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NERA Testimony on 'The American Energy Initiative – A Focus on What EPA’s Utility MACT Rule Will Cost U.S. Consumers'

8 February 2012
By Dr. Anne E. Smith

On 8 February 2012, NERA Senior Vice President Dr. Anne E. Smith delivered testimony at a hearing on "The American Energy Initiative – A Focus on What EPA’s Utility MACT Rule Will Cost U.S. Consumers" before the US House of Representatives Energy and Commerce Committee's Subcommittee on Energy and Power. Dr. Smith was asked to share her perspective on the costs, economic impacts, and benefits of the Environmental Protection Agency's (EPA) Utility MACT Rule, which seeks to control risks from hazardous air pollutants (HAPs) emitted by coal- and oil-fired electricity generating units (EGUs). In her testimony, Dr. Smith explained how EPA is masking its lack of evidence of risks from EGU HAPs emissions with estimates of "co-benefits" from a non-HAP that EPA already is required to regulate to safe levels under separate provisions of the Clean Air Act. She also noted attributes of those co-benefits estimates that undercut their credibility. She then described NERA's estimates of certain costs and economic impacts of the MACT Rule that EPA has not provided in its own analyses.