Taxpayer and Environmental Groups: Corps of Engineers Uses New Recipe to Cook the Books – Again – To Push Wasteful Delaware River Deepening Project - Report Released on Updated Economic Analysis

http://taxpayer.net/resources.php?category=&type=Project&proj_id=5058

Responding to renewed economic claims for Deepening the Delaware River, a coalition of taxpayer, community, and environmental organizations issued a new independent analysis they say proves once again that the deepening project is an economic loser. The groups issued the analysis and an accompanying report titled “Army Corps Cooks the Books Again,” in response to a May 2011 analysis issued by the Army Corps of Engineers.

“The Army Corps once again tried to mislead Congress and the public about the deepening project – a renewed analysis by Dr. Bob Stearns clearly demonstrates how the Army Corps manipulated their calculations so as to present a false picture for the project,” said Maya van Rossum, the Delaware Riverkeeper. “The inappropriate calculation was not hard to find. The Corps’ own report provides the analysis and numbers. Without deepening, shippers will use the feeder port approach which is far cheaper than trucking, and when all matters are considered, is also cheaper than deepening. The Corps’ assessment pretends that without deepening, shippers would use the far more expensive trucking option to get goods to the Philadelphia area markets. But the Corps’ own practices and procedures make clear that the shipping alternative is the best alternative and the one that would be selected, thereby supporting and encouraging port jobs without the need for a nearly $300 million, environmentally devastating deepening project.”

According to the new Cooked the Books report, correction of the shipping vs trucking error alone reduces the benefit-cost ratio for the project to, at best 1.1 (or to below 1 to 1, depending on a shipping diversion assumption) -- far below the 1.64 claimed by the Army Corps’ May 2011 report. Supplemental information in the report provided by the coalition of organizations identifies a number of additional errors they say, when included in the calculation, revive the GAO finding that deepening would provide less than a dollar of benefit for every $1 of cost paid for by the taxpayers.

“The Corps’ economic analysis deserves to be on a Chinese menu under twice-cooked pork. The errors were too obvious and too basic to be a mistake” says Steve Ellis, vice president of Taxpayers for Common Sense. “But more importantly, the new report is being used to justify renewed funding for a project that doesn’t meet the Federal Government’s basic criteria for ensuring tax dollars are invested only in those projects that will generate clear economic value for the country.”

“This new economic analysis makes it clear that the Delaware River Deepening project is an economic looser, which poses substantial environmental risks. The Army Corps needs to take a hard look at its project review practices if projects like this, that don’t meet the Corps’ own basic economic standards, are getting the green light,” asserts George Sorvalis, Coordinator with the Water Protection Network.

In a report issued in April, 2010, the Government Accountability Office (GAO) issued its third challenge to the reliability and accuracy of the Army Corps economic claims for deepening (the first GAO report being issued in 2002, the second challenge in the form of Congressional testimony given in 2006).

The Army Corps 2011 report was issued in apparent response to the less than glowing, GAO 2010 report. The May 2011 Army Corps analysis was its 8th economic analysis of the deepening. “But no one ever learned of this report or got an opportunity to review it until we secured the report through a Freedom of Information Act request,” says van Rossum. “As soon as we received a copy we pursued an independent review of its claims. We think our findings clearly demonstrate why the Army Corps felt the need to keep this newest analysis an apparent secret – because it’s clear that once again they cooked the books, a practice far too common with the Army Corps and one that demeans the entire federal government.”

Increased Recycling Would Create Nearly 1.5 Million Jobs, Reduce Pollution

http://www.bluegreenalliance.org/press_room/press_releases?id=0170
Higher recycling rates hold the potential to produce millions of new jobs, would strengthen local economies, reduce pollution and improve public health, according to a new report released November 15, 2011.

At a National Recycling Day event at the U.S. Capitol, Sen. Tom Carper (D-DE), a representative from the office of U.S. Rep. Frank Pallone (D-NJ) and a panel of environmental, labor and other leaders discussed the report, "More Jobs, Less Pollution," which found that a 75 percent national recycling rate holds the potential to create millions of new jobs.

