EPA TESTIMONY FOR

PROPOSED RULES ON Hg:

CHICAGO, IL 

5/24/2011

Daniel Weber, PhD 

Senior Scientist 

Children’s Environmental Health Sciences Center 

University of Wisconsin-Milwaukee 

Thank you to the EPA for providing this public forum in which 

those who will be most profoundly affected by your decisions can be 

heard. 

Today, we are hearing extensive testimony regarding the 

dangers of mercury, specifically, and of other pollutants, generally, 

that are emitted from coal-fired electrical generating plants. These 

effects have been identified in human populations, as well as those of 

many species of fish and wildlife. The EPA is well aware of these 

data. The fundamental questions for this hearing are whether there is 

some level of mercury exposure that could be considered safe and, if 

so, do we have the technology to achieve it. And if not, do we have 

the courage to deal with that possibility. These are issues with 

particular relevance in the southeastern portions of Wisconsin where I 

reside and its heavy reliance on coal to generate electricity for an 

ever-expanding population. It is an issue for the various ethnic 

cultures in Wisconsin who historically rely on fish as an integral part 

of their diet. And they are issues to which some of the current 

research being conducted in our laboratory may shed some light. 

 I have spent over 25 years as a researcher at the University of 

Wisconsin-Milwaukee investigating the effects of toxic metals such as 
mercury and lead on various species of fish as a model for what we 

also see in human populations. What is critical here is that at even 

very low levels of metal contaminant exposure for short but critical 

time periods, the fish we study still display alterations in gene 

expression, physiology and behavior. As a result of these 

observations, we have, over the past 10 years, focused our efforts on 

3 areas of concern, each with relevance to this hearing. 

First, we have examined the effect of mercury and lead 

exposure, both emitted by the burning of coal, to the developing 

embryo and, by inference the human fetus, in terms of life-long 

alterations in critical behaviors. Our published data and manuscripts 

currently in review clearly demonstrate that such developmental 

exposures are sufficient to cause alterations in nerve function to the 

point that even adult learning and the ability to respond to 

environmental stimuli are permanently affected. Indeed, such 

developmental exposures are now identified as causes of the 

neurodegenerative diseases of Alzheimer’s and Parkinson’s in the 

elderly. Research using mammalian models, as well as 

epidemiological studies on humans, have yielded similar results. In a 

study on the seafood-eating population of the Faroe Islands in the 

North Atlantic, the teenagers of today who were exposed to mercury 

while still in their mother’s womb are still experiencing neurological 

and behavioral problems. In other words, wherever we look, whatever 

species we examine, we see the permanent effects of pre-hatch or 

prenatal exposures to the very metal contaminants that are emitted in 

coal-burning power plants. 
Second, our experiments have extended this finding by using 

ultra-low levels of both mercury and lead. We are now testing 

concentration exposures in the parts per billion range (that translates 

into nanograms of metal for each developing fish embryo), which 

represents the lowest level of detection by the most sophisticated 

analytical instruments, again just on the developing embryo. 

Amazingly, we still are able to identify behavioral aberrations in larval 

and adult fish that have not experienced any metal exposure, even at 

these very low concentrations, since they hatched. To put this level of 

exposure in context, this is several orders of magnitude lower than 

the concentrations currently found in many lake sediments or being 

released by many electrical generating plants. Due to the ability of 

methylated mercury to biomagnify through the food chain, it is 

possible, therefore, that there may not be any safe level of mercury 

exposure to human populations as we are at the top of the feeding 

pyramid. Parallel to these studies, clinical scientists are now 

discovering that ultra-low levels of lead exposure in children, 5 times 

less than the current standard set by the CDC for what constitutes 

lead poisoning in humans, are still sufficient to induce physiological 

and behavioral deficits in children. Similar research identifies other 

metals, such as cadmium, released by the burning of coal as 

developmental neurotoxicants. 

