Background: Federal Environmental Regulations that Reduce Potential Natural Gas Use

NATURAL GAS SUPPLY ASSOCIATION

805 15th Street N.W., Suite 510
Washington, D.C. 20005

Background: Federal Environmental Regulations that Reduce Potential Natural Gas Use

While the Clean Air Act Amendments of 1990 have as one of their objectives the substitution of cleaner-burning natural gas for higher-polluting fuels, the Amendments and the regulations implementing them frequently impede those who attempt to prevent pollution through increased gas use. Following are some of the specific regulations and approaches:

Emissions requirements frequently differ by fuel.

Regulations implementing the Clean Air Act Amendments of 1990 (CAAA), for example, permit coal boilers to emit 0.4-0.5 lb/mmbtu of nitrogen oxides (NOx); oil boilers, .3 lb/mmbtu; and gas boilers, 0.2 lb/mmbtu.

Discriminatory limits force gas users to subsidize coal use; without the low gas requirements, regulators would have to impose more rigorous and expensive requirements on coal users to achieve the same pollution reduction. Discrimination perpetuates environmental damage from the higher levels of pollutants not yet subject to specific controls that are emitted during coal burning (air toxics, particulates, and CO2, for example). And discrimination dissociates environmental costs from fuel costs, providing perverse incentives to use.

Sources switching to cleaner fuels must conform retroactively to more rigorous emissions standards.

Sources that switch fuels are reclassified under federal regulations and must meet all emissions regulations applicable to the new fuel. Since more rigorous emissions requirements are imposed on cleaner-fuel sources than on dirtier-fuel sources, the source must not only bear the costs of the fuel switch but must also purchase all the technologies that will achieve the requirements imposed on the cleaner fuel--even when burning the cleaner fuel without these added technologies would reduce emissions below the level required for the higher-polluting fuel.

Sources switching to a cleaner fuel may become subject to New Source Review procedures.

Stationary sources considering fuel switching as part of plant renovations may become subject to onerous and expensive New Source Review and related federal procedures that not only delay renovations and add to costs but also subject the operation to an additional series of regulatory requirements from which it is almost impossible to escape. NGSA is addressing this problem through the regulatory reform process.

Serial regulations force inflexible emissions control measures that damage competitiveness.

The Clean Air Act Amendments of 1990 sets different timeframes for the development of regulations on different pollutants. Consequently, while source operators know that increasingly stringent regulations are likely, they are forced to evaluate each individual emission regulation separately, weighing the cost of a control technology against the cost of a fuel switch.

This procedure causes implementation problems and forces uneconomic choices, raising total costs as sources purchase and install a long list of separate technologies. In addition, multiple technologies in a single emissions stream may cause operational problems.

EPA enforces regulations on each emission separately.

EPA evaluates compliance with environmental regulations on an emission-by-emission basis, often using technical criteria for pollutant A that run counter to effective control of pollutant B. While the results of projects that use a "multi-media" or "holistic" approach to pollution control at a site have been promising, this approach remains unavailable to the vast majority of stationary sources. This poses a particular problem for gas, which has the potential to address many problems at once.

January 1995

This page was last updated August 31, 1997.