"More Jobs, Less Pollution"  is a report from the Tellus Institute prepared for the BlueGreen Alliance, SEIU, NRDC, Teamsters, Recycling Works!, and the Global Alliance for Incinerator Alternatives (GAIA) available free of charge at www.bluegreenalliance.org/morejobslesspollution.

A 75 percent national recycling rate would also reduce CO2 emissions by 276 million metric tons by 2030 - equivalent to eliminating emissions from 72 coal-fired power plants or taking 50 million cars off the road; reduce conventional and toxic emissions that impact human and ecosystem health; and generate a stronger economy by creating a broader employment base.
...

MSW is Municipal Solid Waste, C&D = Construction and Demolition Debris

The Massachusetts Department of Environmental Protection (MassDEP) has made available several case studies that demonstrate the waste diversion and economic benefits of the ban. Clarke Corporation, a wholesale distributer of kitchen appliances, renovated and expanded its distribution center in Milford, Mass. Ninety-eight percent of materials generated on site were recycled or reused, resulting in cost savings of $259,043. In another case, recycling during the commercial demolition of the Massachusetts Institute of Technology (MIT) Media Lab in Cambridge resulted in 96 percent waste reduction and cost savings of  $17,684. For more information and the C&D recycling case studies, see http://www.mass.gov/dep/recycle/reduce/managing.htm.

The Blue-Green Alliance www.bluegreenalliance.org
Press Release dated November 15, 2011

New York City Department of Environmental Protection (DEP) Proposes Enhanced On-Site Stormwater Controls for New Construction Projects to Improve Harbor Water Quality

http://www.nyc.gov/html/dep/html/press_releases/11-91pr.shtml
On September 29, 2011 Environmental Protection Commissioner Carter Strickland proposed a rule requiring new construction and major building alteration projects to capture more stormwater runoff, provide additional capacity in the combined sewer system and reduce street flooding. New York City, like other older urban areas, is largely serviced by a combined sewer system where stormwater and wastewater are carried through a single pipe. During heavy storms, the system can exceed its capacity and must discharge a mix of stormwater and wastewater — called a combined sewer overflow, or CSO — into New York Harbor. Enhancing an already existing requirement, the rule will employ a wide range of on-site stormwater control techniques to all new development, redevelopment and major alterations in combined sewer areas. For a typical site over 5,000 square feet, DEP estimates that the rule will limit stormwater discharge to 10% of its present permitted flow to the combined sewer system using cost-effective detention, infiltration, and conservation techniques. This rule will lead to on-site control systems that are projected to reduce combined sewer overflows by as much as 800 million gallons over the next 20 years based on historic development trends. No existing homes or developments will be impacted by the new rule. The rule delivers a key component of the NYC Green Infrastructure Plan announced by Mayor Bloomberg last September.

"Combined sewer overflows remain one of the greatest challenges to water quality in New York Harbor," said Commissioner Strickland. "Our Green Infrastructure Plan seeks to control water at the source to keep it out of our sewers while balancing compliance costs. Through several years of outreach to the real estate, development and environmental communities, we have received many comments to adopt innovative and cost-effective techniques, and the final rule allows additional opportunities to use infiltration and recycling systems to meet control requirements."

The new proposed rule will reduce the amount of stormwater runoff discharged from new development projects as part of DEP's existing permitting processes. The current rule is based on a number of different factors such as existing sewer design criteria, property type, size, and drainage area of the lot. The new rule will reduce current limits for runoff to 10% of present permitted flows through the use of innovative control systems, such as blue roofs, green roofs, or subsurface gravel beds and stormwater chambers. For example, a typical one-acre site currently allowed to release 2.5 cubic feet per second under existing standards, will now be required to detain and release runoff at 0.25 cubic feet per second through some combination of on-site stormwater control systems. The cost impact of the new standard on a project's development is estimated to be an additional 0.3% to 1.5% of total costs.

