Common Sense Finally Coming to EPA with Cost-Benefit Analysis

By Daren Bakst
Washington Times
WASHINGTON, DC (June 10, 2019) – Shouldn’t Environmental Protection Agency regulations do more good than harm? The agency hasn’t always thought so.
In 2012, under President Barack Obama, the EPA finalized a rule to reduce emissions of mercury and other hazardous air pollutants from coal- and oil-fired power plants. In doing so, the agency decided that it didn’t need to consider the rule’s costs, estimated at $9.6 billion per year — roughly 2,000 times more than its annual benefits of only $4 million to $6 million.
Fortunately, the U.S. Supreme Court directed the agency to take costs into consideration based on specific Clean Air Act language applicable to that rule. If the EPA had its way though, costs wouldn’t have been considered.
That cavalier attitude is evident in other major air regulations, where the EPA didn’t bother to quantify whether there would be any benefits for reducing emissions of the regulated pollutant.
Now, however, there’s reason to hope that some common sense might finally be coming to the EPA.
In May, EPA Administrator Andrew Wheeler issued a memorandum directing the agency to “ensure that its regulatory decisions are rooted in sound, transparent and consistent approaches to evaluating benefits and costs.”
The full scope of what this process will entail isn’t clear. However, it appears that various offices within the EPA will be proposing rules to codify important principles of cost-benefit analysis into the agency’s work.
The memo explains that “the EPA should evaluate and consider both benefits and costs in decision-making.” The fact that such an obvious point has to be made is sadly instructive.
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New Study Finds Existing Coal-Fired Power Plants are Less Costly than New Electricity Sources

WASHINGTON, DC (June 3, 2019) – Today, America’s Power, in conjunction with the Institute for Energy Research (IER) released a study that analyzes and compares the levelized cost of electricity (LCOE) for new and existing sources of electricity. The levelized cost of electricity (LCOE) includes all of the costs (variable and fixed operating and maintenance expenses, capital investments and financing costs) of an electricity source over its lifetime and is a useful way to compare existing power plants to new facilities. The new analysis finds that, on average, the levelized cost of electricity from the coal fleet is less than the levelized cost of new natural gas combined cycle (NGCC), new wind and new solar.
America’s Power issued the following statement by Michelle Bloodworth, President and CEO:
“This new study is unique because it provides an apples-to-apples comparison of existing and new electricity sources,” said Bloodworth. “The study shows that policymakers should carefully consider levelized costs when decisions are being made to retire coal-fired power plants because replacing them with gas, wind or solar could be a bad economic decision.”
Tom Pyle, President of the Institute for Energy Research, also noted:
“This study illustrates why foolish policies like the Green New Deal and 100% renewable mandates would harm our economy and significantly raise the cost of electricity for American households. Shifting our electricity generation away from existing affordable and reliable plants to expensive and intermittent wind and solar would substantially increase energy costs for businesses and families. This study provides a necessary reality check for anyone making decisions about America’s electricity policy."

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Coal Stockpiles at U.S. Coal Power Plants at their Lowest Point in Over a Decade

By Chris Cassar and Owen Comstock
WASHINGTON, DC (May 17, 2019) – U.S. coal stockpiles decreased to 98.7 million tons in February 2019, their lowest value in more than a decade. Total U.S. coal stockpiles have fallen as more coal plants have retired.
Coal plants generally stockpile much more coal than they consume in a month. Coal consumed by power plants follows the seasonal pattern in overall electricity generation, meaning coal consumption is typically highest in summer and winter months. Because coal-fired power plants are consuming more coal in the warmest summer months and coldest winter months, coal stocks at power plants are often at their lowest in August and February.
In addition to surveying coal stockpile levels, EIA also calculates how long these stockpiles would last, assuming the power plants receive no additional coal. This value, known as days of burn, considers each plant’s current stockpile level and its estimated consumption rate in the coming months. In February 2019, U.S. coal power plants had, on average, about 90 days of burn.

