Lynne Kiesling on the Administration's

Lynne Kiesling on the Administration's new New Source Review rules

Here: "New Source Review".

"To hear some of the "environmentalist" and media folks talk about this, it's like the EPA has repealed all air quality regualtions and we'll be soon plummeted into a universe of dark, sooty skies. But how realistic an opinion is that? Not very, in my view. First, new source review and the stringent treatment of equipment upgrades has induced firms to stick with older, less efifcient, more polluting technology than they might otherwise have implemented. What the Chicken Litlle crowd often forgets is that fuel costs for these companies are a substantial portion of their budgets, so if power plants and refineries can get more bang for their fuel buck by installing new technology, they would like to. Furthermore, these newer technologies are cleaner burning, and therefore less polluting than the grandfathered ones. But if installing these new technologies will trigger a long, extensive, bureaucratic review, at the end of which you will be subject to more stringent emission regulation, are you going to want to go through all of that as long as you can avoid it? Certainly not. [NOTE: always remember and never forget that arguments like these are marginal arguments, that I am claiming at the margin that NSR induces less technology upgrading than we would see otherwise]

"So the complaint about the NSR changes seems to be that the companies will be allowed to upgrade their equipment without being forced to decrease their emissions. OK, so ... how does this make us worse off than we have been in the situation in which they choose not to upgrade at all? They will still be held to the same Clean Air Act regulations..."