Third, and possibly the most disturbing, is an increasing 

understanding among scientists and identified in our laboratory, as 

well, that the offspring of exposed individuals, even at very low 

concentrations, who, themselves, have not been exposed to mercury, 

display the same degree of behavioral and physiological aberrations 
as the parent generation that was exposed. In other words, the toxic 

effects of mercury exposure are passed down to our children and 

grandchildren, that the developmental and behavioral issues our 

children, grandchildren and those not yet born will experience may be 

the result of our inability to significantly reduce the toxic emissions 

from coal-fired power plants to levels even below current standards. 

Collectively, our data are telling us that 1) exposures to the 

developing organism by metal contaminants such as mercury and 

lead found in the emissions from coal-fired power plants induce longterm and even permanent behavioral deficits; 2) these alterations in 

behavior are occurring at very low-levels of mercury or lead 

exposure, far below what was previously considered safe; and 3) 

future generations may be affected by the inability of this generation 

to clean up its toxic emissions. The estimated cost to society due to 

mercury exposure alone in terms of health care and lost productivity 

is over $8 billion annually1

. Add to this the cost to society of lead, 

cadmium and other pollutants distributed into the atmosphere by the 

burning of coal, it should be clear to all that, for the sake of this and 

future generations, it is in the nation’s best interest to tighten our 

emission standards. The added cost to achieve the goal of lower 

mercury emissions clearly will be money well spent. 

1

Trasande L, Schechter C, Haynes KA, Landrigan PJ. Applying cost analyses to drive policy that 

protects children: mercury as a case study. Ann N Y Acad Sci. 2006;1076:911-23. 

Exposure in prenatal life to methylmercury (MeHg) has become the topic of intense debate in the 

United States after the Environmental Protection Agency (EPA) announced a proposal in 2004 to 

reverse strict controls on emissions of mercury from coal-fired power plants that had been in 

effect for the preceding 15 years. This proposal failed to incorporate any consideration of the 

health impacts on children that would result from increased mercury emissions. We assessed the 

impact on children's health of industrial mercury emissions and found that between 316,588 and 

637,233 babies are born with mercury-related losses of cognitive function ranging from 0.2 to 

5.13 points. We calculated that decreased economic productivity resulting from diminished 

intelligence over a lifetime results in an aggregate economic cost in each annual birth cohort of 
$8.7 billion annually (range: $0.7-$13.9 billion, 2000 dollars). $1.3 billion (range: $51 million-$2.0 

billion) of this cost is attributable to mercury emitted from American coal-fired power plants. 

Downward shifts in intellectual quotient (IQ) are also associated with 1566 (range: 115-2675) 

excess cases of mental retardation (MR defined as IQ < 70) annually. This number accounts for 

3.2% (range: 0.2-5.4%) of MR cases in the United States. If the lifetime excess cost of a case of 

MR (excluding individual productivity losses) is $1,248,648 in 2000 dollars, then the cost of these 

excess cases of MR is $2.0 billion annually (range: $143 million-$3.3 billion). Preliminary data 

suggest that more stringent mercury policy options would prevent thousands of cases of MR and 

billions of dollars over the next 25 years. 








David Matthew Birr, President 

Synchronous Energy Solutions, Inc. 

329D Woodview Road 

Barrington, Illinois 60010 

Business: (847) 842-9106 Fax: (847) 842-9145 

E-mail: DaveBirr@aol.com 

♦ Nationally recognized expert on energy performance contracting 

♦ Over 25 years’ technical experience designing, managing, and monitoring energy efficiency projects 

♦ Over 24 years’ experience negotiating and testifying as a technical expert on utility DSM programs and energy 

service contracts 

♦ Over 25 years’ experience developing and evaluating energy programs and policies for government agencies 

♦ Over 25 years’ experience providing technical training on energy technologies, procurement policies, 

monitoring methods and environmental policy. 