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How the U.S. is Investing in Advanced Coal Technologies

By Sonal Patel
HOUSTON (June 6, 2019) – The U.S. is investing heavily to ensure its future coal-fired power fleet will be cleaner, more efficient, and more flexible, experts said at the 9th International Conference on Clean Coal Technologies in Houston on June 4.
The conference—which is taking place this week in the U.S. for the first time—is spearheaded by the IEA Clean Coal Centre (IEA CCC), an autonomous collaborative partnership organized under the International Energy Agency (IEA), and co-hosted by the U.S. Department of Energy (DOE). The U.S. Energy Association (USEA), which represents 150 members across the U.S. energy sector, is also backing the conference. As Andrew Minchener, general manager of the IEA CCC, noted, the conference and workshop are modes of “knowledge transfer and capacity building,” but the event also serves as a “clear and impartial dialogue on the relative merits on coal technologies.”
For the most part, discussions at the conference about the future of coal were framed by the drastic changes affecting the energy sector, including concerted decarbonization efforts bolstered by the Paris Agreement, that threaten to diminish coal’s share in global energy demand. According to the IEA’s World Energy Outlook 2018, if ambitions expressed by the world’s policymakers to boost energy efficiency, ramp up renewable resources, and slash air pollution are adopted, global coal demand, which constituted 27% of total energy demand in 2017, could decline to 22% by 2040.
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Michael Bloomberg Promises $500 Million to Help End Coal

By Lisa Friedman
New York Times
NEW YORK (June 6, 2019) – Michael R. Bloomberg, the former mayor of New York City, said on Friday he would donate $500 million to a new campaign to close every coal-fired power plant in the United States and halt the growth of natural gas.
The new campaign, called Beyond Carbon, is designed to help eliminate coal by focusing on state and local governments. The effort will bypass Washington, where Mr. Bloomberg has said national action appears unlikely because of a divided Congress and a president who denies the established science of climate change.
“We’re in a race against time with climate change, and yet there is virtually no hope of bold federal action on this issue for at least another two years,” Mr. Bloomberg said in a statement before the announcement, which he made in a commencement address at the Massachusetts Institute of Technology. “Mother Nature is not waiting on our political calendar, and neither can we.”
President Trump has made reviving what he has called “clean, beautiful coal” a cornerstone of his energy agenda.
A spokesman for Mr. Bloomberg said most of the money would be spent over the next three years, though the time frame could be extended. It will fund lobbying efforts by environmental groups — in state legislatures, City Councils and public utility commissions — that aim to close coal plants and replace them with wind, solar and other renewable power. Part of the cash also will go toward efforts to elect local lawmakers who prioritize clean energy.
The campaign will be based on the need to avoid the most dangerous effects of climate change, but will also emphasize the economic benefits of switching to clean energy.


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How Much Credit Can Beyond Coal Claim for Plant Closures?

By Benjamin Storrow
E&E News
NEW YORK (June 10, 2019) – In 2011, when the Sierra Club and then-New York City Mayor Michael Bloomberg launched the Beyond Coal campaign, coal accounted for 42% of America’s power generation. Today, that figure is closer to 25%.
Now, the pair is aiming to finish the job. On Friday, Bloomberg announced he will spend $500 million to retire America’s remaining coal plants by 2030, halt construction of new natural gas plants and elect climate champions to public office as part of a new Beyond Carbon initiative. A press release touted it as the largest philanthropic climate donation ever.
“Our goal is to move the U.S. toward a 100% clean energy economy as expeditiously as possible, and begin that process right now,” Bloomberg told graduates at the Massachusetts Institute of Technology, where he announced the initiative as part of a commencement address. “We intend to succeed not by sacrificing things we need, but by investing in things we want: more good jobs, cleaner air and water, cheaper power, more transportation options, and less congested roads.”
Beyond Coal, operated as an arm of the Sierra Club, is fond of touting the number of plants retired since 2011: Some 289 of the 530 units in operation at that time are now closed. The campaign can claim some credit for the trend, but how much is difficult to quantify.
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‘Contempt for Working Families’: Miners’ Union Blasts Mike Bloomberg’s Anti-Coal Push

By Michael Bastasch
Daily Caller
NEW YORK (June 10, 2019) – Former New York Mayor Michael Bloomberg’s renewed campaign to shut down every coal-fired power plant in the U.S. puts working “families on the economic chopping block,” says the top coal miners’ union official.
United Mine Workers of America (UMWA) International President Cecil Roberts said Bloomberg “demonstrated his contempt for the working families of Appalachia and other coal-dependent communities once again with his $500 million pledge to destroy every American job associated with coal by 2030.”
“Instead of taking a rational approach to addressing the issue of climate change, he has pledged to throw more than 800,000 people out of work and destroy their families and communities while he’s at it,” Roberts said in a statement issued Monday.
Bloomberg announced in June he would infuse another $500 million into climate change campaigns, including boosting the Sierra Club’s effort to close every U.S. coal plant by 2030 and prevent the expansion of natural gas.
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Department of Energy Invests $39 Million to Improve Existing Coal-Fired Fleet

