ORDES
COMMENTS ON THE OHIO RIVER BASIN ENERGY STUDY
Collected by
James J. Stukel Boyd R. Keenan
University of Illinois University of Illinois
at Urbana-Champaign at Chicago Circle
Urbana, Illinois 61801 Chicago, Illinois 60680
PHASE II
OHIO RIVER DASIK ENERGY STUDY
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February 1981
COMMENTS ON THE OHIO RIVER BASIN ENERGY STUDY
Collected by
James J. Stukel Boyd R. Keenan
University of Illinois University of Illinois
at Urbana-Champaign at Chicago Circle
Urbana, Illinois 61801 Chicago, Illinois 60680
Cooperative Agreement EPA CR807395
Project Officer
Lowell Smith
Office of Environmental Engineering and Technology
Office of Research and Development
U.S. Environmental Protection Agency
Washington, D.C. 20460
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
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PREFACE
The Ohio River Basin Energy Study (ORBES) was a four-year research
activity undertaken by over 100 university faculty members at eight
institutions in the Middle West and the area popularly known as the Ohio River
valley. ORBES was mandated by the U.S. Congress in 1975 in response to
concerns expressed by citizens in that area. The study was planned and funded
by the U.S. Environmental Protection Agency (EPA).
The principal element of the ORBES publication series is entitled Ohio
River Basin Energy Study (ORBES); Main Report (EPA-600/7-81-008), which also
will be available in summary form (EPA-600/S7-81-008). The main report
represents the collective end product of a 13-member interdisciplinary faculty
group known as the ORBES core team. In addition to the main report, more than
50 other ORBES documents by various researchers were issued over the four-year
project period.
The members of the ORBES core team are James J. Stukel, professor of
environmental engineering and mechanical engineering and director, Office of
Energy Research, University of Illinois at Urbana-Champaign, and Boyd R.
Keenan, professor of political science, University of Illinois at Chicago
Circle, both of whom also served as co-directors; and (alphabetically) Robert
E. Bailey, professor of nuclear engineering and director. Program on Energy
Research, Education, and Public Service, The Ohio State University; Donald A.
Blome, research scientist, Institute for Mining and Mineral Research, Energy
Research Laboratory, University of Kentucky; Vincent P. Cardi, professor of
law. West Virginia University; Gary L. Fowler, associate professor of
geography and associate director, Energy Resources Center, University of
Illinois at Chicago Circle; Steven I. Gordon, assistant professor of city and
regional planning, The Ohio State University; James P. Hartnett, professor of
energy engineering and director, Energy Resources Center, University of
Illinois at Chicago Circle; Walter P. Page, associate professor of economics,
West Virginia University; Harry R. Potter, associate professor of sociology,
Purdue University; J.C. Randolph, associate professor of ecology and director
of environmental programs, School of Public and Environmental Affairs, Indiana
University; Maurice A. Shapiro, professor of environmental health engineering,
University of Pittsburgh; and Hugh T. Spencer, associate professor of chemical
and environmental engineering. University of Louisville.
The core team's work grew out of ORBES Phase I, which extended from the
fall of 1976 through November 1977, when QRBES Phase l: Interim Findings
(EPA-600/7-77-120) was published. This latter publication, written by
iii
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Professors Stukel and Keenan, synthesized findings of the three preliminary
research teams that operated independently during Phase I. As mandated by
Congress, the Phase I study region consisted of portions of Illinois, Indiana,
Kentucky, and Ohio, and researchers were from universities in these states.
EPA officials as well as members of Congress and their staffs agreed that in
ORBES Phase II the study region should be expanded to include virtually all of
West Virginia and the southwestern portion of Pennsylvania.
ORBES may be unique in terms of its management framework and its openness
to the public. The work of the interdisciplinary, interuniversity core team
was coordinated by a management team and by a project office maintained on the
University of Illinois campuses at Urbana-Champaign and at Chicago Circle. At
least once a month, and sometimes more frequently, the full core team held
two- and three-day working sessions that were open to the public on the
various campuses and at other locations around the study region. These
meetings began in the fall of 1977 and continued for two years. Moreover,
during both Phase I and Phase II, open meetings on research results were held
throughout the region. Early in Phase I, an advisory committee was appointed,
consisting of representatives from government, business, labor, agriculture,
the public, and other sectors. Committee membership was expanded throughout
Phase II and reached a total of 43. Advisory committee members had an ongoing
invitation to provide written or oral comments on the ORBES research. As part
of their input, they reviewed a preliminary draft of the main report.
Members of the advisory committee and other project entities also were
given the opportunity to contribute to the present volume, which is entitled
Comments on the Ohio River Basin Energy Study. The other project entities are
the core team, the management team, and the support researchers. This latter
group carried out specialized subprejects commissioned in Phase II by the core
team.
The comments collected in this volume cover not only the ORBES main
report, but also any other aspect of the project that the writers chose to
review. Each individual's review is limited to 10 pages. Of the 13 core team
members, 2 contributed to this volume, as did 1 support researcher. Eleven of
the 43 advisory committee members are represented by individual comments. In
addition, two groups of advisors chose to pool part or all of their allotted
pages: (1) utility company representatives and (2) the administrators of EPA
Regions III, IV, and V.
For the convenience of the reader, a complete list of ORBES publications
appears as Appendix A. Appendix B consists of rosters of the various Phase II
participants.
IV
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CONTENTS
PREFACE iii
CORE TEAM COMMENTS
Robert E. Bailey, The Ohio State University 3
Hugh T. Spencer, University of Louisville 9
SUPPORT RESEARCHER COMMENTS
E. Earl Whitlatch, The Ohio State University 13
ADVISORY COMMITTEE COMMENTS
Valdas V. Adamkus, U.S. Environmental Protection Agency Region V ... 19
John P. Apel, Columbus and Southern Electric Company
Hugh A. Barker, Public Service Indiana
W.C. Gerstner, Illinois Power Company
Owen Lentz, East Central Area Reliability Council
R.A. McKnight, Indianapolis Power and Light Company
W.S. White, American Electric Power Company, Inc 29
Harold G. Cassidy, Save The Valley 75
Tom Duncan, Kentucky Coal Association 83
W.C. Gerstner, Illinois Power Company 89
Damon W. Harrison, Kentucky Department of Energy 91
Fred Hauck, Save The Valley 97
Edward Light, Appalachian Research and Defense Fund, Inc 99
Walter A. Lyon, Pennsylvania Department of Natural Resources 103
Ralph Madison, Kentucky Audubon Council 105
A. Jenifer Robison, U.S. Congress Office of Technology Assessment . . . 107
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Jack Schramm, U.S. Environmental Protection Agency Region III
Rebecca W. Hanmer, U.S. Environmental Protection Agency Region IV
Valdas V. Adamkus, U.S. Environmental Protection Agency Region V ... Ill
W.S. White, American Electric Power Company, Inc 115
APPENDICES
A. QRBES Publications 127
B. QRBES Phase II Participants 133
VI
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Core Team Comments
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Robert E. Bailey
Director
The Ohio State University Program for Energy Research,
Education, and Public Service
Columbus, Ohio
Radioactive Release from Coal and Sabotage of the Nuclear Fuel Cycle
There is little question as to the validity of the statements within the ORBES
Main Report1* that air quality issues are the ones for which there will be greatest
concern in regards to energy development within the ORBES region during the period
in which the ORBES assessment was made. There are, nevertheless, two additional
classes of issues which were not mentioned but might become important in the future.
Both deal with nuclear radiation. One class of issues is related to the radioactivity
that is inherently contained within coal and thus emitted into the ecosphere when the
coal is burned. The other class is related to radioactivity released into the
environment that is initiated through acts of terrorism directed toward components of
the nuclear fuel cycle that presently exists within ORBES. These components would
be even more present under the Nuclear Fuel Substitution Scenario of the Fuel
Substitution Scenarios.
Coal and Radioactive Release
Recent studies of The Ohio State University, which were done as part of the
ORBES, indicate that, on the average, the concentration of uranium and thorium in the
coal used in the Basin is 1.65 and 4.86 ppm respectively.2 The ash content is
approximately 11%. The radioactivity associated with the coal leaves as part of the
ash, or as radon gas which is liberated from the coal as it is burned. The radioisotopes
that are emitted are those which are associated with natural decay chains from
thorium and uranium and furthermore, they are in secular equilibrium. In the case of
nuclear reactors, the radioisotopes emitted are those which are fusion products and a
few other activities such as tritium.
A comparison of the radiation doses received by persons within ORBES, living
near nuclear and coal-fired plants^, indicates that the population receives more
radiation from the use of coal than from a nuclear power plant operating within design
conditions. In all cases studied, the dose received was below the standards described
in Title 10 of the Code of Federal Regulations.
* Footnotes can be found at the end of this article.
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These results are in agreement with similar calculations done elsewhere.3
The radioactive release and corresponding radiation dose experienced by the
population from the burning of coal could become an issue if allowable levels of
population dose are lowered. It is conceivable that standards will be lowered as more
is learned about the health effects of low levels of radiation.4 At the present time,
coal is not considered a licensed material and thus the radioisotopes associated with
coal are not under the same regulations as those from a licensed material such as
uranium. This naturally leas to the question:
If radiation is harmful to human health, shouldn't regulations on the
control of radioactive release be directed toward the radioisotope and not
the source of that isotope?"
Should radiatioin dose from coal become an issue, this could have special significance
within the ORBES region since coal has such widespread use. Impacts would be felt
not only in emission controls to reduce the ash release to the atmosphere, but more
importantly, such regulations would impact on the storage of ash from many facilities
using large quantities of coal, since it can be demonstrated^ that the ash from a large
user, using basin coal, already exceeds limits for burial of radioactive licensed
materials as specified in Title 10, Chapter 20 of the Code of Federal Regulations.
Terrorism and Radioactive Release
As the ORBES Main Report states, there are three major processes of the
nuclear fuel cycle - uranium enrichment, fuel fabrication and power generation - that
exist within the ORBES region. Furthermore, a study of the tranport of nuclear
materials throughout the United States shows that nuclear materials are tranported
within the ORBES region.6 Each of the facilities associated with the nuclear fuel
cycle is a potential target for sabotage by terrorists or other types of disgruntled
persons, and could be a source of intentional radioactive release. This applies equally
well to vehicles used for the transport of nuclear materials, as well as for fixed
structures.
As a consequence of this realization, a vulnerability assessment of a nuclear
power plant, spent fuel storage facility, was performed on a plant located within the
ORBES region.7
These storage facilities were selected for analysis essentially for five reasons.
First, spent fuel is highly radioactive and can be quite lethal if improperly handled.
Consequently, its misuse could pose a significant health hazard to the general public.
Second, spent fuel is stored in areas which do not provide the same level of physical
protection given to the nuclear reactor itself. Third, and perhaps most important, the
uncertainty surrounding the status of waste disposal and reprocessing policies in this
country indicates that spent fuel inventories at reactor sites will continue to grow in
the foreseeable future. Fourth, as the debate over nuclear power in general - and
waste disposal in particular - heightens, spent reactor fuel could take on added
symbolic significance as a target. Finally, large, well-financed and sophisticated
terrorists organizations capable of complex operations exist. While the continental
United States has remained relatively immune from their attacks, the potential threat
these groups represent cannot be ignored.
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In performing the vulnerability assessment, it should be pointed out that only
non-classified sources and techniques were utilized. This was done in order to
establish the degree to which relevant information about a given site could be acquired
while working under these constraints. Potential adversaries could therefore avail
themselves to the types of material presented in this report without resorting to
provacative and risky intelligence collection methods.
The results of the study strongly imply that fuel storage facilities can be
vulnerable targets which allow an adversary the opportunity to release radioactivity
into the atmosphere using conventional explosives. Other direct consequences of
sabotage that need to be taken into account are the injury or death of plant personnel
due to an assault, radiological damage to property, non-radiological damage to the
plant proper, and the economics costs of cleanup and any required downtime.
Unlike their counterparts, the potential indirect consequences of a serious act of
nuclear sabotage will remain largely unrecognized until an act occurs. This is the case
since indirect consequences are contingent upon not physical laws, but human
response. This response in turn will be based on perceived rather than actual reality.
Where radioactive materials are concerned, the gap between these two could be quite
substantial. At present, the fear of radiation on the part of the general public could
be exploited. Writing well before Three Mile Island, Brian Jenkins offered the
following:
"almost any terrorist action associated with the words 'atomic' or 'nuclear'
automatically generates fear in the mind of the public...Nuclear power,
whether in the form of peaceful energy or weapons, is the most potent and,
to many people, the most sinister force known to mankind. Any sort of
nuclear action by terrorists would be assured of widespread publicity. It
would instill fear and create alarm...A well-publicized terrorist attack on a
civilian nuclear facility, even if the terrorists failed in their intended
mission, could be almost as alrming to the world as a terrorist success."8
More recent are the cogent statements of Kupperman and Trent:
"Vulnerability of an installation is both physical and symbolic...if a nuclear
power plant were attacked by a small band of terrorists bearing nothing
more than small arms and explosives, very little physical damage would
occur, but the symbolic effects - the hysterical fear of a core meltdown
with its insidious cloud of radioactive materials - would cause the severest
political ramifications and might force the industry to shut down partially.
Thus, it may not be enough to limit the potential for substantial physical
damage; we may need to win so overwhelmingly that the perceived damage
would be insignificant."9
Mitigating the perceived damage of an attack to the point of insignificance
would be a challenge indeed. In an open society, this is difficult to do for any major
terrorist event, much less for one having the sensitivity of a nuclear incident. The
adversary group itself should be expected to maximize the impact of their attack
through the media. Public panic, as well as governmental paralysis, may be principle
objectives.
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Regardless of specific outcomes, there is no doubt that the event wfll trigger an
increased awareness of the security issue at nuclear facilities. If the public perceives
that a serious attack has occurred, even if there is no radiological release and the on-
site security system effectively defeats the adversaries, claims will likely be made
that the industry was simply "lucky this time" and that the attack is a harbinger of
more serious episodes. If this view becomes pervasive, from a public relations
standpoint, the industry may find itself in a "no-win" situation. Criticism of the
industry would carry over to those who regulate it and set the security standards. It is
contended here that strong pressures for fixed site security upgrade would be
unavoidable, even if the then-present system successfully protected the installation.
This leads to the following significant question:
"Is it conceivable that there could be a measurable or even unacceptable
loss in civil liberties as the government increases its efficiency in
protecting citizenry from deliberate attempts to threaten and/or to cause
the release of radioactivity?"
This particular question has special significance for nuclear power plants when one
considers that not only are there safety analysis reports and environmental impact
statements that are public documents, but there are also public hearings for both the
operating and construction permits.
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FOOTNOTES
1. The CRBES Core Team, "Ohio River Basin Energy Study (ORBES): Main Report,"
Office of Research and Development, U.S. Envirnonmental Protection Agency,
Washington, D.C. 20460. November, 1S80.
2. Calculations were made using a modified form of the AIRDOS-II computer code.
The code was modified by incorporating submodels which, a) allowed it to
calculate doses from multiple sources located in varying geographical locations,
and b) allowed it to calculate regional doses based on averaged concentrations of
pollutant. A reference for the unmodified AIRDOS is, "The AIRDOS-II Computer
Code for Estimating Radiation Dose to Man from Airborne Radionuclides in
Areas Surrounding Nuclear Facilities," by R. E. Moore, et al., ORNL-5245 Oak
Ridge National Laboratory, Oak Ridge, Tennessee. 1977.
3. J. B. fcCeBride, et al., "Radiological Impact of Airborne Effluents of Coal and
Nuclear Plants," Science. Vo. 202, Pages 1045-1050 (December 8, 1978), and C.
E. Styron, et al., "Assessment of the Radiological Impact of Coal Utilization,
Report No. MLM-2514, The Manual Laboratory, Miamisburg, Ohio. February,
197*9.
4. Committee on the Biological Effects of Ionizing Radiations, "The Effects on
Population of Exposure to Low Levels of Ionizing Radiation," National Academy
of Science, National Academy Press, Washington, D.C. 1980.
5. K. E. Bailey, et al., "Wastewater Reduction and Treatment for-Synthetic Fuel
Processes in the Ohio River Basin," Water Resources Center, The Ohio State
University, Columbus, Ohio. 1979.
6. "National Energy Transportation," Committee Print for the Senate Committees
on Energy and Natural Resources; and Commerce, Science and Transportation,
Committee Print 95-15, Volumes I and II. May, 1977.
7. B. R. Narduli and R. E. Bailey, "Sabotage Assessment of Two Reactor Spent Fuel
Storage Facilities Found W ithin the Ohio River Basin," The Ohio State University
Program for Energy Research, Education, and Public Service, Columbus, Ohio.
August 5, 1980.
8. Brian M. Jenkins, "WQl Terrorists Go Nuclear?", P-5541, (Santa Monica, CA: The
Rand Corporation, November, 1S75), pp. 4-6.
9. Robert K. Kupperman, Darrell M. Trent, "Terrorism: Threat, Reality,
Response", Hoover Institution Press (Stanford University, Stanford, CA, 1979), p.
103.
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Hugh T. Spencer, Sc.D.
Gore Team Member
Department of Chemical and Environmental Engineering
Speed Scientific School
University of Louisville
Louisville, Kentucky 40292
The National Environmental Policy Act, our landmark legislation for en-
vironmental protection, was signed into law 1 January 1970, just eleven
years ago from the time of this writing. Thousands of environmental impact
statements have since been written; and the ORBES project, although some-
thing different, was spawned of public interest in the environmental impact
analysis movement of the 1970"s. It was to determine the impacts on the
Ohio River Valley of plausible energy futures through the year 2000. Were
the futures chosen by the Core Team plausible, and were their impacts
assessed with known accuracy? These questions will be debated for as long
as the study generates interest, which may well be for some time to come.
Debate over ORBES is nothing new. The Core Team, along with its manage-
ment group and advisory ccnmittee, fought over issues of scenario plausi-
bility and method validation for four years. Indeed, the ORBES project was,
within itself, a study of debate and contest, and this discussion was open
at all times to all takers. We kept no secrets, made our results available
to everyone as they became available to us, and thus made few friends while
engendering the rath of many. To this day, some of our colleagues insist
we selectively leaked self-serving information along the way. That is not
true. Keeping the study open, as in a fishbowl, was to us, however, a more
important consideration than keeping our critics appeased. The issues
raised during the course of the study were profound and could never have
been laid quietly aside anyway, no matter how preliminary the data seemed
to be. Wa could never have allowed the public's windows into the study to
be closed, nor would any attempt to do so have been acceptable to the
Valley's citizenry or our Congress.
I worked over my part of the ORBES main report for many months, and I
have reviewed with care the work of my colleagues. I am proud of the report
as published and ask that it be taken as my comment for the record. Also, I
look forward to the debate raging on, as we all know it will. Ours is a
house with many windows, and so long as those vested with authority, be
they elected officials, utility executives or college professors, use it
fairly, we will succeed.
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Support Researcher Comments
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E. Earl Whitlatch
Associate Professor
Department of Civil Engineering
The Ohio State University
2070 Neil Avenue
Columbus, Ohio 43210
My comments deal with four related topics: 1) the original, motivating
force behind the ORBES study,- 2) public participation in power plant siting
in the ORBES Region, 3) the apparent over-emphasis of air quality aspects in
the Main Report, and 4) techno-orgam'zational strategies for problem resolu-
tion in the ORBES Region.
Motivating Force. Concerning the first topic, the original motivating
force behind the ORBES study, it is noteworthy that in a careful review of
the Main Report, one is unable to find any meaningful reference to the topic
of public participation in power plant siting in the ORBES Region or else-
where. Indeed, one cannot even find the terra "public participation" any-
where in the report. Reference to the fact that public pressure initiated
ORBES is found only in a brief statement in the Concluding Note (Main Report,
p. 295). I am therefore concerned that one of the principal motivating
forces behind ORBES, i.e.; public dissatisfaction with its role in the energy
facility siting process, has been overlooked to a large degree in the final
report1.
It is inaccurate to say that the principal reason for QRBES was to
address the issue of an apparent lack of coordination in the siting of new
power plants in the Ohio River Valley (Main Report, p. 295). I am convinced
that the central issue indicated by the public in calling for the ORBES effort
was not "regional coordination", but something much more subtle and ultimately
more important. An in-depth study of six case studies of new power plant
siting in the Ohio River Basin by this author reveals that the central ele-
ment causing dissatisfaction on the part of public participants is the un-
avoidable feeling that they are powerless to affect the final siting decision
or. indeed, any aspect of it. In such a context, "regional coordination" is
the ultimate luxury in a world wherein even the most basic facts concerning
environmental and social impacts of a proposed plant are unobtainable until
years after basic permits have been secured and large dollar investments have
been made.
The motivating force behind ORBES therefore relates to an apparent lack
of meaningful public participation in power plant siting in the Region, which
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in turn engenders discontent among parties that have tried to influence the
siting decision.
Public Participation.
The causes of this lack of power are many, and have been investigated
elsewhere1. Principal among these are 1) regional siting studies conducted
by the utility wherein public representatives are excluded, 2) utility
maintenance of confidential regional siting study reports, 3) the purchase of
land and conduct of significant site construction work before environmental
reviews are complete, 4) public service commission permit reviews that are
both brief and limited in scope, 5) lack of technical expertise and inade-
quate staff size found in state public service commissions, 6) lack of
expertise found on the part of environmental groups in certain technical
areas related to electricity generation and transmission, 7) costly and
formal adjudicatory proceedings by certain agencies, which are held late
in the siting process, 8) lack of public information until after the Draft
Environmental Impact Statement is issued, 9) inadequate information transfer
to the public throughout the siting process, and 10) lack of National,
generic policy statements with which to guide individual siting studies, to
mention only a few.
It is this author's firm conclusion that any proposed institutional
solution be viewed first in the light of whether it would serve to correct
the current atmosphere of mistrust which exists between utilities and envi-
ronmental and other citizen groups. Such mistrust stems largely from inade-
quacies of the current siting process as cited above, all of which could
perhaps best be viewed as originating from a closed decision-making process,
as opposed to an open one.
Put another way, it is not clear that any new institutional structure is
needed; rather, what j_s_ clear is that current procedures must be changed to
incorporate aspects of a decision-making process more open to the public.
Air Quality.
Third, air quality seems to be used in the Main Report as the principle
justification for a regional coordination mechanism. I am both impressed
and unimpressed by the arguments given along this line. First, the
ORBES air quality studies show, as documented in the Main Report (pp. 11-17),
that under all of the coal-dominated scenarios sulfur dioxide and particu-
late emissions will decrease substantially from 1976 levels by the year 2000.