The rule was developed through several task force meetings DEP conducted with the Mayor's Office of Long-Term Planning and Sustainability and its partners across city agencies. Over the past two years, DEP has received input from building industry which includes real estate, development and professional applicants, and environmental organizations, including the Real Estate Board of New York, the Regional Planning Association, American Institute of Architects, Buildings Sustainability Board, Citizens for Affordable Housing, US Green Buildings Council and the Green Infrastructure Steering Committee. Based on extensive feedback, the rule credits infiltration into soil and recycling for on-site use, which can reduce the size of stormwater control systems.

To assist with the implementation of the new rule, DEP will release a companion document, Guidelines for the Design and Construction of Stormwater Management Systems, offering guidance to the development community and applicants with the selection, planning, design and construction of on-site stormwater detention systems. The manual was developed in consultation with the Department of Buildings, and will feature guidance on siting, design and construction considerations for various stormwater control systems, as well as operation and maintenance recommendations. The guidelines will be continually updated to reflect the latest technology and best practices.

New York City Department of Environmental Protection (DEP) www.nyc.gov/dep

September 29, 2011

EPA Issues First National Standards for Mercury Pollution from Power Plants/ ‘mercury and air toxics standards’ meet 20-year old requirement to cut smokestack emissions

http://tinyurl.com/cpo5nkr
The U.S. Environmental Protection Agency (EPA) has issued the Mercury and Air Toxics Standards, the first national standards to protect American families from power plant emissions of mercury and toxic air pollution like arsenic, acid gas, nickel, selenium, and cyanide. The standards will slash emissions of these dangerous pollutants by relying on widely available, proven pollution controls that are already in use at more than half of the nation’s coal-fired power plants.

EPA estimates that the new safeguards will prevent as many as 11,000 premature deaths and 4,700 heart attacks a year. The standards will also help America’s children grow up healthier – preventing 130,000 cases of childhood asthma symptoms and about 6,300 fewer cases of acute bronchitis among children each year. 
 
"By cutting emissions that are linked to developmental disorders and respiratory illnesses like asthma, these standards represent a major victory for clean air and public health– and especially for the health of our children. With these standards that were two decades in the making, EPA is rounding out a year of incredible progress on clean air in America with another action that will benefit the American people for years to come," said EPA Administrator Lisa P. Jackson. "The Mercury and Air Toxics Standards will protect millions of families and children from harmful and costly air pollution and provide the American people with health benefits that far outweigh the costs of compliance."

“Since toxic air pollution from power plants can make people sick and cut lives short, the new Mercury and Air Toxics Standards are a huge victory for public health,” said Albert A. Rizzo, MD, national volunteer chair of the American Lung Association, and pulmonary and critical care physician in Newark, Delaware. “The Lung Association expects all oil and coal-fired power plants to act now to protect all Americans, especially our children, from the health risks imposed by these dangerous air pollutants.”

More than 20 years ago, a bipartisan Congress passed the 1990 Clean Air Act Amendments and mandated that EPA require control of toxic air pollutants including mercury. To meet this requirement, EPA worked extensively with stakeholders, including industry, to minimize cost and maximize flexibilities in these final standards. There were more than 900,000 public comments that helped inform the final standards being announced today. Part of this feedback encouraged EPA to ensure the standards focused on readily available and widely deployed pollution control technologies, that are not only manufactured by companies in the United States, but also support short-term and long-term jobs. EPA estimates that manufacturing, engineering, installing and maintaining the pollution controls to meet these standards will provide employment for thousands, potentially including 46,000 short-term construction jobs and 8,000 long-term utility jobs.

Power plants are the largest remaining source of several toxic air pollutants, including mercury, arsenic, cyanide, and a range of other dangerous pollutants, and are responsible for half of the mercury and over 75 percent of the acid gas emissions in the United States. Today, more than half of all coal-fired power plants already deploy pollution control technologies that will help them meet these achievable standards. Once final, these standards will level the playing field by ensuring the remaining plants – about 40 percent of all coal fired power plants - take similar steps to decrease dangerous pollutants.

