country to install a new technology that dramatically reduced our NOx emissions. Using low-sulfur coals, we have reduced by 40 percent the sulfur dioxide emissions which contribute to acid rain. We have virtually eliminated the emissions of ash particles from our stacks through the placement of additional capture devices. We pride ourselves on working hard to be part of the solution, not part of the problem. This can only be realized if there is a willingness to work together - collaboratively - to find solutions that work for everyone. This is where SB 128 as written today fails. Gary A. Long is president and chief operating officer of Public Service of New Hampshire.