U.S. Dept. of Energy
WASHINGTON, DC (June 10, 2019) – Today, the U.S. Department of Energy’s (DOE) Office of Fossil Energy (FE) has selected 17 projects to receive approximately $39 million in federal funding for cost-shared research and development under funding opportunity announcement Improving Efficiency, Reliability, and Flexibility of Existing Coal-Based Power Plants.
DOE selected these projects as part of its Transformative Power Generation Program and Crosscutting Research Program. The projects will develop, in the near term, advanced technologies that improve the overall performance, reliability, and flexibility of the Nation’s existing coal-fired power fleet. This research will support DOE’s goal to improve the average modeled efficiency (i.e., heat rate) of a typical plant in the existing fleet by 5 percent from the 2017 baseline of 31 percent by the end of Fiscal Year 2020.
“Coal-fired power plants represent the second-largest energy source for electricity generation in the United States,” said Assistant Secretary for Fossil Energy Steven Winberg. “The Trump Administration remains committed to ensuring a coal-fueled power plant fleet that provides stable energy to the power grid.”

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EPA Head Accuses Reporters, Green Group of ‘Colluding’ on Press Coverage

By Miranda Green
The Hill
WASHINGTON, DC (June 5, 2019) – Environmental Protection Agency (EPA) chief Andrew Wheeler is accusing two media outlets of “colluding” with a top environmental group following a tweet criticizing his earlier remarks.
Speaking to a panel of scientists and industry representatives Wednesday, Wheeler went off script to “caution” the experts to be wary of what they read in the media.
“I did a speech on Monday at the National Press Club. Things that I said — well, actually I didn’t even say it. A reporter for Yahoo News put out a tweet with a made-up quote attributed to me,” Wheeler told the audience.
Wheeler was referencing a tweet by Alexander Nazaryan, a national correspondent for Yahoo News, who was in attendance at the Monday meeting.
Wheeler’s speech earlier in the week chastised reporters for failing to report on the “positive” aspects of EPA’s environmental regulation achievements. The administrator made the comments before being pelted with questions about recent regulatory rollbacks done under President Trump having to do with methane, carbon and car emissions.
The Yahoo News reporter tweeted: “‘The media does a disservice to the American public’ by reporting on global warming, says EPA head Andrew Wheeler. Wants more positive coverage.”
The tweet was later retweeted and commented on by two New York Times employees as well as the Sierra Club. Wheeler and the EPA have said the tweet insinuates incorrectly that his comments were about climate change.
“The quote was then later retweeted by two reporters by The New York Times. That tweet was then used by a fundraising mechanism by the Sierra Club, which makes me wonder if those reporters were colluding with the Sierra Club for fundraising purposes,” Wheeler said.

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Pentagon Turns to Coal Ash to Escape Chinese Dominance of Rare Earth Elements

