Justifications II

In the early 1980s, the California Air Resources Board proposed some stringent rules on how much NOx (nitrogen oxides) could be emitted from power plants. The new regulations were meant to be “technology forcing,” which means that the control technology to meet the regs either had not yet been developed, or it had never been used on a large scale. Moreover, the required control factor was proportional to current emissions, rather than the usual method of allowing X amount of emissions per Y amount of power generated. So any utility that had controlled emissions beyond what had been previously mandated would actually be penalized by being required to clean up more than if they had only just barely met previous regs. Call it a penalty on being good.

CARB had been trying to set stringent NOx controls for years, believing NOx to be the real culprit behind smog. In fact, the relationship between NOx emissions and smog formation is _very_ complex, with fresh NOx emissions, which are mostly nitric oxide (NO) combining with ozone to form nitrogen dioxide (NO2), thereby reducing the level of the main smog constituent – temporarily. Also, NO2 is a radical scavenger, so it slows the smog oxidation process at elevated levels. On the other hand, without a minimal amount of NOx, the smog formation process basically stops, so if you eliminate all NOx emissions, you also stop smog formation. The question in NOx control is always whether or not you can reduce NOx to low enough levels to be effective.

In any case, the consulting firm I worked for was hired by Southern California Edison (SCE) to do an impact study on the proposed regulations, to see if they were properly “grounded in science.” I was selected to be the technical lead on the project.

The project manager wanted a quick result. We had plenty of simulations of various days in Los Angeles, where SCE had its power plant that would be affected, and he wanted a simple reduced-emissions scenario run for some of those days. I wanted to extend the simulations to multiple days.

Part of the reason I wanted this was because it had never been done before, and I wanted to extend the science. That was self-serving in the sense that it would certainly enhance my reputation (and the company’s), and also, I was curious about a number of things that simply couldn’t be examined with single day results, such as the importance of day-to-day carryover of pollutants. But it was also true that such a simulation would be in the best interest of the client, since providing an answer to those unanswered questions greatly reduces the amount of wiggle-room for policy makers.

Anyway, there were argument, loud ones, but eventually my position carried the day. With hindsight, I now suspect that the project manager in question developed a grudge against me, a grudge that explains some of his later behavior, but that’s another story.

In any case, having won the argument, it was then up to me to deliver, which I did. I had to write a different chemical kinetics module to do night time chemistry, one that used a lot of heuristic reasoning and various other tricks of the trade, but it did work, and I had smog chamber data to validate it against, so we were in the clear on that point. I also did some fairly significant work on what “clean air” looks like, that has been used (and misused) by a lot of other people since.

Our baseline simulation ran for over three days. What we found, essentially, was that the near-field ozone suppression effect of NOx emitted by the power plant was greater than the amount of ozone that was eventually attributable to that NOx in smog formation reactions. Moreover, the highest concentration difference in ozone attributable to the power plant was 1 part per billion, less than 1% of the smog standard, and on the baseline day, less than ½ of 1% of total peak ozone at the impacted area.

We presented our results at a CARB hearing, and the result was that they sent the proposed regulations back for reanalysis, pretty much the best possible result for our client. Eventually, more stringent NOx regulations did come into effect, but they were not technology forcing, and no doubt had other aspects that were less unpleasant to SCE, because that’s the way things work. That particular plant, incidentally, was retired a couple of years ago.

There are a lot of “anti-environmentalists” in the conservative movement, and in the fellow-traveling wing of the libertarians who decry all environmental regulations as being anti-business, or an infringement of their rights as individuals. There are also a lot of industry-funded think tanks tasked with muddying the scientific waters, denouncing things they don’t like as “junk science” and working against the proper use of science as a policy tool. I’ve lost count of the number of occasions where one of the other of these folks has sneered at me for being in favor of some “environmentalist” policy.

There are also some environmentalists who would condemn the preceding story as being another case of big business trampling the regulatory process, but I don’t buy it anymore than I buy the anti-environmentalist narrative. I believe our results, and our results said that this particular issue wasn’t worth the price. The amount of smog reduction, if there was any at all, was immeasurable. The actual population exposure to ozone quite possibly would have gone up. And in any case, the primary health effects from air pollution turn out to be from fine particulates, with ozone, even now, after another couple of decades of study, being still problematic from the standpoint of assigning it a specific level of toxicity at urban smog levels. The effects of ozone on plants is better established than its effects on human health.

And what would have been the price or the proposed regulations? Well, the CARB staff said that it would amount to a small amount of money per rate payer per month. Calculated out to the total number of rate payers, it came to $50 million per year. I don’t think that CARB staff had any incentive to overestimate the cost, incidentally. Typically it’s the other way around.

That was over 20 years ago. A cost of $50 million a year, ignoring all present value calculations, etc. comes to over a billion dollars. I always figured that we probably only bought SCE maybe 5 years, thought the later regulations were probably better thought out. I always guesstimate the savings to Southern California rate payers at more like $250 million.

Too bad I couldn’t have held out for a percentage.