The Report (p. 221) indicates, however, that this will still result in l)the
continuance of some episodes of poor air quality both inside and outside the
Basin, 2) the maintenance of a few "hot spots" of air pollution in the Basin
and 3) a decreased but perhaps still significant level of long - range trans-
port of air pollution.
Hlhitlatch, E. Earl, and John A. Aldrich, The Ohio State University, Energy
Facility Siting Procedures, Criteria, and Public Participation in the Ohio
River Basin Energy Study Region (ORBES Publication. Phase II, Grant Nos.EPA
R805589 and R805603, August, 1980, 112pp).
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The first two air quality problems cited above, episodic conditions and
local "hot spots", do call for some degree of regional coordination, but it
would appear that corrective measures for these conditions could be achieved
without the creation of a strong regional body. Rather, a "loose" regional
coordination system would suffice, one which does not have a large adminis-
trative overhead. Existing institutions could be used for most analysis and
interpretation.
The problem area of long - range transport of air pollutants also calls
for some degree of regional coordination, but the problem itself is not
currently well understood. It would be premature to create an institutional
structure to deal with a problem not yet entirely defined. Any discussion of
potential effluent limitations could certainly be conducted without a regional
organization. If some reductions were necessary, regional coordination might
then be useful to achieve the desired total effluent reduction. Again, how-
ever, a strong regional entity may not be needed to achieve these reductions
(see below).
Techno-Organizational Strategies.
This author is not an institution builder; however, it would seem that
subregional institutions could operate within the framework of Federal and
state policies on air quality. This would have the advantage of placing
siting decisions closer to those affected by the decision. It must be remem-
bered that air quality is only one of many criteria used for the siting of
power plants. The public has a right to express its concern on criteria
other than air quality. More than this, the essence of the problem is in
allowing the public to express its concerns conveniently, directly and mean-
ingfully. Such expression is difficult, even under the current decentralized
system. Placing the energy facility siting decision more remotely at the
regional level at this time would probably only exacerbate this problem.
(In passing, it may be useful to observe that, of the regional organizations
mentioned in the Main Report, ORSANCO seems to have most earnestly conducted
public participation activities, at least in its formative years). Sympto-
matic of the institutional emphasis on regional forms in the Main Report is
the fact that utility initiatives in other states, some involving significant
public involvement, have not been discussed.
It would seem that a start at obtaining meaningful public participation
could best be achieved at the subregional level; in fact, at the utility
service area level. As confidence is gained by both utilities and the public
in their ability to communicate and negotiate effectively, movement toward a
more regional coordinating system would be possible. As an example, an open
siting process undertaken by two or three utilities acting together could
probably avoid the problem of local air quality "hot spots" in the Basin.
Once this level of coordination and public participation were achieved, co-
operative action by utilities acting through an organization such as the East
Central Area Reliability Council might enable an alternative such as least
emission dispatching of electricity to deal with episodic periods of poor air
quality caused by adverse atmospheric conditions. As further experience by
the industry is gained, an acceptance of more extensive coordination of
15
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siting of new power plants might be possible, as well as consideration of
regional means to reduce the total level of emissions on a permanent basis
through the most cost-effective means. In fact, voluntary utility coordina-
tion in the latter case (total effluent reduction) would be likely, since it
would be in their own self-interest to jointly cooperate in reducing the total
cost of meeting effluent limitations.
Conclusion.
It is emphasized that the key conclusion from observing case studies of
power plant siting is that dissatisfaction with the energy facility siting
process arises principally from the feeling on the part of public participants
that their comments have no effect on the final siting decision, and that in
fact their comments are received only after the siting decision has in essence
been made. In any discussion of alternative institutional forms, therefore,
much attention should be given to the quality of public participation that
might occur under the alternative forms. I find such a discussion lacking in
the Main Report. If present, much more attention would have to be given to
private (utility) alternatives.
16
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Advisory Committee Comments
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Valdas V. Adamkus
Acting Regional Administrator, Region V
U.S. Environmental Protection Agency
Chicago, Illinois
The Ohio River Basin Energy Study (ORBES) Main Report authored by the
thirteen members of the ORBES Core Team, dated November 1980, has been
reviewed by twenty-one Regional Technical and Management Staff members in
Region V. Because of the broad interest in the ORBES Project expressed
in Region V from its inception, it was decided that comments on all technical
areas of the Main Report and pertinent supplementary ORBES Research Reports
and selected general comments on the study as a whole, except those related
specifically to air quality, would be discussed directly by Region V here.
Comments provided by the Region V staff on air quality and related environ-
mental impacts discussed in the ORBES Main Report have been combined with
corresponding comments from Regions III and IV and will appear elsewhere
in this volume as a Tri-Regional Response.
This study was initiated by congressional action resulting from con-
cerned citizens in the Ohio River Valley convincing their legislators that
a rapidly growing problem in their area was one with which existing controls
could not cope. Their legislators are to be commended for their action in
responding to the citizens in directing the USEPA to conduct a thorough
investigation of the overlapping "potential environmental, social and
economic impact of a proposed concentration of power plants in the lower
Ohio River basin." The cross-impact evaluation of this complicated inter-
disciplinary series of problems provided by the Technology Assessment
approach used by the ORBES Core Team has served the need well.
Co-directors of the project Dr. James J. Stukel and Dr. Boyd R. Keenan
are to be commended for their ingenuity and research management accomplish-
ment in developing the unique organization and procedure used in this study
and described in the report. The Core Team members, also including
Drs. Stukel and Keenan, have produced an impressive Main Report and
auxiliary supporting reports covering every discipline represented by
the Core Team membership and the Support Researcher Roster.
The Ohio River Basin Energy Study has certainly identified and brought
into better focus many of the major factors, and in some instances the sub-
merged sub-structures, that are contributing to the escalation of some very
real and potentially major issues relating to the Ohio River Basin in parti-
cular and to the huge overriding problems orginating from energy development,
while protecting the health and welfare of the citizens in all areas of the
nation. The Executive Summary of the Main Report (Pages 3 to 42) represents
19
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a commendable job in summarizing the critical issues identified. The
Concluding Notes section (Pages 41-42) summarizes in less than a page some
key issues and some key contributors to these issues and ends on an
optimistic note that solutions can be found. The succinct comments on
those pages will, in all probability, challenge legislators and the public
alike to delve more deeply into the contents of both the Main Report and
the support documents. As stated in these pages, the solution to these
problems and issues must without doubt be the result of cooperative effort
from everyone involved - legislators, governmental units and officials at
all levels, industry and private citizens. Whether the readers agree with
all of the various segments of the many ORBES reports or not, it is our
opinion that the Concluding Notes demand the attention and solemn
consideration of all of us.
A major driving force that prompted Regional Management to initiate
strong participation in the ORBES project was the expressed citizen
interest in potentially serious environmental problems related to power
development. The support of citizens and environmental organizations in
Region V along the Ohio River in their effort to obtain more information
about their potential problems and possible alternative solutions has
always been a major interest in this office. Also, a continued effort is
considered essential to be certain that citizens have available to them
the necessary scientific and engineering support needed and to help keep
them continually aware of the several opportunities citizens have for
impacting environmentally sensitive developments in their area during the
planning and pre-construction stages.
Although there are several built-in opportunities for citizens to
be heard by those authorities responsible for controlling environmental
impacts, these opportunities are often buried in legal red-tape. One such
opportunity that exists during the planning stages of all environmentally
impacting projects was not properly referenced by the ORBES reports. We
would like to discuss it here briefly for the benefit of those who may want
to utilize the opportunity in the future. The most recent Council on
Environmental Quality Regulations on the Preparation of Environmental
Impact Statements sets into place the scoping process for major Federal
actions significantly affecting the environment. Most coal-fired power
plants will have an Environmental Impact Statement prepared on them,
therefore scoping would be required.
The scoping process is to be an early and open process for determining
the scope of issues to be addressed and for identifying the significant
issues related to a proposed action. It would appear that the EIS and
scoping process, if applied as intended, could be the focal point for all
persons concerned. Some of the scenarios indicate there would be a signi-
ficant impact upon the environment from the construction and/or operation
of some of the new installations considered in the ORBES report. If an
environmental impact statement was written for a power plant which indicated
a violation of Federal law, regulation, or executive order, our Agency would
have to indicate its objections to the project and recommend either changes
in design, or that the project not be built. In order to construct and
operate plants with these adverse impacts, major changes in the Clean Air
20
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Act, Clean Water Act and other regulations would be required. We encourage
citizens to become better informed on this powerful tool presently at their
disposal and to make use of it whenever it is justified.
It would appear that strict environmental controls and the energy
conservation alternatives will provide significant environmental benefits,
with costs in the same range as the high energy development and electrical
exports scenarios (see figures pages 24 and 25). When public health,
worker health, water quality and agricultural impacts are taken into
account, the question becomes paramount as to whether the benefits of
meeting the environmental requirements are significantly more costly for
the total population of the ORBES region than the SIP-non-compliance
situation.
We note with great interest the various discussions of land use, as
well as, those on physical crop loss. The potential demand for the disturb-
ance of crop lands for mining, for power plant sites including water
reservoirs for cooling systems, coal storage and similar uses, when added
to the loss or decrease in crop production because of air and water impacts,
all present a very disturbing picture. The loss of prime agricultural land
has become a concern of many top agriculturists and of the Council on
Environmental Quality. The Council on Environmental Quality has issued a
report on the need to conserve this land resource. It may become necessary
to include with the present considerations of power plant impacts on air
and water and the disposal of wastes, a consideration of the type and
quality of land where the proposed plant is located.
One additional comment regarding conservation measures in general is
in order. Region V has been very critical of water users that require a
significant amount of a river's flow to supply its cooling water needs.
To minimize the amount of water withdrawn from a river, additional
conservation measures have been required at such sites, for example,
the use of off stream reservoirs (cooling ponds), cooling towers and
recycling of cooling water. Some of the plant sitings suggested in this
study could be rejected on the basis of excessive demand on a stream.
A review of the water quality aspects of this report and the reported
impact of power plants in certain localities has presented some questions
about whether the techniques used actually evaluate the total environmental
impact such an installation can have on both water quality and aquatic
habitats. The Main Report addressed only the impacts resulting from power
plant pollutant loads, and water consumption. Furthermore, the document
dealt only with impacts occuring during 7 day-10 year low flow conditions
(Page 88), and discussed those impacts in terms of entire rivers or the
entire ORBES Region (Page 57). These factors all tended to minimize the
impacts of power plants on water quality and aquatic habitats. The signi-
ficant conclusions that resulted from this are:
1. None of the ORBES coal dominated scenarios (Page 29)
would result in aquatic habitat impacts very different
from those that could have occurred in 1976 under 7 day-
10 year low flow conditions;
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2. Pollutant loading from power plants (Pages 29-30,152)
is not a significant factor in the impacts on ORBES
streams during 7 day-10 year conditions because of
current high pollutant concentrations; and
3. Although power plant water consumption (Pages 30-51,152-
169) might be an important factor on some of the region's
smaller streams, it is only because of the existing high
pollutant concentrations in those streams, and therefore,
once again, the high existing levels are the most important
cause of aquatic habitat impacts.
The comment should also be made that several of the parameters
indicated to have been violated at 7 day-10 year conditions in the various
Ohio River Basin streams are not acute toxicity parameters, but long term
safe levels. Short term violations of these "safe levels" are not too
likely to yield long term damage.
In our opinion, it is a mistake to minimize the aquatic habitat
impacts of power plants. On a regional basis they may not seem significant
but the localized impacts can be important. The ORBES report indicates
that for the most part, uncontrolled power plant effluents would not
significantly contribute to the impacts incurred by ORBES streams during
7 day-10 year low flow conditions, and that impacts related to power
plants are "rather minor" (Page 153). The local impacts of uncontrolled
power plant effluents can be substantial. Such discharges would cause
water quality standards violations, even during normal flows, that could
be devastating during low flows. In these cases the power plants would
not just be contributing factors, they would be the primary cause of the
impacts. Furthermore, the power plants can cause other aquatic impacts not
necessarily related to water quality. The most important of these are
impingement and entrainment of fish and other aquatic life, but habitat
destruction and modification can be locally important. All of these
localized impacts (water quality degradation, impingement, entrainment,
and habitat modification) can significantly affect aquatic community
structure and can be extremely important when rare or endangered species
are involved.
The combined effects of localized water quality degradation, impinge-
ment and entrainment, and habitat modification could cause the loss of
species, or promote the dominance of undesirable species. This is why
power plants are controlled both through the Environmental Impact State-
ment process and NPDES permits.
The same concern pertains to the use of 7 day-10 year low flow
conditions to describe aquatic habitat impacts. This tends to mask the
adverse impacts of power plants because so many factors combine during
low flow to impair aquatic habitat quality that the power plant impacts
are a somewhat minor incremental addition that do not really increase the
total impact. In other words, the impact on the stream is going to be
severe at 7 day-10 year low flows with or without power plants. The
conclusion that follows this line of reasoning is that power plant
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Impacts are not significant. As already discussed, we disagree with
this conclusion because of the potentially severe localized impacts
that can occur during any flow level. They will be most severe during
low flows, but they will occur all the time and be directly due to power
plants.
Another concern we have with the Main Report is the rationale for
projecting future pollutant concentrations. The report states that the
overwhelming majority of the present high pollutant concentrations result
from geochemical or nonpoint sources. Furthermore, it was considered
unlikely that nonpoint sources can be brought under control during the
time frame of the ORBES study period. Therefore, all of the scenarios
except the strict environmental controls scenario assumed that pollutant
levels will be the same in the year 2000 as they were in the mid-19701s
(Page 152). The strict controls scenario assumed a 50% reduction in
pollutant levels but stipulated that this is not likely to occur. They
found that even with this reduction, there would be little change in
aquatic habitat impacts under 7 day-10 year low flow conditions.
Perhaps on a regional basis, the non-point source (NPS) problem is
greater in the ORBES Region than point source problems, but on a stream
reach specific basis, point sources are the most significant pollution
sources in many cases and their impacts should not be minimized. It is
another artifact of the regional approach of the ORBES study that existing
pollutant concentrations cannot be reduced in the next 20 years to a
level that will beneficially affect aquatic habitat impacts that occur
during 7 day-10 year low flows. Progress is being made in the control
of industrial and municipal point sources, and efforts are getting underway
to control NPS pollution as well. Considerable effort is being invested
in the control of urban storm runoff, one of the primary contributors of
the 20 contaminants studied by ORBES.
The Main Report stated that even if these pollution control efforts
should result in a 50/6 reduction in pollutant levels, there would be little
change in habitat impacts (Page 152). In fact, under the strict environ-
mental control scenario (50% reduction in pollutant levels, 95% reduction
in power plant effluent concentration) only four streams would improve
(Page 184), with impacts changing from heavy, if pollutant concentrations
are held constant, to moderate, if concentrations decrease by 50%. This
lack of significant improvement can be traced in part to the methodology
used. The aquatic habitat impacts were based on a calculated water quality
index (Page 95). A water quality index of less than 10 resulted in light
impacts; an index of 10 to 24 resulted in moderate impacts, an index of 25 to
49 resulted in heavy impacts and an index of 50 to 100 resulted in drastic
impacts (Pages 95-96). So, in order to change the aquatic habitat impacts,
the water quality index has to change from one of these ranges to another.
The strict environmental control scenario (Page 184) would significantly
improve the water quality index of many of the 19 streams intensively
studied, without quite lowering the index to the next lower range. For
example, the second greatest improvement would occur on the Great Miami
River. Under the strict control scenario, its index would decrease from
47 to 25. Since 25 is the lowest value still considered to be in the
23
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heavy impacts range, the Great Miami is listed in the report as having no
impacts improvement under strict environmental controls. In all, under
strict controls, 8 streams would have their indices lowered to 25, and
were listed as having no impacts improvement.
If the indices had been reduced by one more increment to 24, these
8 streams would have had impact improvements, and the beneficial effect
of the strict environmental controls scenario would apparently be much
more significant than reported. The point is, it is unrealistic to put so
much emphasis in an arbitrary assignment of severity of impact. An actual
listing of the index changes that could occur under strict environmental
controls shows that every stream improved except one, and that one remained
the same. So perhaps the strict environmental controls would be more
effective than noted in the ORBES Main Report.
Another aspect of the ORBES methodology that lessened the beneficial
effect of the strict environmental controls scenario was the manner in
which it sited power plants. Some streams were assigned more power
plants under the strict controls scenario. For example, the Allegheny
River improved from an index of 32 to 25 with 4 power plants added.
If no plants were added that stream might drop to well within the moderate
impacts range. In all, 8 streams had power plants added and 4 had plants
removed. In summary, our comments, therefore, point out that the strict
control scenario would result in habitat improvements that would be stream
reach specific.
A question has been raised in this office regarding the assessment
of the status of aquatic populations in the Ohio River and many tributaries.
Reliable data on this subject is considered to be very hard to find. It
may be of interest to mention that the Permits Branch, Enforcement Division,
Region V has a study in progress to determine and map fish populations in
the Ohio River. A report on this study is expected to be available in
six to nine months from now.
It is recognized that some of the comments on water, aquatic habitats
and aquatic life portions of this report are perhaps raising issues that
cannot be corrected at this time or may not be considered a part of this
study. All of these comments are being offered for the possible benefit
they may offer in utilizing the above discussed sections of the report and
possibly in guiding future investigations on these subjects. We realize
that the regional approach of this study influenced the methodology used
and the conclusions drawn from it. Other studies may be needed to further
clarify certain details in this technical area.
A review of the discussions of economic issues in the various parts
of the Main Report has raised several questions. Some of them are discussed
here to call attention to the fact that, although the findings reported in
this study may not be in question, this is one instance where updating of
baseline data may be beneficial in the utilization of this information,
particularly for guidance of congressional action. Adoption of the
mid-1970's as a base period does not necessarily reflect current conditions
in the ORBES Region. Furthermore, the use of historic data up to the
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mid-1970's for the establishment of social and economic trends excludes
possible changes in those trends in the late-1970's. Changing social and
economic conditions of the late 1970's could have an effect on the study
results. It must be recognized, however, that this constraint was a
necessary one on a study of this size and scope. The large number and
variety of elements included in this study constrain the use of later
data, even when it is available. One factor is the timing of the basic
social and economic indicators necessary as inputs to other parts of the
study. Also, to update these elements as new information becomes available
could prove to be a hindrance to the overall study effort. Another factor
is the desirability for consistency in the data bases used. Social and
economic indicators vary in the amount and kind of data available and the
years for which it is available.
One example of such indicators is population projections; some of
these projections have been updated from those used in the study. Another
example is the use of mid-1970's industrial data for the fuel demand
portion of the study. How much effect changes in these elements could
have on the study results is difficult to determine.
Of possible significance to the study and its results is the assumed
projected average annual economic growth rate for the ORBES Region. A rate
of 2.47 percent was assumed for all scenarios. This percentage resulted
from a study of gross regional product trends from 1960 to 1975; it was the
average annual growth rate during that time period (Gross Regional Product
in the Ohio River Basin Energy Study Region 1960-1975, by Walter Page and
John Gowdy). Use of this rate to project growth could overstate future
economic growth in the ORBES Region. First of all, the authors of the
study on gross regional product state that trend analysis is not very
useful for best estimates of future values and that historic trends are
most useful as a "high" boundary for growth projections. Additionally,
post-1975 information was not included; estimates of recent trends have
been excluded. Hence, all scenarios must be viewed as incorporating a
"high" growth boundary rather than a "best estimate" of future growth.
Potential error in this regard could have been partially offset by
inclusion of a "low-growth" scenario in this final report. If lower growth
in the ORBES Region is supported by post-1975 information, a "low-growth"
scenario might move toward a more realistic projection of future conditions
than does the base case. Relative to the base case, earlier reports show
that lower growth rates could lead to lower growth in electricity supply
and demand, coal use, emissions, costs, and impacts.
Existing power plants are assumed to purchase coal from the same
supply sources as they did in 1976. Supply shifts occurring since 1976
are not reflected in the base case or in the other scenarios. Shifts
within the ORBES Region and between the ORBES Region and other parts of
the country to comply with sulfur dioxide requirements could have occurred
after 1976. Whether the adopted assumption is realistic depends upon the
nature and extent of such supply shifts.
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An additional assumption is that low sulfur coal for planned power
plants will be supplied within the ORBES Region from sources in Eastern
Kentucky, West Virginia, or Pennsylvania. This assumption could under-
estimate the ORBES region demand for low-sulfur western coal.
Assumptions regarding the use of low sulfur coal relative to flue
gas desulfurization to meet pollution control requirements have an effect
on the cost estimates. These two strategies are reflected differently in
capital and operating costs. The Main Report emphasizes capital costs
in the scenario analyses, while operating costs are reflected in the
consumer cost estimates.
In the analysis of other than "coal dominated scenarios" there is
an emphasis on the effects of reduced coal usage. There are many unknown
factors associated with other possible effects of these scenarios, such
as positive employment impacts of alternative fuel usage, health impacts
of nuclear generation, air quality impacts of biomass usages, etc. Thus,
of necessity, many potentially significant impacts may be excluded from
the analysis of these scenarios. It is important to recognize that these
effects, though currently unknown, could become relevant future
considerations.
In any analysis of pollution control costs and impacts, the results
are usually related to the basic assumptions regarding environmental
quality and needed pollution control. Resulting impacts are ordinarily
highly sensitive to such basic assumptions.
In discussing pollutant emission standards, the study's approach is to
compare baseline conditions to those of the Base Case Scenario, which is to
be a continuation of present regional conditions. The Base Case environ-
mental standards are defined in the study as those standards that currently
exist as applied to present and future sources of pollution. For air,
controls are defined as the application of "current" (as of Sept. 1978)
State Implementation Plans (SIPs). However, significantly revised SIPs
were submitted in 1979. These revisions could substantially alter impacts
defined in the Base Case and subsequently affect assumptions in the
various scenarios. The revised SIPs would have an effect on the following
statements and assumptions in the study:
a. The impact of acidic precipitation (P.74)
b. The estimates of emissions of sulfur dioxide (P.70),
total suspended particulates (P.73) and nitrogen
oxides (P.80)
c. The SIP Noncompliance Case (P.188)
d. Cumulative pollution control costs (P.160)
The report addresses the comparative costs and associated electricity
prices for coal versus nuclear generation. One key finding was that under
current fiscal and regulatory schemes in the region, coal fired units have
26
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a cost advantage over nuclear fueled units. The study notes that government
subsidy in the form of insurance premiums provided nuclear developers and
extensive governmental research and development in the nuclear field
constitute a major subsidy for the nuclear industry not extended to coal
producers. It is not clear if these subsidies are built into comparative
costs or if the pollution control costs for coal fired units are accounted
for. Further, if the additional cost of more stringent pollutant emission
standards as a result of revised SIPs are added to the costs of coal fired
units the comparative costs may be substantially altered.