As part of the commitment to maximize flexibilities under the law, the standards are accompanied by a Presidential Memorandum that directs EPA to use tools provided in the Clean Air Act to implement the Mercury and Air Toxics Standards in a cost-effective manner that ensures electric reliability. For example, under these standards, EPA is not only providing the standard three years for compliance, but also encouraging permitting authorities to make a fourth year broadly available for technology installations, and if still more time is needed, providing a well-defined pathway to address any localized reliability problems should they arise.

Mercury has been shown to harm the nervous systems of children exposed in the womb, impairing thinking, learning and early development, and other pollutants that will be reduced by these standards can cause cancer, premature death, heart disease, and asthma.

The Mercury and Air Toxics Standards, which are being issued in response to a court deadline, are in keeping with President Obama’s Executive Order on regulatory reform. They are based on the latest data and provide industry significant flexibility in implementation through a phased-in approach and use of already existing technologies.

The standards also ensure that public health and economic benefits far outweigh costs of implementation. EPA estimates that for every dollar spent to reduce pollution from power plants, the American public will see up to $9 in health benefits. The total health and economic benefits of this standard are estimated to be as much as $90 billion annually. 
 
The Mercury and Air Toxics Standards and the final Cross-State Air Pollution Rule, which was issued earlier this year, are the most significant steps to clean up pollution from power plant smokestacks since the Acid Rain Program of the 1990s.

Combined, the two rules are estimated to prevent up to 46,000 premature deaths, 540,000 asthma attacks among children, 24,500 emergency room visits and hospital admissions. The two programs are an investment in public health that will provide a total of up to $380 billion in return to American families in the form of longer, healthier lives and reduced health care costs. 

More information: http://www.epa.gov/mats/

The U.S. Environmental Protection Agency (EPA) www.EPA.gov 
Press Release dated December 21, 2011

New York City Department of Environmental Protection (DEP) Launches Program To Improve Services, Lower Costs and Maintain Status ...

http://www.nyc.gov/html/dep/html/press_releases/11-98pr.shtml 

On November 7, 2011 the New York City Department of Environmental Protection (DEP) launched a new program, Operational Excellence, or OpX, to help make DEP the safest, most effective, cost-efficient, and transparent water utility in the nation. The program will enhance services, result in environmental benefits, and reduce costs for the nine million New Yorkers who rely on DEP for water and wastewater services. Veolia Water ("Veolia"), an international expert in water and wastewater utilities, has been hired as a consultant to develop recommendations to streamline workflows, boost productivity, identify opportunities for efficiency gains, and keep future water rate increases as low as possible. As the nation's largest municipal water and wastewater utility, DEP currently spends roughly $1.2 billion annually on operations and maintenance and aims to achieve $100 to $200 million in annual savings through the program. The innovative incentive-based agreement with Veolia Water delivers access to a worldwide network of water and wastewater services and technologies while ensuring continued government control, decision-making authority, and ownership, as well as public-employee status for DEP employees.