 SAMPLE TECHNICAL PROJECT MANAGEMENT & ENERGY PERFORMANCE CONTRACTING CLIENTS: 

Federal Agencies

Lawrence Berkeley National Laboratory National Association of Energy Service Companies 

U.S. Environmental Protection Agency (EPA) (NAESCO) 

U.S. Department of Housing and Urban Development U.S. Department of Energy 

 

States and Local Governments

Georgia Building Authority North Carolina Energy Office 

Michigan Energy Office Florida Energy Office 

City of Chicago City of Evanston 

Commonwealth of Pennsylvania Illinois Department of Commerce and Economic Opportunity 

Chicago Park District City of Atlanta 

Illinois Department of Transportation Georgia Department of Corrections 

City of Cincinnati, Ohio State of Colorado, Office of Energy Conservation 

Illinois Department of Central Management Services Mississippi State Energy Office 

State of Hawaii County of Berks, PA 

Lehigh County, PA Dauphin County, PA 

Cook County, IL City of Miami Beach 

City of Philadelphia Allegheny County, PA 

Universities and Schools

Oakland University Southern Illinois University Edwardsville 

Eastern Illinois University Edinboro University 

Shippensburg University University of Illinois at Chicago 

Northeastern Illinois University Marion County Schools, Florida 

West Chester University East Lycoming School District 

Northwestern University Governors State University 

Norfolk Public Schools Illinois State University 

Millersville University University of Illinois at Champaign 
Dave Birr Credentials 

Page 2 

Public Housing Authorities

Housing Authority of Joliet YMCA of Metropolitan Chicago 

Chicago Housing Authority New Albany Housing Authority 

LaSalle Housing Authority City of New Britain Housing Authority 

Charleston Housing Authority (West Virginia) Pittsfield Housing Authority 

Virgin Islands Public Housing Authority San Antonio Housing Authority 

Rockford Housing Authority Kankakee Housing Authority 

Hawaii Public Housing Authority Albany Housing Authority 

Other

Chicago Building Owners and Managers Association American Medical Design Consultants 

Donahue and Associates, Inc. Midwest Energy Efficiency Alliance 

E-Source, Inc. Enlightened Energy Consultants 

E-Cube, Inc. Energetics 

Illinois Bell Telephone Company Science Applications International Corporation 

Sieben Energy Associates Profile Systems 

Tetra Tech, Inc. Leveraged Solutions 

Delta Institute Wisconsin Energy Conservation Corporation 

Pittsburgh Airport Urbana School District 

 

EXPERT WITNESS AND ARBITRATION CLIENTS: 

State of Iowa Facilities Improvement Corp. Legal Assistance Foundation of Chicago 

Illinois Office of Public Counsel City of Chicago 

Citizens Action Coalition of Indiana O’Rourke Katten and Moody 

Business & Professional People for the Public Interest St. Lucie County, Florida 

Resource Insight Viron Energy Services 

West Chester University Sachnoff & Weaver, Ltd. 

Hogan, Marren, Ltd. Bamberger, Foreman, Oswald and Hahn, LLP 

Paducah Housing Authority Taylor, Porter,Brooks & Phillips LLP 

Bryan Cave LLP 

TECHNICAL TRAINING CLIENTS: 

Florida Energy Office U.S. Dept. of Housing and Urban Development 

Center for Neighborhood Technology IL Dept. of Energy and Natural Resources 

U.S. Department of Energy Chicago Building Owners & Managers Association 

Resource Development Institute National Association of Energy Service Companies 

American Public Works Association NY State Energy Research & Development Authority 

Air Pollution Control Association Commonwealth of Pennsylvania 

Energetics National Center for Appropriate Technology 

Illuminating Engineering Society Rocky Mountain Association of Higher Education 

Occupational and Environmental Health and Safety Facilities Officers 

Education and Research Center University of Illinois at Chicago 

Midwest Energy Efficiency Alliance Wilbur Wright Community College 

EDUCATION:

 Bachelor of Science Degree, Industrial Engineering; Northwestern University - 1975 

 Graduate studies, Industrial Engineering, Energy and Environmental Policy; Northwestern University - 1975-1979 

PROFESSIONAL MEMBERSHIPS: 

Member, National Accreditation Committee, National Association of Energy Service Companies. Former 

Member, Indoor Environmental Quality Subcommittee, International Performance Measurement & Verification 

Protocol. 
Dave Birr Credentials 

Page 3 

David Birr has been a member of several professional associations such as the Association of Energy Engineers 

(AEE) and the Environmental Engineers and Managers Institute and received several awards from the AEE, Chicago 

Chapter, including a Wise Owl Award and the 1999 Energy Manager Award. 