The environmental, economic and social impacts are examined in the
study in the context of a number of potential policies. Of the various
scenarios presented and analyzed in the report, the following specific
policies presently under consideration for implementation were not examined
or considered:
a. The new particulate standard
b. The additional control on fine particulates proposed
for 1981
c. The oil "back out" legislation and mandatory conversion
orders
We certainly appreciated the opportunity of participating in this study
and especially in the review of this and other reports in both their draft
and final forms. It is our opinion that this inter-disciplinary study will
provide useful service to the Members of Congress, Federal and State
agencies and the public in formulating future plans for the ORBES Region.
While we do not agree completely with all of the contents and the conclusions
of the Main Report and the support studies, that is not particularly
disturbing to us. In fact, it is quite probable that some of the individual
parts of some scenarios would constitute a violation of existing environ-
mental laws if carried out as described. It should be kept in mind that
these scenarios are "what if" studies of what impacts would occur if certain
things are done in the future. They are not predictions, or accomplished
facts, or even recommendations. This thought is recorded throughout the
ORBES documents. Furthermore, we are aware that the material reported
represents the best judgement of experts or the consensus of experts in
the various disciplines represented. However, we do not consider ourselves
bound to accept it or make use of any single idea: and we recommend others
consider the contents of these reports in the same way, using them as your
judgement dictates. We plan to make the best possible use of these findings.
Since the starting date of this project, other energy related developments
have come to the foreground, for example, synfuels development. Also, these
studies have helped to emphasize potentially critical occurrences such as
acid rain and trans-boundary transport of air pollutants. The findings of
ORBES researchers will be very useful in the future investigation of all of
these items related to coal utilization. We commend all of those who
participated in this study for their part in /
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Utility Industry Advisors'
Comments on ORBE5 Analyses
"r. J.P. Apel, Columbus & Southern Electric Co.;
Mr. F.A. Baker, Public Service Indiana;
Mr. VT.C. Cferstner, Illinois Power Ct>.;
Mr. 0. Lentz, ECAR;
Mr. P.A. McKnight, Indianapolis Power & Light Co.; and
Mr. V.S. Miite, American Electric Power, Oonpany, Inc.
i. iwTBDDPCTKfr? APD SCOPE
These comments discuss many of the technical issues raised in the
OFBSS Main Report and the numerous backqround documents. The comments
are based on a number of detailed, technical analyses, several of which
are or will be part of the ORBES docket. Tliese analyses and the utility
industry's comments are presented more fully in a separate integrated,
technical critique of ORBES: Utility Industry Advisors' Detailed
Comments on ORPES Analyses. This criticrue and the individual technical
analyses are available to the interested reader and are incorporated
herein by reference.
These comments are organized into three major sections. Following
this Introduction, Section II rejects the implication qiven in the
foreward to the Main Pftport that the utility industry somehow agrees with
ORBES. Section III gives a number of examples illustrating the major
scientific and factual deficiencies which infect ORBES rendering, it
unsuitable for use in any public proceeding. The brief space available
here and the nuirber of the deficiencies make it impossible to present an
exhaustive list.
II. THE UTILITY INDUSTRY ADVISORS REJECT THE ORBES IMPLICATION THAT
PARTICIPATION SUGGESTS AGPEEMQTT; TOE SH1DY IS INFECTED TOTF A
BIASED, MISLEADING PERSPECTIVE
The foreword to the Main Report congratulates the ORBES Core Team
for its "open research process." Id. at 3. The reader is told:
The project Advisory Committee, drawn from groups expected to be
affected by regional energy development [including the utility
industry], was an especially important part....rT]he functions of
the Advisorv Committee...\included] the opportunity to participate
in the internal project meetings and to review research reports in
draft. Id.
The implications that the utility industry had a meaningful opportunity
to correct ORBES1 technical shortcomings and that the industry's
participation in the study indicates concurrence must be corrected.
The Advisors did provide meaningful comments on research reports
and, when requested, participated in Core Team meetings. However,
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operating in this manner does not imply agreement.
The Advisors' comments were often disregarded and, in the case of
the air quality modeling studies, the Advisors' efforts to obtain
necessary information were severely hampered. After repeated requests
for information on the study modeling techniques, the industry resorted
to a Freedom of Information Act request to compel disclosure. Even this
request was denied and the industry was forced to litigate the refusal.
Public Service Indiana v. EPA, Civ. No. IP79-315-C (S.D. Ind. filed April
3, 1979). The complete information has never been obtained.
The Main Report is plagued with a sloppy, often editorial character
which misinforms and misleads the reader. A few examples are:
. Fbreward, id. at 1 - "concerns about plans for accelerated
power plant development." There is no accelerated development
plan; power plants are constructed in response to demand for
electricity.
. Executive Summary, id. at 22 - "increasing evidence ...
[supports the hypothesis that] exposure to sulfates ...
results in an increased mortality rate." Even the body of
Main Report and the background documents do not support this
statement. See Section III-D, 1. infra.
. Id at 275, 277 - Solar power should be benefitted by "tax
incentives", whereas nuclear power should not receive "tax
subsidies." These are merely loaded words to express the
researcher's preference for solar power. The same kind of
transaction is described by each.
. Id at 65 - "2 Btu's of conventional fuels to produce 1 Btu of
electricity." For a good coal or oil-fired plant the ratio is
about 2.9 Btu's to 1 Btu of electricity.
III. ORBES AND THE MAIN REPORT ARE INFECTED WITH BASIC ERRORS OF SCIENCE
AND PRESENT DISTORTED CONCLUSIONS; THEY SHOULD NOT BE CONSIDERED IN
ANY PUBLIC PROCEEDING
A. Summary and Organization of Illustrative Technical Comments
It is not the contention of these comments that all of the
information and all of the study techniques used in ORBES are incorrect.
Some distinguished investigators took great care in studying real
scientific questions and arriving at reasoned scientific conclusions.
Lamentably, however, great portions of the ORBES work and much of the
Main Report contain such serious scientific defects and present their
results in such a misleading light that they cannot be relied on without
an independent analysis of their accuracy.
The following technical sections illustrate the major scientific
30
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defects which infect ORBES. These defects can be organized into six
general categories:
* Inconsistencies between the Main Report and the
supporting background studies;]/
* Fundamental errors of scientific theory;.?/
* Fundamental errors of fact and application;!/
* Use of outdated techniques and assumptions — not
state of the art;*/
* Distorted and misleading presentation;!/ and
* Study design not meaningfully related to policy
guestions.2/
following sections begin with a discussion of the
deficiencies in the study plan. Subsequent sections analyze
the ORBES treatment of atmospheric emissions, their transport
and transformation, and the health and economic affects of the
projected ambient concentrations.
B. The Study Design and Presentation of Results Frustrate
any Meaningful Evaluation of Current Policy
Concerns _
1. Introduction
ORBER purports to be a comprehensive study which ties together
information from disperate areas in order to provide decision makers with
meaningful information about alternative energy development policy
options. Main Report, Foreword at 1. In order to accomplish this goal,
I/See Section III-E, 3. The Main Report presents crop damage
estimates which are inconsistent with the background documents.
j/See Section III-E, 4.2. ORBES employed an ozone analysis
technique which can predict effects contradictory to the real world and
the predictions of accepted scientific techniques.
I/See Section III-D, 3. Tlie Main Report miscalculates the
"expected cancer rates" for radiologically induced cancers by a factor of
10,000 because it misinterprets its own results.
I/See Section III-E, 4.1. ORBES researchers employ a two point,
70-year ozone estimating technique in preference to a theoretical ozone
model.
5/See Section III-F, 2. ORBES overestimates the extent of the
least emission dispatch emission reductions. See Section III-C, 3.1.
The ORBES Main Report misleads the reader concerning the techniques used
in modeling long-range transport of sulfur dioxide.
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the study design must be organized to produce meaningful information, the
study must be carried out using meaningful techniques and the results
must be presented in a meaningful form. The first and third points are
briefly considered in this section; the second is disscussed beginning at
Section III-C.
2. The ORBES Study Design Does not Pose Key Questions Necessary
to Produce Meaningful Results for Policy Evaluation
Any study that strives, to be "useful to decisionmakers in dealing
with policy and regulatory strategy issues", Main Report, Foreword at 1,
should strive to answer the following questions: (a) How much is enough
and (b) How do we get from where we are (or expect to be) to where we
want to be through the cheapest, and least disruptive means. The
omission of these questions from the ORBES inquiry is a major
methodological flaw which seriously limits the study's usefulness.
Because the study fails to ask the first question, the policymaker
cannot establish whether conditions under the base case are acceptable or
not. This should be the logical first step in any study of this kind.
It is because this question is not asked, that the reader never
quite understands why "mitigation strategies" calling for controls
stricter than the "base case" are needed or examined. The reader's
puzzlement over this question is only increased when, after wading
through the complex narrative, he realizes that under the base case:
i) Total emission will decrease for all criteria pollutants
(except NOX);
ii) Ambient air quality concentrations will improve for all
criteria pollutants {except NOy), and for sulfates as well;
and
iii) Ttie National Ambient Air Quality Standards (NAAOS) will be
attained.
CRBES also fails to ask the second key question. The study loses
sight of the public goals to be promoted — decreased human and economic
injury — and focuses on emission reductions. By adopting this focus,
ORBES obscures answers to the second question. The reader is not given
meaningful information on the cost of protecting human health; he is
given information on the cost of reducing emissions.
3. ORBES Dees not Present its Findings in A Meaningful Form
Meaningful results must be presented in a comprehensive and
6/See Section III-B, 2. The ORBES study design fails to consider
necessary key questions.
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comprehensible form. The ORBES Main Peport floes not do this. For
exarole, sulfur dioxide and sulfate concentrations are never placed in
context by comparing the ambient concentrations projected for different
years and for different scenarios with reference levels such as the
National Ambient Air Quality Standards. Table 1 in Section III-C, 2. is
an example of the kind of presentation which should have been included in
the Main Report in order to assist the interested reader (or the
policymaker) in assessing the need for additional controls to promote
basic social goals.
These are a few examples of the structural problems inherent in
ORBES: the kind of problems which contribute to the reader's feeling
that he is "reading all about pollution." That scattered approach may be
desirable in an introductory learning experience but not in a document
designed to inform national and state decision makers on complex policy
questions.
C. Because the ORBES Air Quality-Related Analysis Employs Deficient
Models, Inadequate Data and Presents Distorted Conclusions, it Is
Not Meaningful in Itself and it Does Not Support Meaningful
Inferences
1. introduction and Summary
Air quality modeling lies at the heart of QRBES; the study purports
to relate changes in atmospheric emissions from power plant operation to
health and welfare effects. This can only be done using modeling
techniques. QRBES attempted to model two different air pollution
systems. First, the study considered sulfur dioxide emissions; their
transport and dispersion over long distances; their transformation into
sulfates; and the deposition of these species. The QRBES investigators
attempted to model these processes over the short-term (24-hour) and the
long-term (annual). They purported to evaluate the short-term air
pollution impacts of each energy scenario by modeling that scenario using
meteorological data for one episode — August 27, 1974. They used a
different model to estimate long-term sulfur oxide and sulfate impacts,
but here also they used only one year of input data.
Secondly, the ORBES researchers attempted to model the changes in
ambient ozone concentrations associated with the different amounts of
nitrogen oxides which would be emitted under the different energy
scenarios. This aspect of the ORBES work is examined in Section III-E,
4, infra.
Summary of sulfur dioxide modeling criticisms
The QRBES Main Report does not contribute substantially to our
understanding of long-range transport and transformation. On the
contrary, the results presented in the Main Report are incomplete,
inaccurate and misleading.
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Because ORBES mishandled and misinterpreted air quality and
meteorological data; employed inappropriate, unproven computer models;
and used them in an inappropriate fashion, the major conclusions of the
ORBES Main Report are no more than crude approximations. The crudeness
and inaccuracies of the modeling results, in turn, compromise the health
and welfare assessments in which they were used.
By treating hypotheses as facts, presenting estimates as precise
values and by burying important qualifications in the background reports,
ORBES misleads its reader into believing that it has produced a series of
reliable, accurate projections. In fact, the work is so weak technically
that it would never survive competent peer review. Nine of the most
serious technical flaws are as follows:
i. ORBES fails adequately to point out that the
N&tional Ambient Air Quality Standards (NAAQS)
are being protected throughout most of the region
and that the air quality will continue to improve
under all scenarios.
ii. The computer models used in ORBES did not
properly represent utility emissions — the main
concern of the study.
iii. ORBES does not properly recognize that the
meteorological conditions favoring long-range
transport are complex and not clearly defined;
and that no quantitative relationship between
persistent winds and long-range transport has
been demonstrated.
iv. ORBES fails to recognize that it is not possible
to quantify the relative sulfate contribution of
low-level local sources and high-level distant
sources during regional episodes because the
meteorological conditions which produce elevated
sulfate concentrations may be the same for both
source types.
v. The ORBES computer modeling results were not
statistically compared with observed data.
vi. The "conclusion" that TSP concentrations would
decrease "dramatically" if power plant emissions
were curtailed is a grossly misleading claim.
vii. The air quality and meteorological data base is
inadequate in quantity, quality and coverage
(spatial and temporal) to support the conclusions
reported and ORBES researchers did not attempt to
discriminate between reliable and unreliable data.
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viii. The air quality assessments of the energy scenarios are
unreliable and unrealistic because short-term concentration
estimates were based on a single episode evaluation, and
long-term projections were developed from a single set of
annual meteorological data. These applications improperly
ignore the large variations in meteorological conditions,
which occur from episcde-to-episode, and from year-to-year.
ix. The presentation of results in the ORBES Main Report
camouflages their inaccuracy.
2. The ORBES Main Report Misleads the Reader by Failing Adequately to
Point Out that the National Ambient Air Quality Standards are
Protected and the Regional Air Quality is Improving
The NAAOS are presently being protected throughout most of the
ORBES region. Violations of the sulfur dioxide and particulafae standards
do take place in certain locations; however, the sulfur dioxide
violations are localized and the particulate violations are usually
dominated by natural sources. Thomasian (1980).
The ORBES Main Report does not adequately compare regional air
quality levels with the NAAQS, nor does it adequately compare its own
projected future air quality levels with the standards. Table 1 is an
example of the kind of presentation which should have been included in
the Main Report.
Table 1: Comparison of ORBES Calculated Maximum Base Case Sulfur
Dioxide Concentrations (from Utility Emissions) with
National Ambient Air Quality Standards
Episodic Level (ug/n^)Annual Average
NAAQS 365 (24-hr.) 80
S02
ORBES 1976
ORBES 1985
OPBES 2000
94
65
48
26
19
13
This table gives the reader a meaningful comparison of the future
calculated concentrations, taken from Tables ES-2, 3 of the Main Report
at 19, 21, and the health-based primary sulfur dioxide standard. It also
points out the projected trend toward improving air quality. Also see
Niemann, et. al (1978) (Measured TSP concentration showed substantial
improvement from 1977 to 1978.) This central fact is not fairly pointed
out by the Main Report.
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3. The ORBES Long-Pange Modeling Techniques Are Defective; Not
Even the Best Techniques Are Capable of Accurately
Estimating The Effects Which ORBES Projects
3.1 The ORBES Reports Mislead the Reader by Failing Meaningfully
to Disclose Central Modeling Limitations
Despite the central role of transport and diffusion in the analysis
of both current and projected conditions, the Main Report devotes only a
few lines to a description of the models and how they were used. Id. at
75, 78. It is inconceivable that an allegedly scientific study would not
describe the primary tool used to make most of its future projections.
One must go to the support documents, notably Stukel, et al. (1980), and
to the references cited in those documents to assess the ORBES models.
Even then many important facts are not clearly presented.
ORBES1 Short-term Model Was Used to Model only One Episode for Each
Scenario and Considered Only Utility Emissions
The Main Report indicates that the Prahm (pseudo-spectral) model
was used to examine four specific episodes. Id. at 75. What is not said
— on page 75 or elsewhere in the Main Report — is that only one case,
August 27, 1974, was used for an short-term projections of the future
scenario impacts. The reader is left to discover this for himself.
Stukel, et al. (1980) at 105. The uniqueness of any single day or set of
days — its meteorology, emissions and power generation mix — make it an
inappropriate basis for making projections to the year 2000. Not only is
it technically flawed to base an entire portion of ORBES on the analysis
of one episode, it is grossly misleading not to disclose this fact to the
reader.
There is another equally important fact about the ORBES sulfur
oxide modeling which is disclosed only to the most diligent reader. The
ORBES team modeled only utility emissions; the model runs did not
consider the most numerous actual emission sources! This is a serious
error in logic, because nearly one-fourth of the sulfur dioxide emissions
in the ORBES region originate from non-utility sources. Niemann, et al.
(1980) at 2-4. Moreover, many of these non-utility emissions occur at
low elevations where they can produce high ground-level concentrations.
The failure to include these sources renders any attempt to "validate"
the model mere guesswork.
ORBES' Long-Term Model Has Never Been Subject to Peer Review
For annual modeling, the ORBES researchers used their own
adaptation of the Fay-Rosenzweig model. It is known as the TRI/Fay
model. Main Report at 78. Apparently, the ORBES team used this model
with a single set of annual meteorological data. That is, one
"resultant" wind speed and wind direction were calculated for each
meteorological monitoring station in the ORBES region — using a sort of
averaging technique. It is not possible to comment meaningfully on this
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technique, in part, because the details of this model have never been
released for peer review. See Section II, supra. This, again, is not
made clear in any of the ORBES documents.
3.2 No Long-Range Transport and Diffusion Models Have Been
Proven Reliable
It is important to recognize at the outset that there is no
lonq-range transport and diffusion model that has been validated and
proven. Comprehensive reviews of diffusion models recognize the serious
limitations with all such models. Hosker (1980), Husar, et al. (1980),
and Smith (1980). Thus, any study of the ORBES type must be speculative;
the probable errors in this type of modeling are very large, ranging from
factors of 3 to 5 in some simple situations to several orders of
magnitude in more complex ones.
These large uncertainties arise from a number of fundamental
problems. Long-range models cannot simulate the full complexity of the
atmospheric processes; additionally, the necessary input data are
inadequate in their geographical, vertical and temperal coverage. The
magnitude of the errors is little more than a guess because the data
needed for proper validation of a long-range transport model do not
exist. None of these deficiencies are the fault of the QRBES team.
However, the reader has a right to expect an honest acknowledgement of
them. While cautioning against judgments based on inadequate data, id.
at 55, the Main Report does not so much as hint at these limitations.
3.3 There Are Serious Weaknesses in the ORBES Regional
Short-Term Model
The ORBES team used a version of the Prahm two-dimensional
pseudospectral model, Mills and Hirata (1978) to estimate the "as if" air
quality impacts on August 27, 1974 for each energy scenario. This model
"transports" the total emissions from large grid squares (80 km on a
side) according to a wind field developed from twice-daily upper air
data. The model considers horizontal diffusion, but the atmosphere —
below the mixing height — is assumed to be uniformly mixed in the
vertical. The mixing heights used by the ORBES researchers were assumed
to be constant over the entire area. The transformation of sulfur
dioxide to sulfate and the dry and wet deposition were calculated by the
Prahm model. There are a number of serious theoretical and applied
shortcomings in the ORBES use of the Prahm model.
Power Plant Emissions Are Not Accurately Represented by The
Teknekron Model
While the assumption that all emissions are contained within the
mixing layer may be suitable for low level sources, it is inappropriate
when applied to elevated power plant emissions. Yet, power plant
emissions are the focus of the ORBES study. The buoyant plumes from
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power plants often rise above the mixing layer, reaching the stable air
above. When this happens, the plume does not interact with the ground
surface until the top of the mixing layer rises higher than the plume
elevation.
An example is useful in understanding this point. Suppose a power
plant plume r ises above the top of the mixing layer early in the evening
and is transported with very little vertical diffusion by a 5 m/sec
wind. By the following morning that plume would have traveled over 200
km from the source without contributing to the ground-level
concentrations below. The plume would have had no contact with the
ground during this period. The ORBES model would misrepresent the
behavior of the plume by assuming it to be within the mixing layer. In
this example the model would greatly overestimate sulfur dioxide and
sulfate concentrations within the first 200 km. Moreover, the stronger
winds and the wind's variation in both direction and speed (wind shear)
above the mixing layer would dilute and disperse this plume quite
effectively. Notably, wind shear occurs even during the persistent and
stagnant conditions which the ORBES authors considered favorable to the
production of elevated concentrations. Smith and Martin (1980) at A-56.
ftiring part of the August 27, 1974 scenario modeling episode, the
mixing height was low enough that many power plant plumes would have
penetrated the mixing layer and would have behaved as the plume described
above. This fact is never discussed by the CRBES reports.
ORBES Incorrectly Assumes that Sulfur Dioxide-Sulfate
Transformation Rates Remain Constant
Estimates of the sulfur dioxide—sulfate transformation rate
generally ranges from less than 0.5% to 2.5% per hour. Lower rates are
found at night and in cold winter conditions; more rapid transformation
occurs in wanner daytime situations. Realistic modeling of episodes
would use variable transformation rates. The ORBES system did not.
This omission could produce substantial errors in the calculated
sulfur dioxide and sulfate concentrations. In relatively light winds
(e.g., 2 m/sec) the difference between a 0.5% and a 2.5% transformation
rate would be approximately a factor of 3 at a distance of 500 km
downwind.
ORBES Does Not Accurately Model Changes in Wind Speed and Direction
The ORBES model used a wind field developed from data taken at
600 m above ground. It allows no adjustment of wind speed or direction
with height. This is incorrect.
It is known that the wind always varies in speed and direction with
height. This variation is due to the frictional effects of the earth's
surface. Therefore, at any given time plumes from individual stacks
would be subjected to different wind directions and speeds. Each plume
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vould rise to a different height, and the transportinq wind at the final
effective stack height would be different for each. To understand the
significance of this point, consider two emission sources identical in
all respects except that one is released at 100 m and the other at 300 m
above the around. Assume further than both are released into a
neutrallv-stretified — moderately dispersive — atmosphere. If the wind
at 100 IP were south at 10 moh, according to basic meteorological theorv,
at 300 ra the wire* would probably be south-southwest at about 14 mph.
Because pollutant dispersion is proportional to wind speed, the upper
plur?e would be 40% irore dilute than the lover one and it would be
transported in a different direction.
As the examples outlined above demonstrate, there are many complex
and interrelated effects of failing to account for the inevitable changes
in wind conditions. The interactions of these effects can result in
order-of-maqnitude differences in the predicted concentrations from
typical source configurations.
