## 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 affe cted by your decisions can be

heard. Today, we are hearing extensive testimony regarding the dangers of mercury, specifically, an d of other pollutants, generally,

that are emitted from coal-fired el ectrical 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 pos sibility. These are issues with particular relevance in the southea stern portions of Wisconsin where I reside and its heavy reliance on co al 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 iss ues to which some of the current research being conducted in our la boratory may shed some light. I have spent over 25 years as a res earcher at the University of Wisconsin-Milwaukee investigating the e ffects 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 contaminan t 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 burni ng 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 alt erations in nerve function to the point that even adult learning and the ability to respond to environmental stimuli are perman ently affected. Indeed, such developmental exposures are now identified as causes of the neurodegenerative diseases of Alzhei mer’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 populati on of the Faroe Islands in the North Atlantic, the teenagers of to day 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 contaminant s that are emitted in coal-burning power plants.

## Second, our experiments have extended this finding by using

ultra-low levels of both merc ury 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 ju st on the developing embryo. Amazingly, we still are able to iden tify behavioral aberrations in larval and adult fish that have not experi enced any metal exposure, even at these very low concentrations, since they hatched. To put this level of exposure in context, this is se veral orders of m agnitude lower than the concentrations currently found in many lake sediments or being released by many electrical generat ing 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 le vel of mercury exposure to human populations as we are at the top of the feeding pyramid. Parallel to these studie s, 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 suffi cient to induce physiological

and behavioral deficits in children. Similar research identifies other metals, such as cadmium, relea sed by the burning of coal as developmental neurotoxicants. Third, and possibly the most disturbing, is an increasing understanding among scientists and i dentified in our laboratory, as well, that the offspring of expos ed individuals, even at very low concentrations, who, themselves, ha ve not been exposed to mercury, display the same degree of behavio ral 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 inabilit y to significantly reduc e the toxic emissions from coal-fired power plants to leve ls even below current standards. Collectively, our data are telli ng us that 1) exposures to the developing organism by metal cont aminants 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 prev iously 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 annually 1 

## . Add to this the cost to society of lead, cadmium and other pollutants distri buted 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 in terest 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 Protecti on Agency (EPA) announced a proposal in 2004 to reverse strict controls on emissions of mercur y 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 emissi ons. We assessed the impact on children's health of industrial mercur y emissions and found that between 316,588 and 637,233 babies are born with mercury-related losse s of cognitive function ranging from 0.2 to 5.13 points. We calculated that decreased economic productivit y 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 mercur y emitted from American coal-fired po wer 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 case s in the United States. If the lifet ime 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 trai ning 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 A gency (EPA) (NAESCO) U.S. Department of Housing and Urban Deve lopment 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 Departm ent 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 Colo rado, Office of Energy Conservation Illinois Department of Central Management Se rvices 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 Illi nois University Edwardsville Eastern Illinois University Edinboro University Shippensburg University Univer sity of Illinois at Chicago Northeastern Illinois University Marion County Schools, Florida West Chester University East Lycoming School District Northwestern University Go vernors State University Norfolk Public Schools I llinois State University Millersville University University of Illinois at ChampaignDave 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. Mi dwest 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 Wisconsi n 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 Moun tain Association of Higher Education Occupational and Environmental Health and Safety Facilities Officers Education and Research Center Un iversity of Illinois at Chicago Midwest Energy Efficiency Alliance Wilbur Wright Community College

EDUCATION: Bachelor of Science Degree, Industrial Engi neering; Northwestern University - 1975 Graduate studies, Industrial Enginee ring, Energy and Environmental Policy; Northwestern University - 1975-1979

PROFESSIONAL MEMBERSHIPS:

Member, National Accreditation Committee, National A ssociation of Energy Service Companies. Former Member, Indoor Environmental Quality Subcommittee, In ternational Performance Measurement & Verification Protocol.Dave Birr Credentials Page 3 David Birr has been a member of several professional asso ciations such as the Associ ation of Energy Engineers (AEE) and the Environmental Engineers and Managers Institut e and received several awar ds 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 Effici ency in the State Government Market” by Ranjit Bharvirkar, Charles Goldman, Donald Gilligan, Terry E. Singer, David Birr, Patric ia Donahue and Scott Serota, Principal Authors. Ernest Orlando Lawrence Berkeley National Laboratory, November 2008.