PUBLICATIONS LIST FOR DAVID BIRR 

“NAESCO Analysis of Non-Energy Benefits of Efficiency Retrofits for ESCOs and ESCO Customers” by David Birr and 

Terry E. Singer, Principal Authors. National Association of Energy Service Companies with funding from the US 

Department of Energy. February 2009. 

“Performance Contracting and Energy Efficiency in the State Government Market” by Ranjit Bharvirkar, Charles 

Goldman, Donald Gilligan, Terry E. Singer, David Birr, Patricia Donahue and Scott Serota, Principal Authors. Ernest 

Orlando Lawrence Berkeley National Laboratory, November 2008. 

“A Survey of the U.S. ESCO Industry: Market Growth and Development from 2000 to 2006” Nicole Hopper, Charles 

Goldman, Donald Gilligan, Terry E. Singer and Dave Birr, Principal Authors. Ernest Orlando Lawrence Berkeley 

National Laboratory, May 2007. 

“Public and Institutional Markets for ESCO Services: Comparing Programs, Practices, and Performance” by Nicole 

Harper, Charles Goldman, Jennifer McWilliams, Dave Birr, and Kate McMordie. Ernest Orlando Lawrence Berkeley 

National Laboratory, March 2005. 

“The Federal Market for ESCO Services: How Does it Measure Up?” by Nicole Harper, Charles Goldman and Dave 

Birr. Ernest Orlando Lawrence Berkeley National Laboratory, Proceedings of the 2004 ACEEE Summer Study on 

Energy Efficiency in Buildings, August 2004. (Also published in the NAESCO Journal, August 2004) 

“The Impact of Energy Efficiency Technologies on School Indoor Air Quality – Inside and Out: Lessons Learned from 

the EPA/NAESCO Energy and Indoor Air Quality in Schools Project,” by Dave Birr, Chris Fontana, Emilio Braganza, 

Energy Efficiency Journal, May 2001. 

Meeting the Challenge, How Energy Performance Contracting can Help Schools Provide Comfortable, Affordable, 

Healthy, and Productive Learning Environments. David Birr and Patricia Donahue, Co-authors. Published by the 

National Association of Energy Service Companies with funding from the US EPA. March 2001. 

“Meeting the Challenge: Providing High-Quality School Environments Through Energy Performance Contracting,” by 

Dave Birr. School Business Affairs, December 2000. 

“Energy Performance Contracting Improves the School Indoor Environment,” by Dave Birr. Supplement to School 

Planning & Management, June 2000. 

“Indoor Air Quality Appendix,” David Birr, contributing Author. 1999 International Performance Measurement and 

Verification Protocol. David Birr served as the official NAESCO representative to the subcommittee, which wrote the 

appendix. 

“An Air of Concern,” Terry E. Singer, Tania Shonkwiler and David Birr, Co-authors. American School and University.

May 1998. 

“Choosing an ESCO: Helpful Hints from an ESCO Evaluator,” David Birr, Author. Energy Efficiency Journal, Volume 1, 

No. 3. 

“Advantages of Energy Performance Contracts Compared to Standard Procurement Approaches,” David Birr, Author. 

DOE-HUD Energy Performance Contracting Training Manual. 

“Measurement, Monitoring, and Maintenance as the Keys to Persistent Project Performance,” David Birr, Author. DOEHUD Energy Performance Contracting Training Manual. 

“Why Indoor Air Quality Problems in Schools should not be Ignored by School Administrators: What ESCOs Need to 

Know,” Terry E. Singer, Tania Shonkwiler and David Birr, Co-authors. Energy Efficiency Journal, Volume 5, No. 4. 