OPBES Treatment of Vertical Dispersion Was Unrealistic
The pseudospectral model does not consider vertical dispersion? it-
assumes that all emissions within a column are immediately dispersed
uniformly between the top of the nixing layer and the ground. This
certainly does not happen, especially with emissions from power plants.
The problems caused by this assumption are most serious under neutral and
slightly stable conditions, tinder these conditions the pseudospectral
model will predict ground-level concentrations relatively close to each
source. Emissions from elevated sources will not ordinarily reach the
ground anywhere near their point of release, instead, they will be
transported downwind and will produce diluted ground-level concentrations
tens or hundreds of kilometers away.
The OPBES Regional Node! Vfas Vet Validated
The OFBES researchers might have been able to narrow several of
these uncertainties if they had presented a reasonably convincing
validation study. They could not present a good study because the data
are lacking, but they did not even present a credible attempt.
The Main Report does not mention model validation let alone its
importance. The thoughtful reader might expect to find a discussion in
the support documents. The ORPES researcher present just one figure
which compares predicted and observed values. Stukel, et al., Figure
2-35, at 77. As the authors acknowledge, this figure shows very limited
field data for comparison. Id. at 76. Moreover, this "validation"
figure is for June 11, 1976, not August 24, 1974, the episode used as the
basis for the entire short-term air quality analysis. Stukel, in turn,
refers the reader to Mills and Hirata (1978). However, Mills and Hirata
contains no additional data or explanations. Thus, the diligent reader
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is led down a string of citations to unsupported assertions; this is not
the kind of science upon which policy decisions should be based.
There is another, even more disturbing aspect to the brief ORBES
validation discussion. Bather than presenting clear numerical expression
of the agreement or disagreement between observed and predicted data, the
researchers use qualitative remarks like "generally good agreement." The
reader is seldom told what prediction agrees with what measurement.
Figure 2-35, id. at 77, the only presentation which compares observed and
calculated data in the same diagram, uses smoothed isopleths for
calculated values and AQOR averages for measured values. This kind of
smoothing can greatly alter the apparent comparison and allow it to favor
the desired result.
These deficiencies illustrate that the QRBES model calculations
are little more than mechanical exercises. The ORBES results cannot to
be taken to represent what would occur in actual episodes.
3.4 There Are Serious Weaknesses in the ORBES Regional Long-Term
Model
The ORBES team used a model which they call the TRI/Fay model to
arrive at their projections of annual average concentrations. Judging
from the original paper by Fay and Rosenzweig (1980) this model is a
simplified system for deriving annual average values around a large
number of sources. The model contains algorithms to treat the conversion
and deposition processes.
The TRI/Fay model suffers from many of the same weaknesses as the
ORBES short-term model dees. It is unable to distinguish between plumes
which penetrate the top of the mixing layer and those trapped within it,
and it uses fixed values for depletion and deposition.
There are two excellent reasons for doubting the validity of the
TRI/Fay predictions. The first appears in Stukel, et aj.. (1980) at 84.
There, the ORBES authors state:
"In fact, the model predictions of the 804 =
concentrations from just utility S0j[ emissions are in
closer agreement to the SURE II SOg. = measurements than
were the model predictions using all the SOx
emissions. At present, the significance of this is not
known.... (Emphasis added.)
In essence, this means that the model gave better results if a
significant portion of the emissions and the majority of emission points
were ignored! That result raises serious questions about the validity of
any results produced by that model.
Secondly, the symmetry of the long-term sulfur dioxide and sulfate
projections is not consistent with a basic meteorological understanding
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of the ORBES area climatology. Figures 4-9 and 4-10 from page 79 of the
Main Report are good examples. They both show nearly circular predicted
pollution patterns. These circular patterns suggest that the modeling
reflected the effects of winds from numerous directions. Yet an
examination of Niemann, et al. (1980), Appendix II-A at 2-4, shows that
winds from numerous directions were not used in the annual modeling.
Father, a "resultant" wind direction was developed for each of several
locations in the ORBES region. These "resultant" directions were all
from the southwest, as one would expect from the regional climatology.
Thus, one would expect the ORBES concentration isopleths to be elongated
in a northeast-southwest axis, not circular. Moreover, since the
transformation from sulfur dioxide to sulfate proceeds relatively slowly,
one would expect the CRBES sulfate patterns to be somewhat more elongated
and offset from those for sulfur dioxide.
Here again, ORBES offers virtually no attempt at validation. The
ORBES authors described the agreement between observed and predicted data
as "qcod," but the Fay and Rosenzweig paper shows only one comparison;
also a comparison of smoothed isopleths. In fact, the agreement is
rather poor. Accordingly, the results of the annual modeling are
speculative, unvalidated and indeed rather puzzling.
4.0 ORBES Did Not Evaluate the Reliability of the Air Quality and
Meteorological Data It Used
CREES projected future air quality levels and estimated their
significance. The accuracy of these projections depends upon the
accuracy of many factors, including the air quality, and meteorological
data used in the study. Air quality data should serve two important
functions: to establish the base-case or current levels of pollution,
and to provide part of the basis for validating the model. The
meteorological data should provide the other input for model validation,
and together with the emissions information, should serve as the basis
for estimating the air quality impacts of future energy scenarios.
If either set of data is inadequate, or if either is improperly
used, the modeling projections suffer, unfortunately, both sets of data
used in the ORBES study are inadequate, and both have been mishandled by
the ORBES researchers. Because the ORBES results are based on data of
poor quality they should have been qualified by appropriate caveats.
They ware not.
4.1 The Accuracy of the Air Quality Data Varies And They Are
Inadequate For Use in Making Meaningful Long-Range
Modeling Calculations
The air quality data on which many of the ORBES conclusions
are based differ markedly in reliability, and in spatial and
temporal coverage. The SURE II data are probably among the most
accurate data available. However, they have been collected for less
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than two years and not all days are represented. The American
Electric Power (REP) network has been operating for six years and
the data are of generally good quality. However, this network does
not monitor for sulfates; and it was designed to monitor conditions
close to AEP's major power plants. Thus, the geographical coverage
is limited to a band along the Ohio River and the data cannot be
used to validate a regional analysis. Hie 1974 SURE I data are of
questionable quality. Smith and Martin (1978). The remainder are a
mixture of state and Federal monitoring data, some of which has been
recognized as unreliable. Neimann and Mahan (1978), Appendix B.
The ORBES team should have established a screening process by
which data were admitted or discarded. Tnis was never done. Poor
data were used as if they ware good. For example, pages 69-70 of
the Main Report contain a discussion of the sulfur dioxide
nonattainment areas in ORBES region. One of the areas cited in the
Report is western Pennsylvania. The source of the data used in this
determination is given as the National Aerometric Data Bank (MADE).
However, the ORBES background document states that "[t]he reliability of
the S02 violation is uncertain because of the relatively low percentage
of valid data." Stukel, et al. at 24, n.3.
Without an accurate data base, neither the investigators nor the
reader can be certain of existing air quality levels over the study
region. These uncertainties also weaken the few efforts which were made
to "validate" the models.
4.2 The Meteorological Data Are Inadequate For Meaningful use in
Modeling Long-Range Transport
The accuracy and general quality of the meteorological data used by
the OFBES researchers are good, and some of the time coverage is also
very good. However, certain key variables are either not measured, or
the spatial coverage is too low bo support detailed evaluations. For
example, atmospheric stability — a measure of the dispersive potential
of atmosphere — is almost never measured at the elevations of power
plant plumes. The height of the mixing layer is obtained only twice
daily from measurements at relatively few stations; and the wind speed
and direction at plume elevations is available only occasionally from a
sparse network of stations. This network is inadequate to define
accurately the dispersion conditions for a single stack at a specific
hour, let alone for the entire, complex source pattern over the entire
ORBES region. This issue is not even raised in the Main Report.
5. ORBES Presents Erroneous Air Quality Conclusions as Facts
5.1 ORBES is Misleading Because it Assumes Sulfates Result from
Long-Range Transport
ORBES assumes that calculated sufate concentrations are the
observed results of long-range transport.
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Thus, both data and modeling confirm that long-range transport
from the lower [QRBES] region contributes significantly bo the
concentration averages in the upper region and to violations of
NAflQS in that region. Main Report at 7. (emphasis added).
ORBES does not confirm this fact, it assumes it. In the sulfate
discussion, the ORBES authors treat hypotheses as facts and blur the
distinction between observed and calculated concentrations.
The Main Report states: "[alssuminq that sulfate concentrations
are a good measure of the contribution of nonlocal sources to local TSP
measurements long-range transport of sulfates...contribute between 15 and
20 percent of total annual TSP concentrations...." Id. at 73 (emphasis
added).
But this is just the assumption which the Executive Summary cites
as a conclusion. The sulfate discussion in the body of the Main Report
indicates that in two of the four episodes, emissions from utilities in
the lower QRBES region contributed over 90% of the sulfate concentrations
that were observed in the upper QRBES states of Ohio, Pennsylvania and
West Virginia. Id. at 73. The sulfate concentrations are observed
values. However, the statement that the lower ORBES region utilities
contributed over 90% of the upper region concentrations is based solely
upon the pseudospectral model calculations. It was not and cannot be
verified by observation. By combining observed and calculated values in
this way, the reader is left with the misiirpressicn that there is some
way that long-range transport contributions to the observed sulfate
concentrations can be separated out from local contributions. No such
separation was even attempted.
There are two related ORBES conclusions which should also be
addressed. These are: the alleged documentation of a relationship
between persistent winds and high sulfate concentrations; and the alleged
contribution of sulfates to distant total suspended particulate
concentrations.
5.2 The Relationship Between Long-Range Transport and Persistent
Winds is Not Proven and May Not Be Quantifiable
ORBES1 basic approach to analyzing the short-term air quality
impacts of different scenarios is to estimate the emissions under each
scenario and to use a "typical" sulfate episode to determine the "as if"
impacts of that scenario. In this analysis, ORBES researchers assume
that the persistent wind condition is typical of sulfur dioxide and
sulfate episodes.
Here they made an error. Once they discovered that some high
concentrations were associated with persistent winds, they assumed that
long-range transport was involved and proceeded to base precise numerical
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predictions on that idea. As the Main Report puts it:
[Rjegional data indicate that long-range transport of
emissions, even over distances of several hundred kilometers,
was and is an important factor in regional pollutant
concentrations. At several locations throughout the region,
between 25 and 50 percent of the 25 highest daily sulfur
dioxide concentrations are associated with transport by
extremely persistent winds. Moreover, under certain
meteorological conditions, sulfur dioxide is transformed into
sulfates thereby contributing to regional sulfate
concentrations. Id. at 6.
This assertion — that long-range transport, persistent winds, and
high sulfate and TSP concentrations are related — is repeated throughout
the Main Report, id. at 72-74, and the support documents, Stukel, et al.
(1980) at 40. Oil is is an incomplete, misleading analysis. The ORBES
team did not review those cases in which high concentrations were
associated with conditions other than persistent winds; nor did they
determine the contribution of local sources in the persistent winds case.
The Persistent Wind Hypothesis
Smith and Martin (1978), although recognizing that there were
problems with the data, have analyzed the same data used by ORBES
researchers. They have shown that less than half of the high sulfate
concentrations periods were associated with persistent winds.
Furthermore, there is no significant statistical correlation between wind
persistence and the occurrence of the allegedly elevated daily sulfate
concentrations in the SURE I data used in GRBES. In fact, Smith and
Martin's analysis of the data for the six reporting SURE I stations leads
to the following conclusions:
1. Most days with relatively high sulfate concentrations did not
have extreme persistence of wind speed, wind direction and
stability class;
2. The large majority of days having extreme persistence at each
station had sulfate concentrations in the lowest range; and
3. The ratios of persistence days to total days did not vary
significantly from the lowest to the highest concentration
category.
While wind persistence is common, it does not imply the existence
of substantial long-range transport. Relatively high sulfate
concentrations showed no favoritism for persistent or non-persistent
meteorological conditions.
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The Contribution of Local Sources
On the other hand, one would expect high sulfur dioxide and
sulfate concentrations to be produced by local sources during persistent
winds. Spaite et al. (1980). In a technical support document the ORBES
team states that:
[long-range] transport does make a significant
contribution, in terms of magnitude and frequency,
to elevated 502 concentrations upwind, within,
and downwind of the ORBES region. Stukel, et al.
(1980) at 21,
This statement is not correct. It is based on an analysis of data
from the Clifty Creek monitoring network, an AEP network designed
specifically to monitor effects of local sources. An examination of the
25 highest daily sulfur dioxide concentrations in each of four years used
by ORBES, shows that the persistent wind blew from the local plant toward
the key monitor in virtually every case. This suggests that local — not
distant — sources played the key role. Moreover, background
concentrations from all other sources were very low. Long-range
transport was not significantly involved in these cases. Notably, in no
case were the Ambient Air Quality Standards for sulfur dioxide exceeded.
Thus, the ORBES team failed to distinguish the contributions from
local and distant sources. Once they discovered that some sulfur dioxide
and sulfate episodes were associated with persistent winds, they assumed
that distant sources were responsible. Certainly, long-range transport
can occur but, the questions are: in what concentration, where, how
frequently, and in what ratio to locally-produced concentrations? The
ORBES study answers none of these questions; instead it assumes its
answers. The persistent wind hypothesis propounded by ORBES is not
confirmed by the available data. ORBES ignored non-utility emissions
which are generally low level and affect local sulfur dioxide and sulfate
concentrations greatly. Spaite, et al. (1980). ORBES cannot associate
any particular portion of sulfur dioxide or sulfate to long-range
transport because it failed to evaluate other likely causes of the
observed concentrations.
5.3 Sulfates from Regional Emissions do not Contribute
Substantially to TSP Nonattainment
The ORBES Main Report states:
Contribution to TSP Nonattainment. However, if
utility sulfur dioxide emissions were controlled or
if a fine particulate standard were to be
implemented, TSP concentrations would decrease
amatically since sulfates would decrease with such
controls or such a standard. Id. at 73. (emphasis
added).
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Anyone who studies the suspended particulate problem recognizes
that local sources are of paramount importance, especially in periods
when the air quality standards are violated. Thomasian (1980), EPA
(1976).
Yetf the Main Report continues:
Data indicate that sulfates are a major contributor to
the elevated TSP levels in the GRBES region. During
the period August 1977 to October 1978, measurements
[from] at least three regional monitoring stations
indicated that elevated sulfate concentrations
contributed to TSP nonattainment. ... Id. at 73.
Examining the data referred to in the two preceeding paragraphs,
howeverr shows no evidence that sulfates are a significant contributor to
elevated TSP concentrations nor that the aggregated emissions from all
GRBES power plants account for the reported sulfate concentrations.
Moreover, it is significant to note that not even the ORBES
researchers claim to calculate the impact of the emissions from
individual power plants on distant sulfate and particulate
concentrations. To be sure, occasionally sulfates contribute to a
violation in the sense that if the sulfate fraction were eliminated, the
TSP standard would not be exceeded. But the sulfate fractions in those
cases typically are smaller than the 20-45 percent value by the Main
Report at 73, and, there is no documentation that the sulfates originated
from the long-range transport of power plant emissions. There is every
reason to believe that a complete cessation of utility emissions would
have a negligible effect on TSP concentrations.
The ORBES authors did not present enough details of the SURE II
TSP and sulfate data to permit analysis of them, but examination of
concurrent particulate and sulfate data from Pennsylvania shows that the
sulfate/TSP ratios are relatively low. Martin and Smith (1980).
Based on air quality data from the southwestern border region of
Pennsylvania — TSP and sulfate concentrations recorded at 17 stations in
the Beaver Valley and Monogahela Valley in 1978 — there were 12 cases in
which the Twsnty-Four-Hour Primary TSP Standard of 260 ugAi3 was
exceeded. In ten of the twelve cases the standard level would have been
exceeded even if the sulfate concentrations were zero. Similarly, there
were 82 cases in which the Twenty-Pour-Hour Secondary Standard of 150
ug/rn3 was exceeded. In 50 of these, the standard still would have been
exceeded even if there were no sulfates. The sulfate fraction did tip
the TSP concentration over the Secondary Standard on 32 occasions. The
following table shows that the sulfate/TSP ratios on these 32 days were
46
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quite low. The ratios were 20% or less in three-fourths of the cases.
Number of
Sulfate/TSP Ratio Cases
.10 (or less) 5
.11 - .15 12
.16 - .20 7
.21 - .25 3
.25 (or more) 5
The sulfate/TSP ratios in the two cases in which the TSP
concentration was over the Primary Standard had ratios at 0.16 and 0.05.
These ratios show that the sulfate fraction is generally small when TSP
concentrations are quite high. Neither the Main Report nor the
background documents discuss these results.
It is uncertain how much of the sulfate in the QRBES samples and
in those discussed above was transported from outside Pennsylvania and
how much was generated by emissions within the state.
The ORBES analysis focuses myopically on the long-range transport
of power plant emissons as the cause of the standard violations. This
concern is misplaced. The fact is that the entire ORBES discussion of
sulfates and TSP is exaggerated and contrived. TSP problems are usually
locally generated and, insofar as they can be alleviated, the solutions
will be local also.
D. The QRBES Health Conclusions Are Based on Erroneous Theories,
Incorrect Applications Of Theories And Are Highly Misleading
1. The QRBES Sulfate-Related Mortality Conclusions Are Misleading
And Inconsistent With The Bulk of Scientific Evidence
The Executive Summary of the Main Report states that "a growing
body of evidence supports the hypothesis that the annual average exposure
to sulfates — or something closely related to them — results in an
increased mortality rate." (emphasis added) Id. at 6, 22. Although
this emphatic position is tempered later in the text, the Report states
that the 1975 sulfate related fatalities in the ORBES region could be
between 25,000 and zero; with "median" value of 8,000. Id. at 101-02.
These conclusions have been widely cited in the press as the "facts"
which the Main Report makes them appear to be. Washington Post, Feb. 4,
1981 at A13; The News, Aug. 15, 1980. The fact is that no sulfate
related death has ever been identified medically. Moreover, the Main
Report's conclusions are inconsistent in tone if not in fact with the
ORBES background documents and with the bulk of current scientific
evidence.
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1.1 The Main Report is not Self Consistent and it does not Fairly
Reflect the Background Reports
The work upon which the Main Report sulfate mortality calculations
was based, Shapiro (1980), hardly supports the Executive Summary's
statement that a "growing body of evidence" supports the sulfate
mortality hypothesis. On page 3.4-4 Dr. Shapiro concludes that:
If acid derivatives of sulfur dioxide [including sulfates], . . .
contribute to health effects observed in population studies, their
contribution cannot as yet be isolated from the possible influence
of other elements in the suspended particulates present in the
airborne mix, . . .
Again, on page 3.4-14-15, he states:
Estimation of health damage resulting from increased population
exposure to sulfate adds considerable uncertainty to the
analysis. Health damage associated with changes in annual sulfate
exposure of a few ug/m-* annual average at exposure levels below
15 or 20 ug/m^ annual average cannot be estimated with
accuracy. There may be none. Based primarily on cross-sectional
correlational studies, however, some quantitative damage functions
have been advanced. At this time, we arbitrarily selected damage
functions of 0, 3.0 and 9.0 deaths/100,000 population per uq/ni*
sulfate. . . . (emphasis added).
Tine Main Report appears to have turned Shapiro's hesitancy into
firm conviction. In fact, the evidence which is "growing" is that
suspended sulfates are innocuous at both present and future projected
ambient concentrations.
In addition to changing the tone of the background document, the
sulfate mortality calculations presented in the Main Report are not self
consistent. Figure 7-3, u|. at 159, shows that the entire ORBES area
will be exposed to no more than 5 ug/nP of sulfate in the year 2000.
Multiplying this times the ORBES sulfate "kill factor" of 3 deaths per
ug, id. at 173 n. 22, and again by the projected regional population of
26.6 million in 2000, id. at 116; the number should be 3990 not 5150 as
reported at page 173. This example points up another inconsistency in
the Report; it does not suggest either figure is correct — the correct
number is zero.
1.2 The Sulfate-Related "Kill Factor" Analysis Is Misleading
The Main Report projects between of 0 to 9 deaths per 100,000
persons exposed per microgram sulfate per cubic meter. Id. at 101-2.
From this the reader is told a median annual death rate of 8000 for power
generation in the ORBES region can be calculated. This is a misleading
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result because it employs an "arbitrarily" selected damage function.
Shapiro (1980) at 3.4-lL The subsequent mechanical operations of
multiplication to produce final "body counts" provides the reader no
insight into reality; it merely adds sensationalism by discussing large
numbers of deaths. This approach has been very appealing to the press
which, in turn, has misinformed the public.
The Main Report cites Hamilton as authority for the sulfate health
effects work. Id. at 101, n.34. Hamilton's work is based heavily on the
work of Lave and Seskin (1978) and Winkelstein et al. (1967). The Lave
and Seskin work ha? been largely discredited, see Section III-D, 1.3,
infra. Hamilton improperly relied on Winkelstein by converting his
Buffalo mortality results from TSP to sulfabe to produce unit sulfate
mortality factors. This conversion is without any scientific basis since
Winkelstein himself concluded that sulfur oxide had no effect on Buffalo
irortality.
Another misleading tactic in the Main Report is the use of a
"range" of mortality factors. By usinq the arbitrarily large upper
limit, 9 per 100,000 without substantive evaluation, the renaininq values
look "reasonable." This approach makes sense for bargaining in a bazaar;
it does not as a scientific studv designed for policy formation.
The Main Report states "ft]he major usefulness of the damage
function for the CRBES study [sic] lies not in the accuracy of the health
impacts but in the comparison of the impacts between scenarios." Id. at
102. It)is statement is misleading because the best evidence — as
discussed below — is that the correct value for Shapiro to have used is
zero. The proper comparison should have been between zero and zero.
1.3 The Bulk of Scientific Evidence Shows Present and Projected
Sulfate Concentrations Are Inocuous
Concern by the environmental coinnunity over possible health
effects due to ambient sulfates reached a peak about 1974-75, in
conjunction with publication of the CHESS monograph by EPA. A flurry of
research activity began at that time, and the results of those studies,
without exception, now indicate that those fears were groundless. As a
result, the U.S. EPA has not promulgated a primary (health-related)
ambient air quality standard for sulfate.
Briefly, the results of the research referred to above are:
i. The CHESS studies were badly flawed in design and execution. The
inter-regional comparisons cannot identify which pollutant, if
any, is responsible for any observed health differences. The
time-series studies are badly compromised by poor air quality
monitoring, failure to control for other confounding factors, and
inconsistent study populations. Brown Committee (1976).