... DEP Commissioner Carter Strickland said "Faced with unfunded mandates that have driven up costs, as well as the need for reinvesting in our basic infrastructure to ensure reliability for the next generation, and our desire to keep water rates in check as much as possible, now it is our turn to take our agency to the next level. The Operational Excellence program pairs us with a firm that brings a comprehensive portfolio of best management practices, a track record of boosting productivity while reducing expenses across the globe, and all while protecting existing workforces. Through this new innovative partnership, teams of DEP employees will work with Veolia to look for efficiencies across the board in operations and maintenance and then implement the best recommendations over the next four years while protecting our existing workforce and maintaining our level of service. We also know that the success of this program requires the help of the unions that represent our nearly 6,000 employees; so in addition to briefing them ahead of time, we will be working closely with them as the program moves forward. Bold steps like these are the responsible thing to do to lessen the burden on our 835,000 customers who have been absorbing several years of significant water rate increases."
...
The company's selection followed a Request for Proposals issued in April by the New York City Water Board and a competitive review process that focused on a contractor's ability to assess all aspects of agency operations for potential improvements, including labor productivity and processes, inventory management, chemical purchasing and usage, sludge digestion and disposal, and energy efficiency and management. The Veolia team includes McKinsey & Company and ARCADIS, both serving as subcontractors.DEP will draw from the Veolia team's portfolio of best management practices, including implementing system-wide improvements and saving up to 15% of operations and maintenance costs for utilities including Berliner Wasserbetriebe in Berlin, Germany and Thames Water in London, UK.  Veolia is the global water industry leader, managing more than 5,200 water facilities and 3,200 wastewater facilities around the world.
...
The OpX program is divided into two phases. First, DEP and its partner Veolia will conduct an initial evaluation and recommendation phase that will result in a final report in 2012 of recommendations on how DEP can improve productivity and reduce costs. Based on that report, DEP has the ability to accept or reject any of the proposed operational changes and cost-saving measures. Improvements that DEP chooses will be implemented over a four-year period.  Compensation for work performed includes a combination of a fixed fee and an incentive-based compensation that is calculated based on recurring savings achieved and documented.

The main objectives of the program are to:

• Review current operations and maintenance for potential improvements with a particular focus on energy usage and production opportunities, chemical usage and pricing, labor productivity, inventory management, and optimal sludge processes.
• Recommend implementable measures to improve and/or streamline operations and maintenance, increasing efficiencies, enhancing productivity, and reducing costs.
• Support public outreach, legislative initiatives, and other processes required to implement recommendations.
• Work with DEP staff to manage the implementation of the recommended initiatives.

Improving operational productivity and efficiency is a part of several goals outlined in Strategy 2011-2014, a far-reaching strategic plan that lays out 100 distinct initiatives to make DEP the safest, most efficient, cost-effective, and transparent water utility in the nation. The new plan, the product of nearly one year of analysis and outreach, builds on PlaNYC, Mayor Bloomberg's sustainability blueprint for New York City. The plan is available on DEP's website at www.nyc.gov/dep.
...
DEP manages the city's water supply, providing more than one billion gallons of water each day to more than nine million residents, including eight million in New York City. The water is delivered from a watershed that extends more than 125 miles from the city, comprising 19 reservoirs and three controlled lakes. Approximately 7,000 miles of water mains, tunnels and aqueducts bring water to homes and businesses throughout the five boroughs, and 7,400 miles of sewer lines and 95 pump stations take wastewater to 14 in-city treatment plants. DEP employs nearly 6,000 employees, including almost 1,000 in the upstate watershed. DEP has a robust capital program, with a planned $8.9 billion in investments over the next five years.

New York City Department of Environmental Protection www.nyc.gov/dep
Press Release dated November 7, 2011

EPA Proposes Changes to Clean Air Act Standards for Boilers and Incinerators/Reconsidered standards would set emission limits for less than one percent of boilers, achieve public health benefits while increasing flexibility and responding to public input

http://yosemite.epa.gov/opa/admpress.nsf/bd4379a92ceceeac8525735900400c27/30c5402413cbae038525795a004f5979 
The U.S. Environmental Protection Agency (EPA) is proposing changes to Clean Air Act standards for boilers and certain incinerators based on extensive analysis, review and consideration of data and input from states, environmental groups, industry, lawmakers and the public. The proposed reconsideration would achieve extensive public health protections through significant reductions in toxic air pollutants, including mercury and soot, while increasing the rule’s flexibility and addressing compliance concerns raised by industry and labor groups. The changes also cut the cost of implementation by nearly 50 percent from the original 2010 proposed rule while maintaining health benefits. These standards meet important requirements laid out in the 1990 Clean Air Act Amendments.

Soot and other harmful pollutants released by boilers and incinerators can lead to adverse health effects including cancer, heart disease, aggravated asthma and premature death. In addition, toxic pollutants such as mercury and lead that will be reduced by this proposal are linked to developmental disabilities in children. These standards will avoid up to 8,100 premature deaths, prevent 5,100 heart attacks and avert 52,000 asthma attacks per year in 2015.