“Energy and Indoor Air Quality in Schools: Preliminary Lessons from the EPA/NAESCO Demonstration Project,”
Dave Birr Credentials 

Page 4 

Yasmine Redding, David Birr and Jed Harrison, Co-authors. Energy Efficiency Journal, Volume 7, No. 1. 

“School Solutions: How to Save Money and Improve Indoor Air Quality Using Energy Performance Contracts,” David 

Birr, Author. Published by the National Association of Energy Service Companies. 

PUBLICATIONS LIST FOR DAVID BIRR (cont’d) 

“Special Report: IAQ and Energy School Solutions,” David Birr, Author. Energy Decisions, November 1999. 

“Getting Past the Appeal of Low First Cost Decisions: Commissioning Could Be the Cure,”David Birr,Energy User 

News, August 2002

“Using Energy Performance Contracting to Improve the School Environment Provides Many Benefits,” David Birr, 

Author. Energy Efficiency Journal, Volume 8, No. 1. 

Selected List of David Birr’s Professional Training Experience 

 2009 Indoor Air Quality ( Midwest Energy Efficiency Alliance) 

 Energy Performance Contracting in State Universities (State of Illinois )

 Energy Peformance Contracting in Public Housing and State Agencies ( Hawaii )

 Energy Performance Contracting in State Agencies and Schools and Local Governments ( PA )

 2008 Indoor Air Quality (two trainings; Midwest Energy Efficiency Alliance) 

 Energy Performance Contracting for State and Public Agencies; (series of three trainings in PA, MI and IL) 

 Energy Performance Contracting for Public Housing Authorities (Delta Institute) 

 High Performance Buildings (DePaul University Center for Real Estate) 

 Non-Energy Benefits of Energy Projects (NAESCO annual conference) 

 Energy Performance Contracting for State Facilities (Hawaii )

2007 Energy Performance Contracting and Indoor Air Quality (Midwest Energy Efficiency Alliance ) 

 Energy Performance Contracting for Texas Public Housing Authorities 

 Energy Performance Contracting for Mississippi’s Public Agencies (series of three statewide trainings) 

 Energy Performance Contracting from the Owner’s Perspective (NAESCO regional meeting) 

 Energy Performance Contracting for Public Housing (Delta Institute) 

 Savings Measurement and Verification (NAESCO regional meeting) 

 Avoiding Contract Disputes (NAESCO regional meeting) 

2006 Energy Performance Contracting for Texas Public Housing Authorities 

 Sustainable Cities Conference 

 Energy Performance Contracting for Public Housing (Delta Institute) 

 Project Commissioning (series of three training for the Wisconsin Energy Conservation Corp.) 

2005 Indoor Air Quality (Building Operator Certification. ISU, Normal) 

 Indoor Air Quality (BOC, Chicago Center for Green Tech) 

 Evaluating EPC RFPs (NAESCO SE Regional conference) 

 NAESCO Mid-Year Conference (Austin, TX) 

2004 Energy Efficient Lighting (Building Operator Certification, UIC, Chicago) 

Indoor Air Quality (Building Operator Certification, EIU, Charleston, IL) 

Energy Performance Contracting (Georgia Building Authority, Atlanta, GA.) 

Energy Performance Contracting for State Facilities (NAESCO) 

State Energy Programs for Energy performance Contracting (Rebuild America) 

Measurement and Verification (NAESCO Mid-Year Conference, Seattle, WA.)) 

Energy Efficient Lighting (Building Operator Certification, UIC, Chicago) 

Indoor Air Quality (Building Operator Certification, Chicago) 

Energy Performance Contracting for Public Housing (Raleigh, NC) 

Quantifying the Other Benefits of Efficiency (NAESCO Annual Conference, Newport Beach, CA.) 