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ii. Clinical exposure studies of both normal and sensitive human
subjects have failed to show adverse effects due to exposures to
various sulfates — including sulfuric acid — at concentrations
much higher than normally encountered even in sulfate episodes.
Chaney, et al. (1980), Avol, et al. (1978), Leitauf and Lippmann
(1980).
iii. Subsequent epidemiological studies incorporating the most recent
air monitoring techniques and controlling for such confounding
variables as weather and smoking have failed to find any adverse
health effects associated with sulfate. Zagraniski, et al.
(1979), Bouhuys, et al. (1979), and Iterris, et al. (1979).
iv. The cross-sectional study on which ORBES implicitly based its
mortality calculations, Lave and Seskin (1978), has been found to
be based on flawed ambient data. Lipfert (1979). Subsequent
cross-sectional studies by other researchers who have considered
competing risk factors have found no consistent mortality effects
attributable to ambient sulfates. Crocker (1979); Lipfert
(1978).
v. Atmospheric chemistry studies have shown that the bulk of what has
been measured as (non-specific) water soluble sulfate is ammonium
sulfate, which is of nearly neutral pH and is one of the least
irritating of the common aerosal sulfates.
vi. At least a part of the reason for finding number v., supra, is
the presence of ammonia in human airways, which can initially
neutralize any acid aerosol inspired. Larson (1977).
2. The ORBES Acute Health Effects Analysis Misuse The Underlying
Response Data by Equating British Smoke, Power Plant
Particulate Emissions and Total Suspended Particulates
The Main Report claims that as many as three cadiovascular
fatalities could occur each year as the result of particulate emissions
from each 1000 megawatt coal-fired power plant. Id. at 101. This
estimate was made without serious consideration either of the population
exposed or the actual concentrations produced by the power plant
emissions.
Moreover, ORBES assumes that power plant emissions can be
related directly to cardiovascular mortality. Id. However, the
underlying acute health data were developed using British smoke exposure
measurements. Schiimel (1978). Power plant particulate emissions,
British smoke and total suspended particulates (as cited in the ORBES
Main Report at 101) are three distinct quantities. There is no definite
relationship between the health effects data developed using the British
smoke exposures and mass concentrations of TSP or power plant particulate
emissions as ORBES assumes. Thus, the analysis is so uncertain that it
should be disregarded.
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3. The Radiological Discussion in the ORBES Main Report Contains
Serious Errors of Fact
At the top of page 103 the Main Report states:
. . . Assuming a single year of exposure, three
steps in the nuclear cycle — the mining, milling,
and power generation steps — are expected to result
in a total incidence of lifetime cancers among the
general public of between 0.03 and 0.05 cases per
year per 1000 megawatts electric of nuclear power
production. Roughly half of these oases would be
associated with the power generation step. In 1976
in the ORBES region, 10 million megawatts were
produced by nuclear-fueled power plants. Thus,
between 150 and 250 cases of cancer are expected to
have occurred in 1976 because of nuclear power
generation. . . . (footnote omitted)
This paragraph contains numerous errors. First, the statement that "In
1976 in the ORBES region, 10 million megawatts were produced by
nuclear-fueled power plants." is clearly wrong, The 10 million figure
could be an approximation of the annual megawatt-hour output from the
1,800 M/fe nuclear capacity in the ORBES region; however, the authors of
the Main Report used the figure as capacity in health effects analysis.
Even assuming the data used in the ORBES analysis, this overestimates the
effects by a factor of 10,000, as the following explanation illustrates.
According to page 66 of the Main Report there were 83,125
megawatts electric of installed generating capacity in the ORBES region.
Figure 4-2, on the same page, indicates that nuclear power accounted for
2.2% of this total, or 1,800 MWe; not 10 million!
Using this value, and accepting arguendo the ORBES "cancer
factor," the total number of lifetime cancers induced by each year of
nuclear power generation in the ORBES region would be 1.8 (thousands of
MWe capacity) time the cancer risk factors, or:
(0.03 - 0.05) x 1.8 = (0.054 - 0.09).
There are still more mistakes. The "lifetime cancers among the
general public of between 0.03 and 0.05 cases per year" was taken from
Radford (1980) at 27, by rounding, Radford's factors "0.028 - 0.048" to
0.03 - 0.05. Radford bases this estimate on all stages of the nuclear
fuel cycle, except reprocessing and waste managment; moreover, the major
portion of the exposure (and hence the cancer risk) comes from mining and
milling activities. Id. However, the Main Report indicates, that:
. . . Within the ORBES region, only the uranium enrichment, the
fuel fabrication, and the power generation steps take place at
present. ..." Id. at 102.
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No mining or milling take place in the CRBES region. Using Radford's
factors (Table 7A) for enrichment, fabrication and generation, only about
1/8 of the exposure (and cancer risk) will occur in the CRBES region.
Thus, the figures given on page 103 of the Main Report should be 0.0035
and 0.0060, not 0.03 and 0.05.
Furthermore, the statement that "[r]oughly half of these cases
would be associated with the power generation step" doss not correspond
either with footnote 37 of the Main Report, or Radford's Table 7A.
According to both, the power generation step accounts for more than 90%
of the risk attributable to enrichment, fuel fabrication and reactor
operation.
Multiplying the corrected estimate for the cancers produced in the
QRBES region by one year's operation of enrichment, fuel fabrication and
power generation to produce 1,000 MWe, times the correct figure for the
nuclear power generated in the ORBES region in 1976 gives:
(0.0035 to 0.0060) x 1.8 = (0.0063 to 0.011),
not "between 150 and 250 cases."
Finally, these cases would be produced by the 1976 exposure, and
would arise in the decades ahead. They are not "expected to have
occurred in 1976."
4. CRBES Grossly Overestimates the Radiation Induced Health
Effects Induced by Radiation and Fails to Acknowledge Relevant
Literature.
The Main Report discusses the "methodological fallacy" of
"argument from ignorance" and in so doing makes the statement,
. . . the impacts of nuclear-fueled electrical generating units
are evaluated without knowledge of the health effects of low-level
radiation." Id. at 55.
This quotation is apparently the result of a misunderstanding of
Radford's statement that "the appropriate model for lifetime projection
(of health effects) is unknown at this time." Radford (1980) at 27.
Radiation biologists may continue to wrangle about the "appropriate
model" for relating the incidence of health effects to radiation exposure
for gome time to come, but most agree reasonably that the "impact" on
health is about one lifetime fatal cancer per 10,000 person-rem. See
e.g., ICRP Publication 26 (1977) at 12, paragraph 60.
The "health effects" estimates for radiation from nuclear power
used in both the Main Report and the Jensen background report are based
on Radford's report, which states that the risk estimates used are "based
on the linear no-threshold dose-response relationship, derived from the
draft 1979 HEIR report." Radford (1980) at 24. This draft was
withdrawn, extensively revised, and finally issued July 1980, over
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Radford's objections. The risk coefficients used by Radford in the ORBES
analysis are about 10 times greater than those which are generally
accepted. See, e.g., ICRP Publication 26 (1977) and PEIR (1980).
The radiological aspects of energy in the Ohio River Valley are
not, and are not likely to become important considerations for the
production of electricity in this region. Although the ORBES Main Report
does not state this in so many words, the fact is clearly implied. The
Tore Team has handled the few radiological matters which appear in the
Main Report very clumsily. The danger is that the clumsy handling of
nuclear power and radiation will invite criticism which will cast doubt
on the implied conclusion, which is correct, that radiation is an
unimportant consideration. Three references — UNSCEAR (1977); IPRP
Publication 26 (1977); and BIER (1980) — and the references they
contain, provide a vast and authoritative body of information about
nuclear power, the radiation associated with it, and the probable risk
from this radiation. The Core Team never addresses these documents nor
the fact that some of the ORBES analysis is at odds with them.
E. The ORBES TroD Damage Results are Based On Incorrect Theories,
Incorrect Applications of Theory, Fai] to Recoqnize Kev Scientific
Studies and Greatly Overestimate Air Pollution Damage
1. Introduction
The ORBES region covers 423 counties in the states of Illinois,
Indiana, Kentucky, Ohio, Pennsylvania, and West Virqinia. The tvpes of
farming range from vast corn and soybean tracts in Illinois to smaller
tobacco farms in Kentucky. The agricultural sector constitutes about 4%
of the gross regional product. A key ORBES conclusion is that the
cumulative agricultural economic damage in the region would range from
$7.0 billion (1975 dollars) — under the base case and SIP noncompliance
case — to S8.4 billion (1975 dollars) — under the high electric growth
case — over the period 1976-2000. Main Report at 147. This
"conclusion" has received wide public attention. Evansville Courier,
Sept. 2, 1980, at 1.
The Main Report does not indicate how these estimates were
developed. For this, the reader must search two documents. The
Institute of Ecology (TIE) Report, Loucks, et al. (1980) develops crop
loss coefficients — numerical estimates of the loss produced for
different crop species from pollutant exposures. It also estimates the
current and future crop yield reductions — the annual reduction in crop
yield due to the exposure of regional crops to air pollution. The yield
reduction estimates were used by researchers from West Virginia
University to calculate monetary loss estimates. Page, et al. (1980).
2. The ORBES Crop Damage Estimates are Gross Overestimates
Compared to Other Studies
The economic loss estimates projected bv ORBES for the Ohio River
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Basin area differ drastically from previous estimates. Benedict (1973),
Mbskowitz (1980). Neither the Main Report nor the background documents
compare the ORBES estimates with these studies.
While not endorsing the numerical results of the Benedict (1973)
model, it may be the most comprehensive such study to date. Benedict
estimated the primary (farm-level) economic impacts of air pollution on
vegetation at the national level and attempted to "validate" his
calculation with field data. He found that his results agreed fairly
well with individual state field estimates.
Benedict estimated the 1969 loss to field and seed crops, citrus,
fruits and nuts, vegetables, nursery and forests, and ornamentals to be:
$119,647,000 (attributable to oxidants) and $7,590,000 (attributable to
sulfur dioxide). Of this national total, Benedict estimated that
Illinois, Ohio, and Indiana experienced $7.5 million, $3.3 million, and
$1.3 million of the damage respectively. Moskowitz (1980), revising
Benedict's estimates has calculated nationwide oxidant losses to be:
$130 million (1969 dollars) in 1969 and $290 million (1969 dollars) in
1974.
Paqe's estimate of the damage to soybeans, corn, and wheat for the
year 1977 is $452.0 million (1969 dollars) for the ORBES states alone.
Therefore, the ORBES researchers calculated more economic damage in the
ORBES study area for the year 1977 than Moskowitz estimated for the
entire nation for 1974! Moskowitz calculated that only $34.8 million
(1969 dollars) worth of damage occurred in the Illinois, Ohio, Indiana
three state region in 1974. Certainly this difference in magnitude
should have been explored by the ORBES Report. Yet, no mention was made
of this large discrepancy. The fact that the Benedict estimate compared
favorably with state field estimates suggests that the ORBES estimates
are gross overestimates.
3. The Main Report Ts Inconsistent with the Background Documents
on Which It is Based
ifte total crop loss estimates presented in the Main Report do not
agree with those given in the Page report. The Main Report indicates the
total estimated crop losses for scenarios 2, 2d and 7 is $7 billion, $7
billion and $8.4 billion (1975 dollars) respectively, id. at 147; whereas
Page reports the values $8.1 billion. Table 21, $8.1 billion, Table 35,
and $8.3 billion, Table 49.
There are several errors which compound to produce this
inconsistency. Basically, the economic data presented in the Page report
do not correlate with the conclusions reached in the ORBES Main Report.
The "ozone coefficients" in Tables 11 and 13 of the Page report are
different from those reported by Loucks, et al. on page 208. For
example, Loucks recommends the following "ozone coefficients" for
soybeans for the year 2000 (scenarios 2 and 2d): minimum, 2%; "most
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probable", 7%; maximum, 20%. The Page report uses the values: minimum,
24%; "most probable", 28%; and maximum 41%. Tables 11 and 13.
Neither do the time periods over which the two reports aggregate
their cumulative loss figures agree. Tables 59, 61, and 63 in the Page
report are tabulated from 1977 to 2000, while the Main Report discussed
monetary losses from 1976 to 2000. Thus, the OFBES Main Report appears
to report cumulative monetary losses for scenarios 2, 2d, and 7 which are
in error bv S500 million. While this error would raise the ORBES
cumulative losses estimates, either figure is a gross overestimate.
There are two major reasons for the large overestimates of ORBES.
They are: (1) the estimate of ozone dosages are incorrect and (2) the
ozone and sulfur dioxide yield reduction curves for soybeans, corn, and
wheat are too large.
4. The ORBES Ozone Analysis is Based on Fundamental Scientific
Errors; Its Conclusions are Naive
TVo important conclusions emerge from a review of the ORBES ozone
analysis described in Loucks, et al. (1980). First, although some of the
processes that lead to atmospheric ozone formation are reasonably well
understood, this basic understanding is neither described nor employed in
ORBES. Second, the authors relied on a simplistic, vaguely defined,
semi-quantitative analysis of dubious validity, when well defined, more
quantitative (though simplified and approximate) methods of analysis were
available.
4.1 The ORBES Ozone Analysis Ignores Our Fundamental Scientific
Understanding of the Subject
The ORBES researchers relied on simplistic methods to estimate the
ozone impacts of changes in the NOX emissions, claiming that the more
complex ozone models were untested. Loucks, et al. (1980) at 185. Their
simplistic approach certainly avoided anv pitfalls of the untested ozone
models; however, it also avoided making use of most of the well
recognized learning in this area of study.
Because the ORBES researchers reiected ozone models as "barely
beyond the preliminary testing stages," thev found themselves faced with
a dilemma:
Thus, the options for this studv, and for the ORBES work as it
relates to resource effects, were to accept both the "zero change
in OV' and "zero contribution of utilities" asumptions above or
examine qualitatively the evidence on apparent trends in 03, its
effects and precursors, and as appropriate, draw conclusions
expressed in terms of probable or possible responses. Loucks, et
al. (1980) at 185.
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Thus, the authors chose to rely on observations of past ozone
concentrations and projections of future NOx emissions to estimate
future ozone concentrations. Specifically, they prepared a "trend
analvsis" presented in their Figure VIII-7; they "characterized" the
ozone history of the OEKES region over the past 50 years by extrapolating
backwards in time from the highest hourly value reported in Indianapolis
for the years 1974 and 1979. "loucks, et al. (1980) at 205-06. Next,
they extrapolated this "trend" forward in time another tvo decades and
assumed that future ozone concentrations would depend solely on a
proportional relationship (again assumed to exist) between proiected
NDX emissions and regional ozone concentrations. This approach is
incredibly naive!
Although the findings of many studies in the area of ozone
formation are not regularly published, the basic descriptions have been
published and were available to the ORBES researchers. Anderson, et al.
(1978), Anderson, et al. (1976). Moreover, the Environmental Protection
Agency has sponsored numerous reviews which were readily available.
Whitten, et al. (1980), Wiitten, et al. (1979), EPA (1978), EPA (1977).
The text below illustrates three of the numerous fundamental problems
introduced by ORHES1 naive approach.
ORBFS Ignored the Relevance of The Ozone Tsopleth Diagram
The ozone isopleth display provides a description of the
relationship of ozone to the hydrocarbon and nitrogen oxide precursors.
See Figure i. This display was developed by EPA. The diagram shows
ozone concentrations plotted as a function of the hydrocarbon (Hf) and
oxides of nitrogen (NOy) precursor concentrations. The isopleths —
curves of constant ozone concentration — describe a family of concentric
"I" shaped lines. The lines are roughly parallel to the two axes. The
high ozone concentrations can be produced by low precursor concentrations
if the precursor ratio (PC/toOx ratio) is correct.
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EPA developed a technique for estimating ozone concentrations,
based on this isopleth diagram — EKMA — and requires its use as an
ozone control strategy tool in urban non-attainment areas. 44 Fed. Reg.
65667 (Nov. 14, 1979). Several studies have been completed or are in
progress which support the validity different aspects of EKMA. Whitten
and Hogo (1981), Whitten, et al. (1983). While EKMA may be experimental
and may not be suited for many regulatory contexts, it is based on some
theoretical understanding of the ozone formation process. Smog chamber
studies, computer simulations, and atmospheric observations all support
the general shapes of the isopJeth curves.
respite the fact that EKMA is not a flawlesslv validated tool, it
does embody more scientific understanding of this complex phenomenon than
a two point "seventy year trend analysis." Its discussion and use would
have lead to a more meaningful examination of ozone formation and its
effects on vegetation in the ORBES area.
0.50
0.00
0.00 0,25 0.50 -0.75 1.00 1.25 1.50 1.75
NONMETHANE HYDROCARBONS (ppmC)
Figure 1. Standard ozone isopleth diagram.
2.00
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ORRES teiects the Use of Models Developed on Urban Ozone Studies
But Uses Urban Data to Establish Rural ^rends _
The OPBES researchers imply that ozone models are less reliable in
the rural ORBES setting because precursor concentrations are low and
there are natural hydrocarbons present. Loucks, et al. (1980) at 185,
194-196. The chemistry of ozone formation may actually become less
complex at lower concentrations. And while the chemistry of natural PC
species is not fully understood, some knowledge is available. Isopleths
based on urban chemistry should provide useful insiqhts into rural
problems. Moreover, it is difficult to reconcile ORBES rejection of
theoretical models based on urban ozone studies with its use of a "trend
estimating technique" which employs only (two) urban extreme values!
4.2 Example: The QRBES Proportional Model Is Inadequate to
Simulate the Spatial Distribution of Ozone Necessary to
Estimate Crop Damage
The peak ozone concentration depends on the local HC and
concentrations and on their ratio; the rate of ozone generation is
strongly dependent on the HC/tr^ ratio. In an HC rich rural
environment such as found in parts of the OPBES region, the reduction of
power plant HOX emissions may increase this ratio in the plume and may,
in turn, lead to an increase in the rate of ozone formation. The highest
ozone concentration in the plume may not be reduced at all, yet it may be
reached earlier in the day. Hence the reduction of power plant
emissions can actually lead to a longer persistence of high ozone
concentration and, thus, to qreater crop injury. Moreover, since WO
scavenges ozone during the dark hours, the reduction of plume NO
emissions can lead to less scavenging and increased exposure to ozone
formed from precursors emitted from other sources.
TJie simplistic OPBES proportional model would say that whenever
NDX emissions are reduced in a HC rich environment, ozone
concentrations will also be reduced. Yet, as explored above, this is
inconsistent with our scientific understanding of ozone reaction kinetics
in some situations. This example illustrates that the ORBES sunplistic
model is not adequate for performing the kind of sophisticated analyses
required to assess the effects of changes in NDX emissions on the
region's crops.
5. The ORBES Ozone Crop Loss Estimates are Based on Fundamental
Scientific Errors _
Section V of the TIE Report, Loucks, et al. (1980), identifies
much of the relevant ozone effects literature. Based on this literature,
the researchers formulated several hypotheses which lead, in turn, to the
ORBES ozone damage functions. Dr. Jay Jacobson, of the Boyce Thompson
Institute identified fifteen key assumptions and evaluated each in light
of our current knowledge. In most cases, he concluded that the ORBES
researchers had erred in their judgments. Two examples — the limited
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space prevents a discussion of all fifteen — of these errors are given
below. (Dr. Jacobson's review was limited to the ORBES assumptions
concerning ozone crop damage functions.) in disagreement with the ORBES
team, the industry reviewer does not believe that these hypotheses lead
to conservative estimates of crop damage. Furthermore, the yield
reduction curves are based on so little valid data that they do not
possess much reliability. The following paragraphs illustrate some of
the flaws in the QRBES analysis.
Assumption 2; The ORBES researchers assumed that experiments with
repeated dailv exposures to ozone correctly represent ambient
conditions. Uhlike daily exposure experiments, natural ozone episodes
usually occur in limited clusters of 1, 2, 3 or 4 days. They are
separated by intervals of cloudy, rainy, or windy weather with less
polluted air. Wolff, et al. (1977). Consequently, continuous or
repeated daily exposures at constant concentrations do not imitate the
patterns and fluctuating concentrations of ambient ozone. Since plants
are not allowed time to recover in many experimental situation, this
assumption probably overestimates the effects of ozone on yield.
Assumption 15; The author assumes that the dose-response et al.
relationships for sweet com and field com are the same. Loucks, (1980)
at 92, 93, 96. This is incorrect: it is clear from the scientific
literature that sweet com is far more susceptible to ozone in-jury than
field com. Heagle, et al. (1972); Heagle, et al. (1979); Oshima (1973);
Thompson, et al. (1976). Although OPBES recognized differences in
susceptibility between the two varieties, it did not properly account for
the magnitude of the different susceptibilities. The results of a recent
paper by Heagle and Heck (1981) — the same scientists whose data are
relied on by Loucks — show that field com are overestimated bv ORBES bv
a factor of 20 to 75.
6. The ORBES Sulfur Dioxide Crop loss Estimates Failed
Adequately to Consider Relevant Scientific Studies
Tn considering damage to crops, three basic questions always
arise. They are:
* Is there a threshold level of exposure below which no crop
damage occurs?
* Does damage occur without the development of visible markings
on the leaves? (The hidden in-jury question)
* Does simultaneous exposure to sulfur dioxide and other
pollutants produce synergistic effects?
The Main Report is correct in its assessment that the overall
agricultural losses due to sulfur dioxide exposure are "negligible." Id.
at 21. Even so a thorough review of those papers discussed in TIE
Report, Loucks, et al. (1980) Section V, and other current literature,
shows that the sulfur dioxide damage functions for soybeans, corn and
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wheat have been overestimated. This is because ORBES answered the three
key questions without considering all the relevant literature.
6.1 CKBES roes Not Properly Take Account of Plant Sulfur Dioxide
Threshold Responses
The ORBES researchers rejected the use of a damage threshold and
extrapolated the damage function and yield loss estimates to zero
concentrations. They justified this extrapolation by citing research
results which show that very low concentrations of sulfur dioxide can
affect plants. This approach gives equal weight to both acute and
chronic damage and artificially overestimates sulfur dioxide damage.
Current evidence points to the existence of threshold levels for injury.
Irving, et al., (1980). The ORBES researchers should at least have used
the threshold for injury — anv identifiable or measurable plant response
— to approximate the threshold for damage — injury which significantly
reduces the dollar value of the crop or plant. By doing this a more
realistic — though still conservative — estimate for sulfur dioxide
damage would have been made.