By Russ Read
Washington Examiner
WASHINGTON, DC (June 3, 2019) – Coal ash could be the next source of elements the U.S. defense industry uses in everything from night vision goggles to gyroscopes for smart bombs.
The Senate Committee on Armed Services included a provision in its recent markup of the 2020 defense budget authorizing an increase in funding for the Pentagon to develop capabilities to produce rare earth elements from coal ash, the remnants of burned coal, as China threatens to restrict supplies.
“[Y]ou need to make sure you have either [a] stockpile or access to them,” acting Deputy Secretary of Defense David Norquist told the Washington Examiner. “And so that’s an area where, as you look across the system, and you look at your future production, [you] question: Do I have those? Do I have enough of them? Do I have access to them? Where are they produced? And I think that’s a proper place for the Congress to have focused on.”
A 2016 Department of Commerce survey found 66% of respondents, most of them Department of Defense vendors, imported rare earths. Rare earths like neodymium and dysprosium may not be household names, but they are found in everything from cellphones to F-35 fighter jets — and China is the world’s premier supplier, producing 70% of the world's supply in 2018, according to the U.S. Geological Survey.
The country has threatened to throttle supplies of rare earths as it battles the Trump administration over trade policies.
“I think part of the reason we’re seeing them threaten it is that they don’t have a ton of other points of leverage the way the U.S. does,” said Zack Cooper, a research fellow specializing in U.S.-China competition at the American Enterprise Institute. “The U.S. has control of not just the financial system, in large part, but also almost everything that’s traded in the world is traded with dollars ... So they’ve got to find the places where they have an asymmetric edge, and this is one of the few, so I am not surprised that they are threatening to use it.”
Contrary to their name, rare earths are fairly common. But they are scattered across the earth’s surface in trace amounts that are extraordinarily difficult to separate from surrounding ores. This makes rare earth production not only costly, but extremely dirty. Extracting them involves a variety of processes harmful to the environment. Because there is little profit to be made in rare earths, the last U.S. mine closed in 2015.
China, home to about one-third of the world’s rare earth reserves, has cornered the market by subsidizing production and accepting environmental costs. Last year, it produced 120,000 metric tons of rare earths, compared to the 15,000 tons produced in the U.S.
China has already shown it is willing to use its rare earths advantage as a weapon. Beijing cut off rare earth exports to Japan during a dispute in 2010, scaring markets.
“It sent a shock wave through Japan because this was going to affect their supply chain for a number of things like computers and cellphones,” said Dean Cheng, a senior research fellow specializing in Chinese military capabilities at the Heritage Foundation. “But it was also the first time that the Chinese have actually done something that people had worried about, but never seen, which is would they ever use their economic power for political purposes.”
That embargo was lifted in 2015, but the message to countries reliant on rare earths was clear: China might not be a reliable source. This, experts say, is likely why the Congress has taken up the issue. It’s also why they are focusing on coal ash, which contains traces of rare earths, as the solution.
The U.S. produces nearly 80 million tons of coal ash per year from which rare earths could be derived, according to Rochester Institute of Technology researchers.
“[Rare earth elements] from coal ash is technically feasible, but [it’s] not clear how much it will cost compared to other options,” Eric Williams, one of the researchers, told the Washington Examiner.

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Transportable Moisture Limit (TML) for Coal

By Paul Reagan
Sampling Associates International, LLC

Editor's note: This article was written to provide information to coal exporters regarding shippers’ responsibilities and compliance with the new IMSBC Code regulations for Transportable Moisture Limit (TML) effective January 1, 2019. The article was reviewed for technical correctness by the Hazardous Materials Division of the United States Coast Guard, which is the “Competent Authority” for the United States and is responsible for interpreting and enforcing the IMSBC Code, including provisions related to the TML. This article first appeared in IHS Markit’s Coal & Energy Price Report and ran as a two-part series.
Paul Reagan is president of Sampling Associates International, LLC and can be contacted via phone at (757) 876-5217 or email at

The International Maritime Organization (IMO) publishes the International Maritime Solid Bulk Cargoes (IMSBC) Code which specifies the requirements for carriage of solid bulk cargoes other than grain on vessels to which the International Convention for the Safety of Life at Sea (SOLAS) is applicable. This article will address the rules and regulations governing the Transportable Moisture Limit (TML) for coal that became mandatory as of January 1, 2019.
Testing for the TML is driven by the safety requirements for identifying and preventing the conditions that might cause a solid bulk cargo to undergo liquefaction in the hold of a ship and create dangerous conditions due to loss of stability of the vessel.
Liquefaction of a solid bulk cargo can occur for a number of reasons – but in the case of coal it is primarily related to the interaction between the particle size of the cargo and its moisture content.
The IMSBC Code states “Cargoes that may liquefy means cargoes which contain a certain proportion of fine particles and a certain amount of moisture. They may liquefy if shipped with a moisture content in excess of their TML.”
It is important to note that the recent IMO decision to develop a specific test method for determining the TML of coal cargoes was intended to provide clarity on determining whether or not a given coal is both Group B and Group A. It has long been known that certain coals have the potential to liquefy, as seen by the Group B (and A) classification since the first edition of the IMSBC Code. The decision by the IMO to update many requirements for cargoes that can liquefy was driven by a concern for safety for all bulk carriers after some serious accidents involving other bulk cargos – most notably, nickel concentrates and iron ore fines. The truth is that there have been no known coal shipments from the United States that have liquefied in transit.
While the risk of liquefaction of most US coals is remote, it does not relieve US coal shippers of their responsibilities as outlined in the IMSBC Code. Recent developments in the Code for coal place certain responsibilities on the shipper with respect to declarations to the master of the vessel regarding the cargo to be loaded – as well as certain testing and supporting documentation for those declarations.

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