2003 Indoor Air Quality and Energy Performance Contracting (DCCA) 

Indoor Air Quality and Energy Performance Contracting (NYSERDA) 

HUD Energy Performance Training for PHAs, 5 days of training (ERCCE, Chicago, IL) 

Energy Performance Contracting Training (Georgia Building Authority) 

Energy Performance Contracting in Universities (NAESCO, PA) 

Energy Performance Contracting in State Facilities, 5 statewide training sessions (NC State Energy Office) 
Dave Birr Credentials 

Page 5 

2002 Environmental Quality and Productivity (Mid-Year Conference NAESCO) 

HUD Energy Performance Training for PHAs, 5 days of training (ERCCE) 

Rebuild America Energy Performance and IAQ in Schools (DCCA) 

NAESCO Annual Conference (NAESCO) 

2001 Using Performance Contracting to Improve IAQ, Washington Association of Schools (US EPA) 

Wisconsin Schools Indoor Air Quality and Energy Efficiency (NAESCO) 

NAESCO Mid-Year Conference: Commissioning (NAESCO) 

HUD Energy Performance Training for PHAs, 5 days of training (ERCCE) 

Energy Efficient Lighting and Energy Performance Contracting (IESNA) 

Indoor Air Quality (US EPA) 

IAQ in Schools (US EPA) 

2000 Energy Performance Contracts (Commonwealth of Pennsylvania, Department of Environmental Protection) 

Energy Performance Contracts, 2 days of training (US EPA, Commonwealth of Pennsylvania) 

US DOE Energy Performance Contracting (US DOE) 

HUD/DOE Performance Training for PHAs, 5 days of training (ERCCE) 

Energy Performance Contracting (Rocky Mountain Higher Education Facilities Officers) 

1999 NAESCO Mid-Year Conference; Dispute Resolution (NAESCO) 

Energy Performance Contracting for PHAs 5 days of training (ERCCE) 

Energy Performance Contracting and Measurement and Verification (NYSERDA) 

Energy Efficiency/Air Quality Seminar (National Conference of State Legislators) 

Energy Performance Contracts and Indoor Air Quality (National Association of State Energy Offices) 

1998 Energy Performance Contracting (NAHRO) 

Energy Performance Contracting (NAESCO Annual Conference) 

1997 Energy Performance Contracting Workshop (Florida Energy Office) 

1996 US DOE/HUD Energy Performance Contracting For PHAs (Chicago, US DOE) 

BOMA Commercial Cooling Conference (BOMA, Chicago) 

1995 Efficiency in Existing Buildings Research (US DOE) 

1994 US DOE/HUD Energy Performance Contracting for PHAs (Philadelphia, US DOE) 

1993 US DOE/HUD Energy Performance Contracting for PHAs (San Francisco, US DOE) 

State Florida Energy Performance Contracting (FEO) 

1992 US DOE/HUD Energy Performance Contracting for PHAs (Boston, US DOE) 

1991 Energy Performance Contracting (International Association of School Board Officials) 

1990 Energy Performance Contracting (Resource Development Institute, St. Louis) 

NAESCO Mid-Year Conference (NAESCO) 

1988 Energy Efficient Maintenance, 3 days of training (Center for Neighborhood Technology, Chicago) 

1987 Residential Indoor Air Quality (Evanston Environmental Association) 

US DOE ICP Workshop on Energy Performance Contracting (US DOE, Washington, DC) 

Co-Energy 87 on Energy Performance Contracting (Northeast Utilities) 

1985 Codes and Indoor air Quality (Chicago Air Pollution Controls Association) 

1983 Public Buildings Energy Efficiency (American Public Works Association, Chicago) 

SUMMARY OF ENERGY PERFORMANCE CONTRACTING SERVICE CAPABILITIES: 

♦ Prepare customized Request for Proposal documents. 

♦ Evaluate the technical feasibility of specific sites for a performance contracting project. 

♦ Provide instructions and guidance in the preparation of Technical Facility Profiles. 

♦ Analyze and negotiate baseline utility rates. 

♦ Provide performance contracting training services. 

♦ Conduct technical reviews of engineering calculations in ESCO proposals and energy audits. 

♦ Negotiate energy efficiency project commissioning procedures. 
Dave Birr Credentials 

Page 6 

♦ Review proposed contract documents for substantive performance contracting provisions and technical 

accuracy. 

♦ Educate legal counsel regarding the implications of technical contract provisions. 