6.2 ORBES Uses the "Hidden-Tniury" Hypothesis Without Considering
Key Studies
Loucks, et al. (1980) discusses the evidence for and against the
occurrence of hidden injury and cites various papers discussing the
problem. However, it does not discuss the work of Jones, et al., (1979)
on soybeans; Heck and Dunning (1978) on oats; Brisley and Jones (1980) on
wheat; Davis, et al. (1966) on Arizona range grasses; and the work of the
Selby Smelter Cbmmission (1914) on barley. All of these studies showed
no yield reductions unless definite leaf markings appeared on the
plants. Moreover, the amount of yield loss correlated very strongly with
the percentage of the leaf area destroyed.
These key scientific studies should have been considered in any
scientific study attempting to estimate sulfur dioxide crop damage. Most
were not even mentioned by ORBES. The results of Jones, et al. (1979)
were dismissed as being biased because of certain assumptions that were
made in the paper. Whatever assumptions were made, however, the
experimental results of this study should have been considered on their
merits. Those results showed that there was no reduction in yield
without accompanying leaf destructioni
To support the hidden injury thesis, the TIE Report cites several
studies: Sprugel, et al. (1977 and 1979), and Miller, et al. (1979), are
prominent among them. These papers indicate that significant reductions
in yields of soybeans can occur without accompanying injury symptoms.
Several points should be made. First, the TIE Report itself states that
the Sprugel results should be interpreted in light of the fact that other
pollutants could have caused or exacerbated the damage observed. Loucks
et al. (1980) at 103. Thus, these results can hardlv be depended upon to
produce accurate reduction functions for soybean.
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Sprugel and Miller's yield loss data disagree with those obtained
by previous workers especially in field experiments. Heagle, et al.
(1974); Jones, et al. (1979). While Sprugel and Miller's work was based
on a single replication, the work of Jones, et al. (1979); Heck and
Dunning (1978); and others were found to be statistically significant.
6.3 Minimum Thresholds for Individuals Crops
Soybeans; According to the loucks, et al. (1980), only one study
has been reported that describes the effects of chronic sulfur dioxide
exposure on soybean yield under experimental conditions in the field:
that is, Sprugel and Miller (1977 and 1979). Because of the lack of
replication, however, this studv should be interpreted with great
caution. Results from the numerous studies by Jones, et al. (1979) are
dismissed as being biased. Jones found no reduction of yield unless
there was accompanying damage to the leaf. Many studies carried cut in
the field found no reduction in yield of soybeans growing in the vicinity
of power plants in the Tennessee Valley.
Observations made over the period of years indicate that for
soybeans to develop leaf markings the sulfur dioxide concentration has to
average about 0.7 ppm for one hour or about 0.33 ppm for three hours.
These values are very close to those observed for sensitive plants around
the Sudbury area in Canada by Dreisinqer and McGovem (1970). IMS may
be the threshold for injury; the threshold for damage should be somewhat
higher. Also see Jones, et al. (1979).
Wheat; The authors mention the so-called "Biersdorf" experiments,
Loucks, et al. at 106-07, because they say that the literature dees not
contain relevant yield reduction studies for wheat. The data are
available. Stratmann (1963), and Guderian and Stratman (1968) reported
results of studies in which wheat, together with 22 other species, were
grown in wooden tubs at different distances from a known source of sulfur
dioxide.
These studies show that wheat exposed to doses of 32,000
ug/m3-hr suffered no yield reductions. This dosage is almost twice
that of the dosage alleged to have occured in the vicinity of the Clifty
Creek power plant. Loucks, et al. at 110. Based on these results, the
expected wheat yield reductions around Clifty Creek station should be
zero.
Corn; The GRBES investigators found no pertinent data for corn
yield loss due to sulfur dioxide exposures. Id. at 111-112. However,
based on the fact that one researcher found that sulfur dioxide
concentrations as low as 0.01 ppm for ten minutes could increase stomatal
openings in corn and that another found similar results in broad bean,
the TIE Report concludes that this concentration could lead indirectly to
injury in corn. Id. The hypothesized injury mechanism is that the open
stoma could cause the plants to suffer more from droughts.
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Any quantitative bridge between observing stomatal openings in
beans and estimating the percentage of com yield loss is tenuous at
best. More importantly, it is unnecessary. Although actual yield
reductions were not reported, Guderian (1977) found that corn growing in
a mixture of sunflowers, peas and beans suffered no significant reduction
in green matter when exposed to 1000 ug/m3 of sulfur dioxide for 48
daylight hours and to 2000 ug/fa3 for 24 daylight hours. Both of these
exposures resulted in a doses of 48,000 ug/in3-hr. This is considerably
higher than any dose which would occur in the No. II exposure zone at
Clifty Creek. Loucks et al. (1980) at 106.
Corn is among the most resistant plants to sulfur dioxide. Based
on the assumption that leaf damage would have to occur before reduction
in yield would result, it is unlikely that yield losses would occur as
long as the second highest one-hour exposure in a month is 1.0 ppm.
F. The ORBES Least Emission Dispatch Analysis is Totally unrealistic
1. The ORBES Model for Least Emission Dispatch is Totally
Unrealistic
The ORBES conceptual model for the least emission dispatch (LED)
discussed in the Main Report principally at pages 204-207, and in
Teknekron (1980), is so totally unrealistic that it does not provide any
meaningful insights into the subject. Three fundamental problems with
the Teknekron concept are: system variability, dispatch order, and
region of dispatch.
The meaning of LED varies tremendously from system to system
depending on such factors as excess capacity, generating mix, system
balance, etc. Because none of these factors ware taken into account, any
conclusions from the Teknekron analysis have no direct applicability to
any system. Moreover, because no real world system has the make-up
implicitly assumed by QRBES, the inferences made in the study have no
relation to LED as strategy in the real world.
The Teknekron model assumes that generating units will be
dispatched on a purely least emission basis. This is a naive and
meaningless assumption as any power engineer knows. ORBES assumes that
LED would be implemented on a state-wide basis. This is another naive
assumption; it ignores the fact that there are several interstate system
serving the ORBES region. Given this fact, statewise dispatch would lead
to chaos for the region as a whole.
2. ORBES Presents Misleading Overestimates of the Emission
Reductions Achievable Through Least Emission Dispatch
Teknekron (1980) finds that LED could reduce emissions of sulfur
dioxide by 21 percent in 1985 and 45 percent in 2000 in the QRBES
region. (These percentages vary throughout the Main Report compare pages
15 and 131 — 55% reduction in 2000 — with pages 204-207 — 45%
reduction in 2000.) These are substantial emission reductions. But two
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facts make these reductions verv misleading. First, the LED reductions
are only compared to the high electric growth scenario; they are not
compared with the base case. Second, although emissions may be reduced
within the ORBES region thev will increase at plants immediately adiacent
to the region.
3.] OPBFS Is Misleading Because it rbmpares LED Onlv With the
High Growth Scenario _
points out in their report at cage 121 that the effect
of LED depends on assumed electricity growth rates and other assumptions
that determine the number of new units that are forecast to be built.
New units are subject to the revised New Source Performance Standards and
hence have low emission rates. Each substitution of a new unit for an
existing unit reduces emissions. The more new units there are, the more
effective LED appears to be. Teknekron tested LED only on the high
growth scenario. This exaggerates the potential effects of LED because
assumed high electricity growth rates will result in forecasts of more
new units being built. TMs point is not drawn to the reader's attention
in the QRBES Main Report and is an example of the kind of misleading
omissions which indicate a consistent bias to the study.
3.2 ORBES Exaggerates the Apparent Emission Reductions bv Failinq
to Discuss Emission Increases in Adjacent Regions _
Teknekron notes that some of these apparent reduction result from
the geographic boundaries of the ORBES region. Teknekron (.1980) at 119.
The Main Report merely mentions that some generation might be shifted out
of the ORBES region. Id. at 131, n. 5. This does not adequately alert
the reader to the fact that a large fraction of the emission reductions
are illusory.
The effect of LED for the systems with plants both inside and
outside the ORBES area is to shift generation from units with high
emission rates in the OPBES region to units with lower emission rates
outside of but adjacent to the ORBES region. Hence, the emission
reductions within the ORBES region are correctly reported but the total
emission reductions were less than the reported values. The difference
is the emission increase which occurs outside of the OPBES region.
Teknekron notes that for the year 2000, about 30 of the 45 percent
emission reduction was due to LED. Id. at 119. The impliction is that
the other 15 percent — one third of the total — is due to the shifting
of load outside of the geographic boundaries of the ORBES region. Thus,
while the reported emission reductions may be technically correct
emissions within the ORBES geographic boundaries; thev mislead the reader
because they do not pertain to the effect on the total emissions of the
affected systems.
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This section provides comments on various issues as noted by the
underlined headings.
Mining and Use of Coal—The congressional mandate to ORBES states "The Study
should also take into account the availability of coal and other energy
sources in this region." In spite of the vastness of the coal supply in the
region, the report is for the most part written in a negative posture for use
of coal. It states "In general, the reclamation of surface-mined land for
permanent land use tends to "be a slow process." and notes two years for
quick-growing cover after cessation of mining. It talks about significant
increases in land use for surface mining for a number of scenarios as com-
pared to the base case. These comments and others leave many readers with
the impression that a vast amount of land is being lost forever. It would
seem a report dealing with such an important subject as our nation's future
energy requirement, a matter which will extend beyond the lifetime of those
involved in making and commenting on the study, would not consider a period
of five, ten, or more years as a significant time for reclamation. The
report also fails to point out that under today's reclamation regulations,
many surface-mined areas have been restored to a condition better than
existed before mining and in some cases land has been restored to agricul-
tural use within two or three years.
The assertion that numerous counties would experience a "boom town effect"
from mining of coal for various scenarios is without documentation. Possibly
the authors have been confused with the improved standard of living that has
been realized in the coal areas with the higher price for coal and resulting
higher wages for miners. This has resulted in the building of new homes,
hospitals, and other amenities. The gradual increase in use of coal to meet
future energy needs, even with greater emphasis to achieve more energy inde-
pendence, will produce stable communities-, not "boom towns." The eastern
coal areas, while not heavily populated, can cope with growth in mining.
Conditions in the eastern coal field are not comparable with those in the
West.
Plant Siting—The siting of future power plants for each of the scenarios
analyzed is based on support reports entitled, "The Ohio River Basin Energy
Study" and "Energy Facilities Siting Model" Vol. I Methodology and Vol. II
Sites and On-Line Dates, respectively. The voluminous and impressive
detailed description of the modeling technique in Vol. I yields at best a
program that can only provide very preliminary screening of potential sites.
In fairness to the authors, neither time nor money, allotted for this project
could possibly allow selection of candidate sites that would meet all envi-
ronmental requirements. To evaluate and select sites based on meeting
Prevention of Significant Degradation (PSD) alone would be an overwhelming
task. As noted in the support report, many simplifying assumptions were
made. This was necessary to alleviate the need for making modeling studies
beyond those accomplished to date. The methodology employs a technique of
grading siting components such as water availability, agricultural land,
forest land, impact on air quality, etc. and uses the gradings as input into
the modeling program. In most cases, grading cannot be established by any
quantitative analysis. The grading is highly dependent on the opinion and
judgment of the grador. Thus, the modeling program for site selection is
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highly sensitive to the grading of the many components. In summary, the
results of the ORBES Siting Study should not "be construed as being authori-
tative. Both good and bad sites may have been selected. For purposes of the
scenario development and analyses of environmental impacts, a much simpler
and less expensive procedure could have been used to site future units
through the region without identifying specific counties.
Power Plant Cooling—The report's evaluation of operation and resulting envi-
ronmental impacts of different types of cooling cycles for power plants,
direct cooling, cooling towers, and cooling ponds is totally inadequate and
is presented in a biased manner. Possibly this is a lack of adequate
research. For example, in a supporting research report under "Terrestrial
Ecology" it is stated that quantitative data on cooling tower effects are not
available. Actually, there are many publications citing the quantitative
effects of cooling tower operation. The authors note that, of the alterna-
tives, the direct-cooling cycle is the least consumptive of water, but do not
indicate any credit for this in their evaluations. Likewise, they do not
point out that generating units with cooling towers consume more auxiliary
power and operate at lower efficiency because the turbine cannot attain the
low back pressures that can be realized with a direct cooling cycle. These
two factors result in higher costs for the production of electric power.
Throughout the sections discussing water for each of the scenarios, the
report talks about the once-through cooling cycle with such phrases as
"water withdrawl would increase drastically" with the addition of a large
number of power plants on the Ohio River. The way it is presented leaves
the uninformed reader to believe the water is taken out of the river and not
returned. It is true that more water would be withdrawn if there are more
plants. However, the amount of withdrawl is not meaningful unless it can be
proven that the withdrawl and returned water impacts substantially on the
environment of the river.
In further discussion of the direct-cooling cycle, the report states that the
rise in river temperature caused by the discharge would be damaging locally;
especially to sensitive bank habitats. This statement and the report's gen-
eral assumption of no strict effluent controls on the water discharge from
power plants for all scenarios, "except the strict environmental case,"
indicates the authors are either unaware of the very strict existing regula-
tions controlling discharges from power plants or they have chosen to ignore
them. For example, there are regulations which set limits on the rise in
river temperature caused by the effluents from the direct-cooling cycle.
During the course of the ORBES Study the Core Team was told that such limits
exist and that power plant outputs have been and will be restricted to the
level required to prevent exceeding the specified temperature limits. The
implication of the ORBES Report seems to be that the present regulatory
standards are incorrect. If the authors of the study have developed evidence
to prove this, it should be stated forthrightly if the report is to achieve
its purported goal of providing meaningful information for "decision makers."
Social-Economic Impacts—The report's treatment of social values (p. 107) is
nebulous and lacking in basic scientific quality and authenticity. The
report largely relies on the work of Dr. Potter, "Social Values and Energy
Policy." He was quick to point out major shortcomings in his own research
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(p. 2), as well as possible, the entire ORBES endeavor: "One of these
limitations often is the adequacy of the data for the specific problem." We
agree with his observation since no original data were collected for the
study. In a survey of "The Socioeconomic Dimensions of Electric Power in
the ECAR Region," conducted by Dr. Frank Clemente of the Pennsylvania State
University and commissioned by ECAR, substantial data and information were
obtained from electric power users covering; the economic costs of electric
power interruptions, the value of reliable electric power as defined by con-
sumers in the ECAR region, the basic implications of current and projected
socioeconomic trends in the ECAR region over the period 1960-1990, and the
socioeconomic impact of power plants as viewed by community residents and
leaders. Space does not permit listing results of the survey to identify
the positive benefits of have reliable and adequate electric power as viewed
by respondents. The survey results do not support many of the observations
presented in Section k.B of the Main Report.
As to the item of economics, the statement "Whether utility expansion con-
tributes to economic growth is unknown." (p. 55) raises the questions as to
whether the authors make this as a casual observation or have made studies
of sufficient depth to verify the statement. A survey for the Committee
for Great Lakes Economic Action (encompassing portionf of three ORBES states)
concludes "uncertainty about energy supply" represents one of the "impedi-
ments that must be overcome if new growth in the regional economy is to be
stimulated," "Heavy manufacturing, which long undergirded this region's
economy dominance, is growing slowly in the United States, still more
slowly in the region.," and "Non-manufacturing jobs (i.e., those highlighted
by ORBES) in the region are not growing fast enough to absorb those displaced
by the substitution of capital for labor, absolute losses of employment in
some basic industries, natural increase in the size of the labor force, and
increased participation in labor force." The conclusion of the foregoing
study and the responses to Dr. Clemente's survey document the important role
of electric power and its growth in maintaining the economic health of the
region.
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Public Service Company of Indiana, Inc. (PSI) participated in many ORBES
activities and availed itself of the opportunity to provide periodic inputs
and objective comments throughout the duration of the ORBES Project. The
ORBES Project Team's determined reluctance to accept and/or incorporate
data which was not totally compatible with its views, has now resulted in
what we believe to be a grossly erroneous and scientifically unsupportable
ORBES Main Report. Therefore, PSI and its Chairman, Hugh A. Barker, who
served as an Advisor to ORBES, at this time disclaims the accuracy of the
contents and quality of the ORBES Main Report.
PSI supports the positions expressed in the pooled comments on the Main
Report by the utility industry advisors to ORBES. In addition, there are
two specific issues on which PSI would like to comment. In reviewing the
mandate for the study, the ORBES Main Report emphasized that it was "to
assess the potential environmental, social, and economic impacts of a
proposed concentration of power plants" (page 45). The Report further
stated "In late 1974, Public Service Indiana announced that it would build
a nuclear fueled facility, the Marble Hill plant, on the Ohio River between
Louisville and Cincinnati. Citizen concern intensified" (page 46). The
Report assumed that under the nuclear scenario about 145,000 MWe of capacity
would be installed by the year 2000 (page 10). Yet the Report concluded
that the nuclear substitution case would reduce sulfur dioxide emissions
only 3% over the base case with coal fired generation (page 34). The
Main Report grossly underplayed the resultant vast improvements in air
quality under the nuclear scenario. Also, the ORBES Project Team for
some unexplained reasons expanded its Congressional mandate of 'proposed
concentration of power plants' to a series of arbitrary scenarios which
emphasized existing sources.
In discussing Section 126 of the Clean Air Act, the Main Report commented
on the Gallagher Generating Station hearings. It stated that the problem
may be linked to the Clifty Creek Station and that emissions from Clifty
Creek may contribute to air quality degradation in the vicinity of
Gallagher (page 224). However, such a claim was not substantiated in either
the Main Report or its support documents. In its 'Air Quality and Related
Impacts' document, the authors zealously attempted to demonstrate violations
of the NAAQS for S02 In 1977 in Floyd County, Indiana (page 6). A CAAP
(Continuous Aerometric Acquisition Program) site in Floyd County, operated
by the Indiana Air Pollution Control Division and the county's only quality
assured monitor, demonstrated that in 1977 Floyd County complied with the
NAAQS for S02.
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Harold G. Cassidy
Emeritus Professor (Chemistry), Yale
Save The Valley
Box 813, Madison, Indiana 47250,
Overall Comments
My first reaction on reading the Main Report is one of
admirations so much information summarizing those forty-odd
Phase II publications listed in Appendix B is organized and
presented in so smooth-flowing a style. In this aspect it is
a tour de force, irrespective of the validity of the data.
One has to recognize that these distillations of research
belong on library shelves. They will not gather dust there,
for they will represent a carefully planned data base. The
plan may look easy now, but was surely not easy to make in the
beginning.
Such a data base is badly needed in ecology and energy
areas today. This is for two reasons: one because of the con-
fusion and actual misunderstandings that are prevalent as in
the public relations utterings of some interests; and two, be-
cause of the difficulty of preservation of basic data in a
field that is developing so fast as to lose perspective and
historical lessons from its past.
An example of serving the first need is the careful lay-
ing to rest of the myth that nuclear generation provides cheaper
electricity than coal generation does [pp. 274ffJ.
An example of serving the second is the case of natural
gas. Most of the work on natural gas use is already outmoded
(see below), but at least one can learn from this the effects
of deregulation on an energy source. There is, on p. 39, a
parenthetic bow to the facts in the case.
Specific Comments
These probably do not exhaust the possibilities for
specific comments. However, I have tried to ensure against
serious omissions in the General comments, below.
1. Granted the major emphasis on coal, it is encourag-
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ing to see the very minor attention given to nuclear as an
energy sourcei it constitutes of the order of 1.5% or less of
our energy needs and deserves relegation to minor attention,
even though excessively capital intensive.
2. One rather serious error, in my estimation, is the
blithe assumption that "RNSPS Units already are very clean
units, removing approximately 90 percent of their potential
sulfur dioxide emissions." [p. 156]
This statement may be true for oil-fired and low-sulfur-
coal units with scrubbers, where removal of sulfur dioxide is
not so important. At the same time there is not one unit of
large size. greater, say, than 100 MW, burning high sulfur coal,
which operates reliably. And I suspect that in the nature of
things, large units can not operate reliably with scrubbers.
Thus the "already" is in part false.
The quoted statement seems to reflect the EPA official
position. But this position is based on the institutional
crystal ball. The credibility of much of the air-pollution data
suffers seriously because of this assumption, and the overall
effect is to draw unrealistic conclusions. I suspect that EPA
has been led astray by too much reliance on LG&E reports.
3. Statements such as that in the first full paragraph
on p. 26 suffer seriously, in my opinion, because no mention is
made of the effects of "price elasticity" in changing demand.
Failure to take account of this phenomenon may blind one to
the considerable decreases in demand for energy that have al-
ready occurred. The statements such as that on p. 39 ". . .
conservation could make significant inroads. . ." and that on
p. 54, paragraph 4, where the quoted statement is repeated,
should not be in the conditional. Already some of the problems
of demand and wasted energy are being solved under the impact
of price increases. The ill effects of this omission are
slightly mitigated by the discussion on pp. 224ff.
4. One very serious omission, it seems to me, is the
problem of sludge. This goes along with the lax acceptance re-
ferred to in item 2, above. Some 600 Ibs. of sludge is produced
by a scrubber for each ton of high sulfur, coal burned. The
impact of sludge disposal on local water quality is poorly un-
derstood and surely deserved careful discussion, along with
sulfur-recovery alternatives and coal beneficration.
5. It seems to me that considerable effort should have
been made to emphasize the gross over-building of power plants
in the ORBES, and indeed the national, area. The overcapacity
presently existing for which utility customers have to pay
would seem to be excessive, and suggests that Managements of the
involved utilities have not been responsive to changing condi-
tions, and to their statutory responsibility to serve the public.
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6. My last specific comment is that the quality of the
content of a number of sections of the Main Report would have
been not only improved but also made more up-to-date had more
attention been paid to the highly professional, competent and
objective contributions of Mr. Fred Hauck. Indeed, had such
attention been paid sufficiently for his information to issue
in the Report my criticisms in the five areas above might not
have been necessary.
General Comments
These comments are legitimized by the "... and, indeed,
on any aspect of the ORBES project. . ."in the covering letter
of December 17, from Drs. Stukel and Keenan, They are neces-
sitated by the directive of the Senate Appropriations Committee
when it "directed EPA to conduct a study 'comprehensive in
scope, investigating the impacts from air, water, and solid
residues on the natural environment and [on the] residents of
the region. . .'" [Executive Summary, p. 3].
It has become more and more evident in the last three
hundred years of the Industrial Revolution that to the classical
three material necessities of mankind--food^ shelter, and cloth-
ing- -we must add energy. Of course, energy was always there,
largely implicitly at first. But now the necessity is explicit.
The problems that arise because of this explicit necessity
have increased with the burgeoning of technologies. One begins
to see as a serious problem whether people will continue to
control technology in this increasing energy demand, or
technology people.
The problem should not be trivialized by treating it as a
species of legal game.
There is nothing more difficult than to become crit-
ically aware of the presuppositions of one's thought.