More than 99 percent of boilers in the country are either clean enough that they are not covered by these standards or will only need to conduct maintenance and tune-ups to comply. Today’s proposals focus on the less than one percent of boilers that emit the majority of pollution from this sector. For these high emitting boilers, typically operating at refineries, chemical plants and other industrial facilities, EPA is proposing more targeted emissions limits that protect Americans’ health and provide industry with practical, cost-effective options to meet the standards – informed by data from these stakeholders. These limits are based on currently available technologies that are in use by sources across the country.

As a result of further information gathered through the reconsideration process, including significant dialog and meetings with stakeholders, the proposal maintains the dramatic cuts in the cost of implementation that were achieved in the final rules issued in March while continuing to deliver significant public health benefits. As a result, EPA estimates that for every dollar spent to cut these pollutants, the public will see $12 to $30 in health benefits, including fewer premature deaths.

Using a wide variety of fuels, including coal, natural gas, oil and biomass, boilers are used to power heavy machinery, provide heat for industrial and manufacturing processes in addition to a number of other uses, or heat large buildings. EPA’s proposal recognizes the diverse and complex range of uses and fuels and tailors standards to reflect the real-world operating conditions of specific types of boilers.

Some of the key changes EPA is proposing include:
 

Boilers at large sources of air toxics emissions: The major source proposal covers approximately 14,000 boilers – less than one percent of all boilers in the United States – located at large sources of air pollutants, including refineries, chemical plants, and other industrial facilities. EPA is proposing to create additional subcategories and revise emissions limits. EPA is also proposing to provide more flexible compliance options for meeting the particle pollution and carbon monoxide limits, replace numeric emissions limits with work practice standards for certain pollutants, allow more flexibility for units burning clean gases to qualify for work practice standards and reduce some monitoring requirements. EPA estimates that the cost of implementing these standards remains about $1.5 billion less than the April 2010 proposed standards. Health benefits to children and the public associated with reduced exposure to fine particles and ozone from these large source boilers have increased by almost 25 percent and are estimated to be $27 billion to $67 billion in 2015.

Boilers located at small sources of air toxics emissions: The proposal also covers about 187,000 boilers located at small sources of air pollutants, including commercial buildings, universities, hospitals and hotels. However, due to how little these boilers emit, 98 percent of area source boilers would simply be required to perform maintenance and routine tune-ups to comply with these standards. Only 2 percent of area source boilers may need to take additional steps to comply with the rule. To increase flexibility for most of these sources, EPA is proposing to require initial compliance tune-ups after two years instead after the first year.

Solid waste incinerators and revisions to the list of non-hazardous secondary materials: There are 95 solid waste incinerators that burn waste at a commercial or an industrial facility, including cement manufacturing facilities. EPA is proposing to adjust emissions limits for waste-burning cement kilns and for energy recovery units.

EPA is also proposing revisions to its final rule which identified the types of non-hazardous secondary materials that can be burned in boilers or solid waste incinerators. Following the release of that final rule, stakeholders expressed concerns regarding the regulatory criteria for a non-hazardous secondary material to be considered a legitimate, non-waste fuel, and how to demonstrate compliance with those criteria. To address these concerns, EPA’s proposed revisions provide clarity on what types of secondary materials are considered non-waste fuels, and greater flexibility. The proposed revisions also classify a number of secondary materials as non-wastes when used as a fuel and allow for a boiler or solid waste operator to request that EPA identify specific materials as a non-waste fuel.

Following the April 2010 proposals, the agency received more than 4,800 comments from businesses, communities and other key stakeholders. As part of the reconsideration process, EPA also received additional feedback after the agency issued the final standards in March 2011. EPA will accept public comment on these standards for 60 days following publication in the Federal Register. EPA intends to finalize the reconsideration by spring 2012.

More information: http://www.epa.gov/airquality/combustion

U.S. Environmental Protection Agency (EPA) www.EPA.gov

Press Release dated December 2, 2011