A Scientific Critique of EPA’s Proposed National Emission Standards for Hazardous Air Pollutants [NESHAP] Rule
The EPA fails to describe the scientific reality of natural processes that govern the cycling of Mercury in newly proposed National Emission Standards.
From the Summary of Findings: The Environmental Protection Agency’s (EPA’s) newly proposed National Emission Standards for Hazardous Air Pollutants (NESHAP) failed to describe the scientific reality of natural processes and multi-factorial controls that govern the cycling of mercury (Hg) and the ultimate biomethylation and bioaccumulation processes for methylmercury (MeHg).
As this report documents, this natural cycle has been taking place for at least the last 650,000 years. EPA’s proposed NESHAP provides no detectable beneficial outcomes in the control of mercury emissions (even accepting EPA’s own risk-benefit analysis without a challenge). The new rules will result in a major economic impact, harm American public health by creating exaggerated and unfounded fears about eating fish that are beneficial in everyone’s diet, and further degrade the essential role of science in informing public policy.