Everything can be seen directly except the eye through
which we see. Every thought can be scrutinized dir-
ectly except the thought by which we scrutinize. A
special effort, an effort of self-awareness, is neededi
that almost impossible feat of thought recoiling upon
itself—almost impossible but not quite. [E. F.
Schumacher, A Guide for the Perplexed. Harper and
Row, New York, 1977, p. 44.J
Nor should the problem be ignored entirely, as it seems to
be in the Main Report. We need some discussion of philosophical
alternatives to complement the possible scenarios. I do not
propose to remedy this, as it seems to me, defect; nor would I
feel entirely competent to try. At the same time I would like
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to indicate the directions that such discussion might have
taken.
Present thinking in this area of pollution production and
control may attempt to deal with issues raised in this Report
by economic theory using the concept of "unpriced values." The
value called, for example, "quality of life," not having a mar-
ket price, resists quantitative approaches. [For an extended
discussion see John A. Sinden and Albert C. Warrell, Unpriced
Values. Decisions Without Market Prices. John Wiley & Sons,
New York, 1979.J
The term "pollution" may require unorthodox analysis.
Pollution is what someone does not want. For this reason it is
never unilateral. This fact can be the genesis of conflict or
preferably of rational compromise.
For example, some of the people of my Valley of the Ohio
River find sulfur oxides and particulates polluting in respect
of their effects on the 'quality of life' and, more specifically
in respect of their effect on health. Local physicians agree
with us. But to the utility our demand for clean air is pollut-
ing since it would prevent them from the reasonably legitimate
activity of getting rid of their waste products inexpensively.
A modern approach suggests that both sides should pay for
their privileges: the one for getting purer air the other for
using the environment their way. Negotiated prices would then
presumably permit market forces to operate. Values then may
take on prices. This may be called the hard-boiled, or mechan-
istic, or tunnel-vision approach to the environment. It
ignores those values on both sides that are literally priceless.
It seems clear that overt response of people to pollution
follows a probability distribution such that at any given level
of a pollutant there will be a certain number of people who
will be hardly affected, a number of people subclinically af-
fected, and some who will be clearly sickened by the pollution.
It may be accepted objectively that for the last of these the
pollution is bad to an extent measurable in part by hospital
costs and undertakers' charges. The pollution may be acceptable
to the majority of people. Perhaps they-have grown up all their
lives in polluted air. There must be thousands of people who
have never breathed pure air. The pollution is irrelevant to
the first group except as it destroys clothes and finishes on
cars or houses, or produces such non-health costs. That life
expectancy and illness in the neighborhood of the polluter may
be affected relative to the State average may not be known to,
or perhaps even considered important by, the majority of
citizens.
An example pertinent to this point is that of the Youngs-
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town area Save Our Valley members who wish "to 'save' jobs
from being lost by the closing of steel mills in the area"
[p. 295].
In any event, it seems likely that the values perceived by
the three groups will differ, and may even appear irreconcil-
able.
At the same time, the source of the pollution--let's say a
power plant--will assign to its right to rid itself of its sul-
fur oxides and particulates a value related at least in part to
the cost of scrubbers and precipitators to remove a specified
percentage of the waste material.
Here, then, in a situation typical of all--certainly at
least, most--pollution problems: a mix of values some of which
have rational price tags; some of which are and must remain un-
priced. Further, the analysis is relativistic. Strong biases
are likely to be imposed.
If a just solution of any of these problems is to be
reached then the protagonists: the citizens' group, the utility
and the regulatory agency must be prepared to recognize and
agree on boundary conditions set by the nature of the case.
For example, is the health of the affected people over-
riding. It may be that some other value such as jobs may be
thought overriding by the affected people, as in the Youngs-
town example cited above. Here health must take a secondary
position.
In another example, as reported in Business Week. February
2, 1976 "Heart disease deaths per 100,000 population: Ohio,
382; Steubenville, 500.5; nearby Mingo Junction, 606.2." Bron-
chitis deaths at Steubenville double the average for Ohio; at
Mingo Junction almost five times as many as the Ohio average.
Only the ill move away from this polluted area--under the
advice of physicians.
Another boundary condition is demographic. For example,
there has been an out-migration of people from this area, as
well as a fall in the birthrate, so it may be that job demand
will continue to fall unless some artificial stimulus is
applied--assuming that the people would benefit therefrom.
This implies a decreased need for more generating capacity in
the near future.
One important boundary condition that needs to be settled
on is the issue of growth. To reject a new power plant on the
ground that it is not needed is to be tagged an exponent of "no
growth." The issue is so heavily loaded with emotion that it
becomes a major challenge to obtain a hearing for someone who
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would ask whether growth in one direction might not profitably
be replaced by growth in another. For example, the mental and
physical energies released by not building an unneeded plant
may find profitable constructive growth in an area of imagina-
tive, improved services and increased efficiency of the exist-
ing utility. Then, everyone profits.
This "jobs" issue is so persistent, and apparently so im-
pressive to the unthinking listener or reader, that it seems
worthwhile to recall an ERDA-financed study by the Lawrence
Berkeley Laboratory which concluded that "a dollar spent on
electricity produced fewer jobs than almost any other option."
For example, "one million dollars spent buying electricity
produced about 44 jobs. On the average, one million consumer
dollars produced 80 jobs. Buying more efficient household
appliances produced 96 jobs per million dollars." [Ron Lanoue,
Nuclear Plants; The more they build^ the more vou pay. Center
for Study of Responsive Law, 1976, p. 15.J
Still another boundary condition has to do with need. Be-
cause a utility asks the Public Utilities Commission for the
go-ahead to plan and build another power plant does not by any
means certify that it will be needed. The average citizen finds
this hard to believe. However, several recent studies have
exposed the tax incentives that make it highly profitable to
build, and that even encourage building, more and more plants.
(See, for example, Duane Chapman's Report in the ORBES series.)
If these (and there are other) boundary conditions can be
agreed upon by the negotiators the source of controversy may
well disappear, and with it ill-feelings and recriminations.
For example, if thorough analysis shows that a plant is not
needed, then there is no problem about what to do with its
proposed pollution. Such an analysis by Fred Hauck [consulting
engineer and President of Save The Valley] in the case of PSI
has provided a paradigm case. In 1973 PSI forecast that in
1985 their peak demand would be 7120 MW. This was during their
pleading for permission to build Marble Hill. Mr. Hauck, in-
voking the rational constraints and boundary conditions I have
indicated, set their forecast 1985 need at a maximum of 4450 MW.
Since then their annual forecasts have steadily declined: by
1976-7 it had been projected at around 6000 MW. The quarterly
report of the end of June, 1980 estimates the 1985 need at
4650 MW! Gibson Unit #5, deferred, is yet to go on line. Thus,
without Marble Hill PSI is likely to reach around 50% excess
capacity by 1985.
Having agreed that a new plant is not needed, the negotia-
tors may turn to the matter of jobs since it is desirable to
replace a negative with a positive. Here it may well be poss-
ible to show that there are plenty of opportunities in service
areas that can open up new job opportunities. Further, there
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are industries that are practically non-polluting that can move
into an area where the pollution limit has been reached, and
furnish jobsi There is always the possibility of work to de-
crease pollution!
In the present situation in our Valley it is the citizens
who suffer when environmental pollution is increased. The
power company management often live at a distance. Actually,
it seems that these companies are run by accountants, whether
they are presidents of the company or lesser cogs in the organ-
ization. Decisions are made on even the narrowest margin of
the "bottom line." I have suspected that the person who really
runs the company is the person who programs the computer. He
tells it what to say, and its word may too often be accepted
uncritically as a pronouncement from on high.
The fact is that uncertainties are bound to enter into any
judgment--which is one reason for management, of course. These
may be hidden in data which appear sharp and clear because
couched in numbers. But uncertainties may also hide in un-
recognized variables, in human error and in human intransigence.
In earlier times a manager might rely upon his knowledge of
human nature. If the bottom line yielded him less profit than
he could get by screwing the clamps on his customers, he might
accept it in the conviction that in the long run all would be
better off. But the larger the organization, the more diffi-
cult to operate this way. For with a half-million customers a
tiny margin per customer multiplies to a too-tempting number.
Besides, a policy decision based on the bottom line saves
decision and furnishes a firm legal base in case things go
awry. Rigidity is tempting, but may be self-defeating in the
long run.
I have tried in these few general comments to show the
type of discussion which in my opinion would have strengthened
the Main Report. At those working sessions I was able to attend
I gained the impression that there was strong opposition to in-
cluding this kind of philosophical-technical-boundary condition
type of discussion in the Report. It seems to me that such
discussion would have been of signal benefit to all sides in
this complicated network of issues.
I wish to end on the positive note that this monumental
effort by the Core Team and the Project Management Team deserves
to bear fruit. It has given us a remarkable example of the
value of openness and rational discussion in attacking many
difficult and emotionally laden problems.
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Tom Duncan
President
Kentucky Coal Association
Lexington, Kentucky
This comment should be prefaced with the statement that Dr.
James J. Stukel and Dr. Boyd R. Keenan, project co-directors,
have performed well and fairly in a difficult situation. They
and a number of the Core Team, as well as many support re-
searchers, have been willing to hear with open minds dissenting
or challenging comments from advisory committee members and
others.
But the fact is that, whether from the very real, if
subtle, influence of the Environmental Protection Agency role,
or the obvious biases of many of those involved in the ORBES
project, or both, some strong prejudices permeate the Main
Report. Indeed, this was almost inevitable, given the approach
and nature of much of the preliminary work, unless the authors
were to repudiate much of that work. I think that should have
been done, although recognizing how quixotic such thoughts are
in these circumstances. Without knowing the inner workings of
the final drafting process, one would think only an awareness
of such prejudices and a sense of fairness could lead to such
statements as that found in Section 6.1 on page 141:
"MORTALITY. As discussed in section 4.6, substantial con-
troversy exists about the quantification of deaths related to
air quality. Some researchers believe that only total suspended
particulates can be related firmly to increased morbidity and
mortality and then only to cardiovascular disease, not to res-
piratory disease. Many other researchers believe, however, that
a growing body of epidemiological evidence exists to support the
hypothesis that the annual average exposure to sulfates—or
something closely related to them—results in an increased mor-
tality rate."
How, pray tell, can anyone grapple with a statement that
"Many...believe...a growing body of epidemiological evidence
exists to support the hypothesis that...exposure to sulfates
or something closely related to them results in an increased
mortality rate"? But the report seeks to use such a shaky reed
as a springboard to projections of "sulfate-related deaths"
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through the year 2000. These projections are sprinkled liber-
ally throughout the report. Unfortunately, the caveat is not
so well emphasized.
Indeed, the picture painted by the report might well be in
much better focus if several caveats sprinkled through it were
boldly set forth at the start, perhaps in a special section.
For example:
(In Section 2.6, page 55) "The most troublesome method-
ological problem, but an unavoidable one, is the argument from
ignorance....Several examples illustrate this problem in the
case of ORBES....the health benefits from electricity such as
its use for life support systems and air conditioning are not
entirely clear....Nor is there information about what would
occur if this electricity were not generated. In addition,
whether utility expansion contributes to overall economic growth
is unknown...."
(In Section 4.7, page 104, footnote 39) "The most recent
data were used for each of the social measurements discussed in
this section. In some cases, however, data from 1970 consti-
tuted the only available information. It is recognized that
updated information could change some of the conclusions in this
section."
(In Section 5, page 117) "Among the coal-dominated sce-
narios, environmental standards are assumed to be the same for
the base case, the high electrical growth case, and the electri-
cal exports case....The controls for land reclamation are
derived from federal standards prior to the 1977 Surface Mining
Control and Reclamation Act." (In view of that, it is startling
to read in the same paragraph the statement that "With regard to
environmental protection of air and land quality, then, the base
case, the high electrical energy growth case, and the electrical
exports case reflect the full implementation of current poli-
cies. ")
(In Section 15.2.3, pages 288-289) "It also should be noted
that the harvesting of biomass resources in logging and agricul-
ture could lead to a higher incidence of occupational injury
than the extraction of conventional fossil fuels, including coal
mining."
Since a portion of our comment on the preliminary draft of
the report was directed to the lack of such caveats as quoted
above, this is not an attempt to belittle them. But an open-
minded reading of the report will, I believe, clearly show
underlying biases that simply cannot be overcome by a few token
disclaimers. The biases, I believe, are primarily anti-growth
and anti-coal. Although only a page-by-page analysis would make
the case fully, I will try in the space allotted to point out
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some reasons for that belief.
It is interesting that, at a time when the EPA, which con-
tracted for this study, was attempting to make "acid rain" or
"acid deposition" its new battle cry against coal-combustion
emissions, the report would conclude (page 296):
"The single issue within the broad context of continued
(and perhaps increased) reliance on coal that could produce the
most conflict is the long-range and transboundary movement of
air pollutants across state lines. Since ORBES began in 1976,
this issue has become perhaps the most prominent one in the
region. It affects employment levels in the coal-mining indus-
try as well as industry in general. It triggers emotions that
are easily translated into political controversy. Some feel
that such political controversy, both intrastate and interstate,
could threaten the stability of the American federal system."
That strong assertion must be taken along with the state-
ments (in Section 12.1.2.2, page 229) that "Although the acid
rain phenomenon is not understood fully, it is clear that long-
range transport plays an important role"; and (page 236) that
"The policy debate that will take place in the upcoming Clean
Air Act review will include at least three distinct points of
view. The first argument, whose proponents will include many
leaders from the ORBES coal-producing states, is that present
energy needs and associated national security matters are so
serious that additional attention cannot be paid to questions
of transboundary air pollution " Not being equipped with
such mind-reading powers, I cannot flatly refute the pre-
diction in the latter statement. But its apparent implication
that the coal industry will take such a stand is absurd at best.
The coal industry has encouraged attention to the question, in
fact has sought to get the EPA to leave the pulpit and go into
the scientific arena on the issue, and is cooperating in an
effort to get reliable data, which the EPA and others seeking
precipitate action seem strangely reluctant to compile.
In the report's various treatments of deaths and injuries
(for example, Table 7-3, page 173), a basically straight-line
projection seems to have been made. On the other hand in
Section 15.2.2, page 286, after discussing problems with wind
energy conversion systems such as the occasion when an eight-ton
blade was thrown 750 feet, the report casually assumes that
"Ultimately these issues will be resolved by technological im-
provements in wind turbine systems." Throughout the report
there is a tendency to assume that problems associated with coal
will continue or compound, while problems associated with other
energy sources or with lack of growth are discounted, ignored or
acknowledged only with a disclaimer that information wasn't
available.
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Information obviously must be limited even in a four-
million-dollar study. But, as stated earlier, the course chart-
ed at the start of the study fairly well determined the final
dilemma, despite all the computer models, statistics and techni-
cal arguments generated in the meantime. A preliminary report
mentioned, I believe, only in footnotes and Appendix B in the
main report is a case in point. It is "David S. Walls, Dwight
B. Billings, Mary P. Payne and Joe F. Childers, Jr., University
of Kentucky, A Baseline Assessment of_ Coal Industry Structure
in the Ohio River Basin Energy Study Region, Subcontract under
Prime Contract EPA R805588." Its bias against the coal industry
is such that the only positive factor mentioned is wages paid,
while negative factors were pulled from secondary and remote
sources or, on occasion, apparently invented since the cited
source certainly did not reflect the same picture. But the
point is not just the unrealiability of the preliminary report,
it is the position in which it places the authors of the main
report they- are left with practically nothing good to say
about the coal industry except in terms of jobs. And that seems
generally to be placed in the context of the danger of creating
"boom town" effects. It is interesting that one positive state-
ment on employment comes in the context of using scrubbers
(Section 8.4, page 186): "The slightly higher labor demand under
the strict control case as compared to the base case is inter-
esting in light of the dispute over the use of scrubbers. Such
higher employment benefits, plus the fact that the high-sulfur
coals in the ORBES region would be more competitive and keep
more miners employed, are a tradeoff with the costs of building
such systems." But whatsis really puzzling to the non-academic
mind is how the question of jobs relates to the flat statement
regarding coal-dominated scenarios that (Section 5, page 116)
"Also common to all the scenarios is the assumed regional eco-
nomic growth rate: an annual average rate of 2.47 percent
between 1974 and 2000." If, in fact, that is saying that none
of the various scenarios would change economic growth, surely
something is missing; and if it is saying that such mundane
matters were of no concern or not enough concern to warrant
pursuing, than I say the four million dollars for the study went
in the wrong direction. But, on that, I suppose I'm just being
repetitious.
The biased approach comes through in little ways, too. In
Section 3, pages 7 and 8, we find, "In general, the reclamation
of surface-mined land for permanent land use tends to be a slow
process. Data are available for only a quarter of the region's
1.6 million affected acres. These data show that this portion
has been affected for 10 years and has not yet been fully re-
claimed." Unless "these data" came from lists of abandoned
lands or those with bonding problems, they are a bunch of junk.
And, if better information wasn't sought, this is again the case
of ORBES1 taking the convenient route to disparage the coal
industry.
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The fact is that all too frequently negative data seemed
perfectly acceptable, no matter how fragmentary, while great
efforts were made in the other direction, such as the projec-
tions of crop losses because of emissions, certainly on grounds
only slightly firmer than the "sulfate-related deaths." And,
just as with mortality projections, there is no attempt to put
a value on losses that would occur if the electricity were not
generated and available. In this connection, one might note
that the Associated Press in an October 16, 1980, story said
that the National Oceanic and Atmospheric Administration re-
ported that "The final toll from this summer's heat wave is
1,265 deaths....Most of those who died from the heat were
either elderly or poor and lived in homes or apartments that
were not air-conditioned, said the agency." It also said that
"electrical energy use was 5.5 percent above normal, a record."
Certainly this information came late for use by ORBES. But
after watching a good bit of the ORBES activity, one could have
some questions whether such pedestrian figures as deaths or
production losses linked to the lack of electricity, whether
because of costs or capacity, somehow don't have the attraction
for computer-equipped, EPA-funded researchers that they find in
projecting deaths, injuries, illnesses and losses "caused" by
familiar targets like the coal and electric utility industries.
One question that perhaps would be answered in the pre-
liminary research report, still could use some treatment in the
main report. It involves the statement (in Section 14.2, page
259) that "Under the natural gas substitution case, total
revenues collected from consumers between 1976 and 2000 would
be lower (by about 26 percent) than the total revenues collected
under the base case between the same years." The question is
what consideration, if any, was given to partial and/or full
decontrol of natural gas prices at the wellhead. Developments
on that line could make these calculations wrong, not just shaky.
With all these questions and criticisms, it would be unfair
not to point out specifically one finding of some comfort to the
coal industry (in Section 15.1, page 275) : "One key finding is
that, under the current fiscal and regulatory schemes prevalent
in the ORBES region, coal-fired units have a slight cost ad-
vantage over nuclear-fueled units. Perhaps even more significant
for future energy policy and development is another key finding:
without present federal tax and other fiscal policies that favor
capital-intensive production (including the nuclear industry),
the cost advantage of coal-fired over nuclear-fueled generation
would be substantially greater...."
But such crumbs are precious few. The main report, built
on the unsound foundation of "studies" involving too much bias
and over-reaching, cannot stand, despite ameliorating language
sprinkled through it in an apparent.attempt to salvage a
semblance of objectivity and reliability.
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W. C. Gerstner
Executive Vice President
Illinois Power Company
Decatur, Illinois
These comments on the Ohio River Basin Energy Study (ORBES); MAIN Report
have been prepared in response to the project office invitation. Prior to
presenting comments, we want to point out that our Company being represented
on the ORBES Advisory Committee is not to be interpreted that we agree with
methods used or the results indicated in the report. Further, we find sever-
al aspects of the project that make the objectivity of the results of the
ORBES effort questionable. These aspects will be described in our comments.
Institutional Considerations
It is not reasonable that comparative coal and nuclear costs should be
discussed in this section of the report. A coal versus nuclear comparison
does not appear to be in the directive mandate from Congress. The discussion
of the comparative economics shows a bias on the part of the authors and
editors. This analysis was performed by an individual from outside the ORBES
region who is known to have a definite anti-nuclear bias. The region is rich
with nuclear expertise and has many operating and soon-to-be-operating
nuclear units. The comparative analysis considers the Southern Indiana area
of the region. Southern Indiana currently has no operating nuclear units.
Yet, this area is identified as being "typical" of the region.
The basic argument in the nuclear versus coal comparison centered on
taxes and tax subsidy provisions. These provisions were created by legisla-
tion to help stimulate economic development. What is not presented is the
total impact on income and outflow to every customer if their provisions are
not in place. The basic assumptions and methodologies described in the
support research are questionable and without sufficient documentation within
the referenced report to support the conclusions. For example, the analysis
compared coal and nuclear units installed in different time periods, thus
reflecting a lower installed cost for the earlier installed coal plant with
resulting lower tax subsidies. Also, the widely differing construction
periods between coal and nuclear installations result in benefits to the
coal alternative.
Fuel Substitution and Conservation Emphasis Scenarios
The fuel substitution and conservation emphasis scenarios are compared
with one another. Ihe only common factor in the comparison is the economic
growth rate. We question whether or not there may be other assumption(s)
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that may also be controlling the model and whether or not other growth rates
are valid for a proper comparison between the scenarios.
We also question why the natural gas substitution scenario is the only
scenario where consumer costs are calculated. By not presenting the consumer
cost for all of the scenarios the authors show a lack of thoroughness and
create the impression of bias.
Of particular concern is the calculation of consumer costs for the
natural gas scenario. Not defined is whether the total revenue impact is
calculated for all areas of the ORBES economy or only for the electric
utility industry. Thus, the costs to other industries and the final impact
to the consumer may not be properly reflected. It is also questionable to
imply that large quantities of natural gas will be available in the future
for the generation of electricity0
General Concerns
An overall direct concern in the Main Report is the manner in which the
authors and editors utilize some of the conclusions of the support research
efforts. Throughout the Main Report conclusions are presented as if they are
undisputed facts rather than presenting the results by saying "support stud-
ies indicate". Misleading to the reader is the use of words like "substan-
tially," without being quantitative, and "assuming," when subsequent conclu-
sions and results are stated without reminding the reader that they are based
on assumptions. The authors also point out to the reader that certain areas
are controversial. The authors then frequently only present results and
findings only from one side of the controversy,.
We contend that the USEPA failed to maintain objectivity or adequate
control in managing the subject study. USEPA paid for a large percentage of
the Teknekron work on air modelling outside the grant arrangement for the
ORBES project. The Teknekron work was supplied to ORBES and provides the
basis for the air quality analyses promulgated in the ORBES final report.
The Teknekron models and theories have not been subjected to peer review to
any degree. To the degree that the Teknekron work has been reviewed, it has
been subject to question. Whether the Teknekron work is valid or not, and we
do not believe that it is, it was not objective of the USEPA to introduce
this material into the ORBES effort as though it were independent research.