♦ Assist in the negotiation of the technical scope of projects. 

♦ Negotiate the technical and financial terms of energy savings guarantee language. 

♦ Review the reasonableness of cost estimates for ESCOs technical services 

♦ Negotiate energy service contract provisions related to warranties, correction of installed work, operating 

responsibilities, energy measure upgrades and alterations, malfunctions and emergencies, defined material 

changes in performance and events of default and remedies. 

♦ Audit and review monthly performance monitoring reports. 

♦ Arbitrate and mediate energy performance contract disputes. 

♦ Conduct an independent review of the technical feasibility of proposed efficiency measures. 

♦ Evaluate proposed material and operational cost savings. 

♦ Negotiate and review proposed interim savings calculations. 

♦ Draft energy audit agreements. 

REFERENCES 

Mr. Paul Meister, P.E., CEM 

Energy Engineer 

Penn State Facilities Engineering Institute 

135 East Nittany Avenue, Suite 414 

State College, PA 16801 

Phone: 814-865-3368 

Mr. Wayne Hartel 

Energy program Specialist 

 Illinois Department of Commerce and Economic 

Opportunity 

 620 East Adams 

Springfield,IL 62701 

Phone 217 785-3420 

Mr. Chuck Goldman 

Program Manager 

Energy Analysis Department 

Lawrence Berkeley National Laboratory 

MS90-4126 

1 Cyclotron Road 

Berkeley, CA 94720 

Phone: 510-486-4637 

 

 

Mr. Bruce Stultz 

Pennsylvania Department of General Services 

Bureau of Facilities Management 

Room 414 North Office Building 

Harrisburg, PA 17125 

Phone: (717) 705-8519 

Gary Reed, P.E. 

Director of Facilities Planning and Management 

Eastern Illinois University 

600 Lincoln Avenue 

Charleston, IL 61920-3099 

Phone: 217-581-2199 
Comments from David Matthew Birr 

1992 Illinois NOx

Emission Sources

Other 

Stationary 

Sources

16%

Mobile

Sources

43%

Electric 

Utilities

41%

315,400

 tons

301,700

 tons

118,500

 tons

Energy 

Production and 

Consumption 

Federal Energy Subsidies Distort 

the Price of Energy Supplies 

Compared to Energy Efficiency

$50

$1

$35

$1

$30

$1

$0

$10

$20

$30

$40

$50

1984 Supply 1984

Efficiency

1989 Supply 1989

Efficiency

1995 Supply 1995

Efficiency

Billions

of $ of 

federal 

subsidies 

in (1989 $)
Dave Birr Credentials 

Page 8 

Energy Supplied per Dollar of 

Federal Energy Subsidy (1984 Data)

13

5.8

3.8

2.4

1.7 0.8 0.4 0.07

0

5

10

15

Millions of BTUs

Energy Delivered

per $ of Federal

Subsidy

Energy Efficiency

Coal

Nat. Gas

Oil NG Liquid

Non Hydro Renew

Fossil Elec

Hydro Elec

Nuclear Elec

Market Failures to Reduce 

Emissions

• Utility lack of investment in low 

emissions energy sources

• Failure to protect human beings from 

toxic mercury exposures 

• Under investment in natural gas, energy 

efficiency and renewable sources
Dave Birr Credentials 

Page 9 

Market Failures (continued)

• Energy prices that do not include 

environmental costs, but do include huge 

government subsidies for supply,which leads to 

significantly under estimating the real value of 

energy efficiency and renewable alternatives

• We need effective mercury emissions 

regulations to address these market failures to 

protect human health
This document is not available in Regulations.gov since it 

contains comments from patrons under the age of 13. 

Contact the EPA Docket Center, Public Reading Room to view 

or receive a copy of this document. Requests for copies may be 

made as follows: 

In person/writing: 

Environmental Protection Agency, Docket Center 

1301 Constitution Ave NW, 2822T, Room 3334 

Washington, DC. 20004 

Telephone: 

202-566-1744 

Fax: 

202-566- 9744 

Email: 

docket-customerservice@epa.gov