“A Survey of the U.S. ESCO Industry: Mark et Growth and Development from 2000 to 2006” Nicole Hopper, Charles Goldman, Donald Gilligan, Terry E. Singer and Dave Birr, Pr incipal 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 Labor atory, 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 I ndoor Air Quality – Inside and Out: Lessons Learned from the EPA/NAESCO Energy and Indoor Ai r Quality in Schools Project,” by Dave Birr, Chris Fontana, Emilio Braganza, Energy Efficiency Journal , May 2001. Meeting the Challenge, How Energy Perf ormance 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 En vironments Through Energy Performance Contracting,” by Dave Birr. School Business Affairs, December 2000. “Energy Performance Contracting Impr oves the School Indoor Environment,” by Dave Birr. Supplement to School Planning & Management , June 2000. “Indoor Air Quality Appendix,” David Birr, contributing Author. 1999 In ternational Performance Measurement and Verification Protocol . David Birr served as the official NAESCO repr esentative to the subcom mittee, 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 t he 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: Prelimi nary Lessons from the EPA/N AESCO 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 Indoo r 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 Cu re,”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 P ublic Housing and State Agencies ( Hawaii ) Energy Performance Contracting in State A gencies and Schools and Local Governments ( PA )

2008 Indoor Air Quality (two trainings; Midwest Energy Efficiency Alliance) Energy Performance Contracting for State and Public A gencies; (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 Contracti ng 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 Pub lic Agencies (series of three statewide trainings) Energy Performance Contracting from the Ow ner’s Perspective (NAESCO regional meeting) Energy Performance Contracting for Public Housing (Delta Institute) Savings Measurement and Verifi cation (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 traini ng 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 Oper ator Certification, UIC, Chicago) Indoor Air Quality (Building Operator Certification, EIU, Charleston, IL) Energy Performance Contracting (Georgia Building Authority, Atlanta, GA.) Energy Performance Contracti ng for State Facilities (NAESCO) State Energy Programs for Energy performance Contra cting (Rebuild America) Measurement and Verification (NAESCO Mid-Year Conference, Seattle, WA.)) Energy Efficient Lighting (Building Oper ator Certification, UIC, Chicago) Indoor Air Quality (Building Operator Certification, Chicago) Energy Performance Contracting for Public Housing (Raleigh, NC) Quantifying the Other Benefits of Efficiency (N AESCO Annual Conference, Newport Beach, CA.) 2003 Indoor Air Quality and Energy Pe rformance Contracting (DCCA) Indoor Air Quality and Energy Pe rformance Contra cting (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 St ate 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 (Co mmonwealth of Pennsylvania, Departm ent of Environmental Protection) Energy Performance Contracts, 2 days of tr aining (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 M ountain 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 M easurement and Verification (NYSERDA) Energy Efficiency/Air Quality Seminar (Nat ional Conference of State Legislators) Energy Performance Contracts and Indoor Air Qualit y (National Association of State Energy Offices) 1998 Energy Performance Contracting (NAHRO) Energy Performance Contracting (NAESCO Annual Conference) 1997 Energy Performance Contracting Wo rkshop (Florida Energy Office) 1996 US DOE/HUD Energy Performance Contra cting For PHAs (Chicago, US DOE) BOMA Commercial Cooling Co nference (BOMA, Chicago) 1995 Efficiency in Existing Buildings Research (US DOE) 1994 US DOE/HUD Energy Performance Contract ing for PHAs (Philadelphia, US DOE) 1993 US DOE/HUD Energy Performance Contractin g for PHAs (San Francisco, US DOE) State Florida Energy Performance Contracting (FEO) 1992 US DOE/HUD Energy Performance Cont racting for PHAs (Boston, US DOE) 1991 Energy Performance Contracting (International Association of School Board Officials) 1990 Energy Performance Contracting (Resou rce Development Institute, St. Louis) NAESCO Mid-Year Conference (NAESCO) 1988 Energy Efficient Maintenance, 3 days of traini ng (Center for Neighborhood Technology, Chicago) 1987 Residential Indoor Air Quality (Ev anston Environmental Association) US DOE ICP Workshop on Energy Performa nce Contracting (US DOE, Washington, DC) Co-Energy 87 on Energy Performance Contracting (North east Utilities) 1985 Codes and Indoor air Quality (Chicago Air Pollution Controls Association) 1983 Public Buildings Energy Efficiency (Ameri can Public Works Association, Chicago)

SUMMARY OF ENERGY PERFORMANCE CO NTRACTING 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 pr eparation of Technical Facility Profiles.

♦ Analyze and negotiate baseline utility rates.

♦ Provide performance contracting training services.

♦ Conduct technical reviews of engineering calcul ations 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 implic ations 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 relat ed to warranties, correction of installed work, operating responsibilities, energy measure upgrades and alterati ons, 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: 217-581-2199Comments from David Matthew Birr



# 1992 Illinois NO x 

# 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 sourcesDave 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 th ese market failures to protect human health

# This document is not availabl e in Regulations.gov since it contains comments from pa trons under the age of 13.

Contact the EPA Docket Center, Public Read ing Room to view or receive a copy of this docu ment. 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