Many of the ORBES project conclusions have been released to the press
before the report was finalized and subjected to peer review. See the UPI
article appearing in the February 4, 1981 Washington Post as an example.
USEPA should not have allowed their grant recipients to perform in such an
irresponsible manner. Leaking such potentially inflammatory, unreviewed, and
draft material to the press certainly strikes of questionable objectivity and
confirms our belief that the scientific bases of the conclusions of
the report are so weak that flamboyant headlines are required to gain
attention.
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Damon M. Harrison
Kentucky Department of Energy
Lexington, Kentucky
The Ohio River Basin Energy Study (ORBES) was undertaken to describe the
effects of various energy futures in the Ohio Valley. The final report will
be of interest to all citizens and policy makers concerned about the social,
economic, and environmental aspects of energy development, particularly for
coal-fired electric power generation. The study was commissioned by the U.S.
Senate in response to citizen concern about utility plans to construct addi-
tional electric generating units on the Ohio River. The work was funded by
grants from the U.S. Environmental Protection Agency. The research was
carried out by over 100 university faculty members at 8 institutions, in-
cluding the University of Kentucky and the University of Louisville.
Encouragingly, under a number of different energy futures (including
business-as-usual, strict environmental, strict conservation, and high
electricity growth) the environmental effects of the utility industry in the
year 2000 will be substantially less than those in 1976 - even with signifi-
cant growth in electricity production. This Is most notable in the decreases
projected for utility sulfur dioxide and particulate emissions, which should
result in fewer adverse effects on air quality. In many cases, only slightly
different impacts were predicted for scenarios based on strict environmental
controls or strict conservation measures. This is partly due to the fact that
environmental controls on new plants are already quite strict and the replace-
ment of older plants with newer, better controlled plants leads to lower over-
all environmental impacts.
The positive nature of these findings was obscured by the emphasis the
report placed on cumulative (thus magnified) differences among the scenarios.
Thus, for example, nowhere in the report is it pointed out that in all
scenarios - except where environmental laws are ignored - the deaths alleged
to result from air pollution will be significantly lower in the year 2000
than in 1976.
Possibly the major criticism of the report, however, is the lack of dis-
tinction made for the readers between findings which are highly certain and
reasonable and findings which are highly speculative, controversial, and
admittedly imprecise. The latter would apply particularly to conclusions
reached concerning sulfate-related mortality, ozone-related crop damage, and
"boom-town" social conditions. The authors pointed out some of the short-
comings of their data, but this did not restrict their conclusions. These
problem areas are discussed in some detail below.
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Sulfate-related Mortality - Atmospheric sulfate is formed from sulfur
dioxide, which is released into the air during the combustion of fuels, the
largest source being oil and coal burning power plants. The report concludes
that "a growing body of evidence supports the hypothesis that the annual
average exposure to sulfates - or something closely related to them - results
in an increased mortality rate." Furthermore, the report assumes that the
actual mortality rates can be calculated from known or projected sulfate
levels throughout the region. Such calculations indicated that exposure to
this single air pollutant was responsible for up to 11% of all the deaths
which occurred in the ORBES region in 1975, which would make this far and away
the greatest health concern of any aspect associated with energy generation.
By comparison, the report suggests that the mortality associated with sulfate
exposure resulting from a coal-fired power plant is 100 to 1,000 times greater
than all the possible deaths associated with a nuclear power plant of the same
size. Based on this difference, it must be considered surprising that the
study did not recommend a rapid shift from coal to nuclear electric power
generation.
One might ask, how reasonable is it to assume that large numbers of
the general public are dying each year from sulfate exposure? Not very. All
of the numerous scientific panels that have examined the available evidence
have concluded that there simply is no justifiable basis for any sulfate
standard or for any claim that sulfate levels are, in fact, related to
mortality. These include reviews by the National Academy of Sciences, the
scientific review panel for the U.S. Environmental Protection Agency, the
National Institute for Environmental Health Sciences, and the World Health
Organization, to name a few.
Claims of sulfate-related mortality have been based solely on statistical
analyses and the above groups, as well as many others, have found this work to
be seriously flawed and the conclusions unwarranted. Statistical analysis is
full of pitfalls and correlations cannot be viewed as cause-and-effect re-
lationships. The studies have been characterized by poor data, uncontrolled
variables, and internal inconsistencies; for example, some of the correlations
suggest that pollution is good for people. In spite of this, such work con-
tinues to be used by some people to "estimate" the effects of sulfate ex-
posure on mortality. The uncertainty of the estimates is acknowledged by
setting the bottom limit on mortality at zero deaths. Thus, we see in the
ORBES report a mortality estimate ranging from 0 to 489,000. The next step
was to determine a "best estimate", which was one-third of the maximum of
163,000 in the above example. At this point the zero death possibility was
dropped from the discussion. The fact is, there is no justification to
assume that 163,000 is more reasonable number than zero.
The limitations of such analyses may have been apparent to the authors
of the ORBES report, but they certainly are not apparent to many readers and
reviewers of the report. The following quotation from the Louisville
Courier-Journal (February 2, 1981) is not untypical:
"Under all five coal scenarios, the impact on the region's
health would worsen the report estimates that 163,000
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people could die between 1975 and 2000 because of sulfate-related
diseases. If stricter environmental rules were adopted, that
number could be reduced to 109,000."
Such an assertion is absurd and surely not intended by the ORBES authors.
How could one attribute any significance to a difference of 54,000 between two
numbers when one number could be 0 to 489,000 and the other 0 to 327,000? One
could not.
This lack of objective and responsible scientific reporting detracts from
an otherwise credible review of the health effects related to coal use. It is
certain that many unwarranted and irresponsible conclusions will be drawn from
this report. It is unfortunate that the report did not rely on the conclusion
reached by Dr. Edward Radford in a support study carried out for ORBES.
Dr. Radford, an environmental epidemiologist at the University of Pittsburg,
reported that the effects attributed to acid derivatives of sulfur dioxide
(sulfates) were unreliable and that all air pollution mortality together is
only a small fraction of that suggested by the statistical studies, concerning
which, Dr. Radford wrote:
"Allegations of much more significant health impacts from
urban air pollution, which are based on multiple regression
techniques, simply display the clear inadequacy of this method
for evaluating health effects in complex social groups where
major confounding variables such as cigarette smoking cannot
be taken into account." - Impacts on Human Health from the Coal
and Nuclear Fuel Cycles and Other Technologies Associated with
Electric Power Generation and Transmission, prepared for Ohio
River Basin Energy Study (ORBESJ, July, 1980.
To return for a moment to the initial statement that "a growing body of
evidence" supports the theory of sulfate-related deaths, it should be pointed
out that there is little - if any - new evidence, only new studies which con-
tinue to count tremendous numbers of sulfate-related disease deaths (although
none are known in the medical profession) and which continue to document their
results by referring to the same earlier, discredited work.
Crop Damage - The ORBES report concludes that current levels of ozone and
sulfur dioxide throughout most of the region are causing significant crop
losses, even at levels well below the air quality standards. In 1976 the
crop losses in the ORBES region attributed to the utility contribution to
ozone were estimated to be 14% of the soybean crop, 8% of the corn crop, and
6% of the wheat crop. Although power plants do not emit ozone, they were
estimated to be responsible for 40% of the atmospheric ozone levels in-
directly, through emissions of nitrogen oxides.
The predicted losses were said to be occurring in the absence of any
visible damage to the plants. Since small losses in the absence of visible
injury are, for practical purposes, impossible to prove or disprove, this is
and has been a subject of some controversy. For the many farmers who will
read or read of this report, the implication is that a major study has pro-
vided new evidence that air pollution from power plants is causing significant
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crop losses amounting to several hundred million dollars per year in the ORBES
region. Nothing could be further from the truth. The Institute for Ecology,
which provided the study, did not obtain any new evidence at all nor did they
carry out any experiments on crops. As with the mortality studies referred to
above, the authors merely reviewed the available literature and withdrew
selective data bearing on their hypothesis.
The most questionable aspect of this study lies in the derivation of
equations for predicting crop damage which are based on the assumption that
crop losses are proportional to cumulative ozone exposure. In other words,
exposure to high ozone levels for a short period is assumed to be equivalent
to exposure to low levels for a long period. Such an assumption can not be
supported by the data cited in the report. In fact, in the author's data for
soybeans, at equal cumulative exposures, a high concentration of ozone
(0.07 ppm or parts per million) gives much higher damage than a low concentra-
tion (0.02 ppm). Thus, it is seen that cumulative exposure overestimates the
damage at low concentrations - by nearly 3 times in this case. The yield data
is so poor that one cannot always find a relationship between the duration of
exposure and crop loss: exposure to 0.1 ppm ozone for 258, 552, and 798 hours
gives reductions of 66%, 55%, and 66% in plant fresh weight, respectively.
Data such as this from several studies were combined and the authors deduced
a "statistically significant" damage function by a best fit of the data. No
best fit was obvious; thus a regression analysis was applied. Since the fit
was still not good, further data were arbitrarily thrown out to make the
function "more statistically significant". In truth, there is nothing signi-
ficant about the damage function except the statistics.
The most surprising finding after all of this analysis was not mentioned
by the authors: that is, that crop losses in 1976 due to background levels of
ozone (0.03 ppm, the level found in pristine, unpolluted areas) exceed those
due to the ozone levels which were attributed to utilities.
The next area of certain controversy, but uncertain accuracy is the large
proportion of ozone that was attributed to utility nitrogen oxide emissions.
There is no evidence that ground level ozone in rural areas is largely due to
power plant emissions. Researchers are working on methods to determine ozone
concentrations from nitrogen oxide and hydrocarbon emissions, but none are
presently available. Levels of hydrocarbons were not considered in the report
to be important determinants of ozone levels (power plants do not emit signi-
ficant amounts of hydrocarbons) - an assumption contrary to present scientific
opinion in this area. The most significant sources of ground level ozone
precursors are known to be urban sources of hydrocarbons and nitrogen oxides
(predominately mobile sources). The authors speculated that urban nitrogen
oxides might be scavenged by plants - this speculation is unsupportable. The
authors judged that 40% of the regional ozone levels in 1976 were due to
utility nitrogen oxide emissions. This figure is based on a long list of
assumptions rather than calculations. Taken all together the entire argument
for ozone-related crop losses is a "house of cards", which can be shaken to
the ground by the slightest breeze.
Boom-Town Social Conditions - The major social consequence of an expanded
utility industry in the ORBES region would be due to the increased production
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of coal and the increased employment of coal miners. The study predicts
"boom-town" effects for at least 79 to 88 of the 152 ORBES counties with coal
mining. This conclusion is clearly erroneous and based on a parameters which
is not related to community growth problems - namely, a growth of over 200%
in coal mining employment between 1976 and 2000. In other words, if a county
had 100 miners in 1976 and 300 in the year 2000, boom-town conditions would be
predicted. Coal production was predicted to nearly double in the ORBES region
by the year 2000 - a growth rate that results in a 2.3% annual increase in
coal production. Coal production in Kentucky increased at an annual rate of
5.1% between 1965 - 1975 (or over twice the rate predicted by ORBES). A
number of Kentucky counties grew at even greater rates during that decade,
with no evidence of any "boom-towns".
The ORBES project was an experiment - an experiment which produced some
worthwhile results. The possibility of continued growth of the electric power
industry in the ORBES region needed to be examined. The ORBES team did a
credible job of describing a number of alternative energy futures for the
region. Assessment of future impacts, always difficult to judge, was handled
with considerable objectivity and with appropriate scientific expertise for
the most part. It is important to point out, however, that several major
conclusions reached in the report can not be substantiated.
1. There is no evidence that exposure to air pollution in the
ORBES region is responsible for large numbers of deaths
each year.
2. There is no evidence that widespread crop losses are occurring
in the ORBES region because of exposure to ozone derived from
utility emissions.
3. Future growth in coal production at less than past rates is
not likely to result in any boom-town conditions in the ORBES
region.
In conclusion, the ORBES report, while providing many useful findings,
will actually further the controversy in the area of air pollution effects
on health and crops. While providing little in the way of new analysis and
no new data or evidence bearing on these subjects, the report will carry with
it a certain authority based on its Congressional mandate, the prestige of
some of the ORBES team members, and its $4 million price tag.
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Fred Hauck, Environmental Engineer
Save-the-Valley
P.O. Box 813, Madison, IN 47250
FUNDAMENTALS THAT THE ORBES STUDY SEEMED TO HAVE MISSED
o that United States electrical generation reserves are now at
an all-time high of at least 43% (see "Electrical World",
September 15, 1979).
o that ECAR electrical generation reserves are also at an all-
time high of 45% (see DOE's "Electrical Power Monthly",
August 1980).
If present trends continue, both of the above figures are
certain to surpass 50% well before 1985!
Maintenance of these excessive reserves (greater than 20%)
is costing U.S. consumers a great deal of money. Our own
figures indicate a money penalty of more than $12 billion
annually, or at least 12% of every consumer's bill!
Duane Chapman's ORBES study has outlined in meticulous
detail, the money incentives that "persuade" both the
utility and its executives that excessive growth is good
for all. Chapman's "Conflict of Interest" conclusions
should be widely publicized!
o that electric energy, even in the excessive amounts being
used, constitutes but 12% of all energy reaching the point of
of use. Nuclear generated electricity is but 11% of this
figure. Thus, nuclear energy is presently filling 12% times
11%, or only 1.3% of our total energy needs! Even in 1990,
when nuclear installations might conceivably grow to 110
facilities, the atom will still supply less than 3% of all
energy needs! The stress on nuclear energy seems to be much
ado about very little.
o that the real-dollar cost of electricity seems to be increas-
ing more than 5% annually. This cost increase in itself is
a powerful suppressant to the growth of electricity use.
Further, when the Public Utility Regulatory Act's (PURPA)
time-of-use pricing is finally put into use, peak growth
could be stifled for a decade or more. Both "Ripple Control"
and "Radio Control" are currently being used effectively in
experimental areas to regulate daily and seasonal peaks.
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I feel that the ORBES study, while it was most carefully
planned and carried out, lacked the boldness needed to be
truly effective. Only Cornell's Duane Chapman had the aud-
acity to point out the fundamental weaknesses of allowing
the electric utility industry to act as "the expert" in decid-
ing its own growth policy.
Fred Hauck V
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Edward Light
Staff Scientist
Appalachian Research & Defense Fund, Inc.
Charleston, West Virginia 25301
QRBES represents an excellent start toward developing the information
needed to make rational energy-related policy decisions in the Ohio River
Basin. The predictions presented in QRBES appear to be based on reasonable
interpretations of the best information currently available. The major
limitation of the ORBES report, in my opinion, is that some important factors
were not developed for several of the scenarios studied. Because of this, a
comprehensive comparison of the various energy and environmental policy
alternatives cannot be made.
The most complete comparison which can be developed from the ORBES data
is that between several alternative approaches for dealing with the con-
troversial issue of sulfur dioxide emission limits. A comparison of the
most significant impacts of these alternatives indicates the following:
1. Converting to Least Emissions Dispatching. At an increased cost of
1% to electricity consumers, annual sulfate is reduced 2.1 micrograms/m^,
resulting in about 20,000 fewer premature deaths.
2. Tightening Air Pollution Standards. At an increased cost of 1.5%
to electricity consumers, annual sulfate is reduced 1.6 micrograms/m3, re-
sulting in 54,000 fewer premature deaths.
3. Reducing Power Plant Life by Ten Years. At an increased cost of 3%
to electricity consumers, annual sulfate is reduced 2.1 micrograms/m3, re-
sulting in about 20,000 fewer premature deaths.
4. Using More Natural Gas. At a savings to electricity consumers of
.2%, annual sulfate is reduced .3 micrograms/m3, resulting in 34,000 fewer
premature deaths.
5. Relaxing Air Pollution Standards. At a savings to electricity con-
sumers of 4%, annual sulfate is increased 2.7 micrograms/rrr, resulting in
55,000 more premature deaths.
Assuming that the majority of consumers are willing to pay a little more
for electricity in exchange for air quality that reduces health risk, the
most attractive option would appear to be a conversion of power plant net-
works to a least emissions dispatching system. Additional air pollution
relief could be provided by converting to natural gas where practical, and
also having certain power plants either shut down ten years early or install
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air pollution controls. The selection of those plants should be based on
their relative economic efficiency for reducing air pollution emissions.
Expansion of this ORBES data base would allow for a much more complete
analysis of air pollution control alternatives. For example, the following
questions could then be examined in great detail:
- Should future power plant siting in the region be concentrated or
dispersed?
- What are the incremental costs and benefits of relaxing or tightening
air quality standards?
- What is the roost efficient SO2 control strategy utilizing all avail-
able considerations, including low sulfur coal, cleaned coal, flue
gas desulfurization, least emissions dispatching, reduction of power
plant life, energy conservation, use of more natural gas, solar
energy, new plant siting, and stack height.
An unfortunate aspect of QRBES is that only a very incomplete analysis
was performed on several scenarios. It would have been very helpful to
develop information on at least sulfate concentrations, air pollution
mortality, costs to the consumer, employment, and crop damage for all
scenarios. This would allow much better answers to questions such as the
following:
- Is it in the ORBES region's interest to export power?
- Is investment in energy conservation or alternative energy sources
worthwhile?
- What are the implications of increased energy growth?
Another limitation of ORBES is that data for a number of important impacts
was not developed at all. This results in a very incomplete picture of
some scenarios, allowing for misleading comparisons. The best example of
this is for nuclear power where the critical iapacts of the nuclear fuel
cycle, normal radioactive plant emissions, and the risks of a nuclear acci-
dent are not quantified. For the conservation, alternative energy, and
natural gas, the total employment impacts and total cost to consumer could
have been presented. ORBES only looked at costs and employment attributed
to the centralized generation of electricity. Two other important, but
overlooked, factors in ORBES are acid rain and morbidity caused lay air pol-
lution.
One last issue not analyzed by ORBES is alternatives for managing peak
electrical demands. Peak load pricing, pumped storage projects, and new
power plants, are all under consideration in the region. ORBES could have
been very helpful in clearing up some of the controversy surrounding this
issue.
Despite the limitations of the final report, the ORBES approach appears
to be the best hope for developing sound energy and environmental protection
policies. ORBES shows that our current plant-by-plant approach for deter-
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mining these policies is totally inadequate. A much more sophisticated,
regional approach toward planning is clearly called for when making energy
and environmental decisions of regional impact. Unfortunately, political
realities may dictate that such a rational decision-making approach to these
complex issues will not be developed.
In conclusion, I would state that the QRBES approach toward our energy
problems is helpful and does work. A major follow-up study is now needed to
further develop and refine the data needed to make rational energy and
environmental policy decisions in the Ohio River Basin.
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Walter A. Lyon
Deputy Secretary for Planning
Commonwealth of Pennsylvania
Department of Environmental Resources
Harrisburg, Pennsylvania 17120
Comments on ORBES MAIN REPORT
1. The ORBES main report mentions the impacts on land from coal mining and
electrical transmission lines, but does not mention large land requirements
of solid waste from fly ash and from air pollution control devices unless it
considers these to be a part of power generation land requirements. This
couldn't be determined from the report. There should be a notation that
there are some significant land requirements from waste disposal.
2. The impact discussions in the report are too general and not site
specific.
3. The report emphasized heavily on coal energy and the impacts on various
scenarios of the coal energy production have been thoroughly discussed.
However, the impacts on the other alternative energy are not adequately
addressed.
4. Synfuel plant development is a coal related development and is a very
important energy development in the Ohio River Basin. However, it was only
briefly mentioned on page 237 in the report. We feel that more information
and the impacts discussion concerning the synfuel plant development should
be addressed in the report.
5. The report emphasized the discussions of air quality and water quality
impacts. However, very little water quantity impacts were discussed. For
example, the quantity problem in the Monongahela River as a result of future
energy development was totally neglected. We feel that the report should be
further revised to describe problems and potentials of energy development
more specifically, and the impact discussions, especially on the water
quantity aspect should be addressed more adequately.
6. From an Air duality standpoint, the study is particularly significant to
Pennsylvania in that it conclusively documents the existence of long-range
interstate transport and demonstrates the significance of utility S02
emissions on ambient S02 air quality, on total suspended particulate concen-
trations (through sulfate formation) and on acid precipitation. Because we
must burn more coal in the future and not less if we are to solve this
country's current energy-petroleum crisis, recognition of the importance of
long-range transport and transformation of S0£ is a key to assuring
appropriate energy development in the ORBES area.
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7. One significant problem does exist with the air quality analysis as
presented. The implication is that we are following the base case scenario.
This was a valid assumption in 1976 when the study was originated. Since
then, however, a shift in EPA's attitude has promoted maximizing 502 emissions
while ignoring long-distance transport. This shift has been justified by
the source by source control method outlined in the Clean Air Act for
existing sources which tends to overlook the cumulative effect of pollutant
emissions. This shift has caused massive relaxations of SO^ emission
limitations throughout the ORBES area as cited in "Petition of the State of
New York for Disapproval of Proposed Revision of State Implementation Plan
and Comments." Thus, we are in fact following the non-compliance case more
closely than the base case. We recommend that the 1980 S02 emissions for
the ORBES area be added to the report graphics to verify this assumption
including a statement as to the significance of this assumption.
The main report states "the immediate benefits of SIP compliance are
clear: utility S0£ emissions could be reduced by one-third by 1985." It
also indicates that in the year 2000 SIP units will dominate in emissions, but
will represent only 28% of the electric generation and will emit five to
six times more sulfur dioxide than those units regulated by new source per-
formance standards. This indicates that following the non-compliance
scenario will have a significant impact and the readers should be aware of
the direction or a scenario that the ORBES area is following.
8. One economic consideration which has not been adequately considered in
the report is the problem of inequity of emission limitations throughout the
ORBES area and their impact on a state's air quality and their economic
development. This is of greatest significance to Pennsylvania as the "last
downwind" state in the study area. You may wish to refer to a recent draft
study entitled "Economic Consequences of Long-Range Transport and,
Additional Costs of Sulfur Dioxide Control in Southwestern Pennsylvania Due
to Long-Range Transport."
9. The report states that ORBES Region Power Generating Units produce about
80 percent of the regional sulfur dioxide emissions and A? percent of the
regional nitrogen oxide emissions. The report further states that long-
range transport of these acid rain precursors is an important factor, with
effects from emissions in the lower region appearing in the upper region --
Eastern Ohio, Pennsylvania, and West Virginia. Long-range transport from
this region may also affect southeastern Canada. With the current awareness
of the acid percipitation problem and the potential for long-term environ-
mental damage, the emissions caused by increases in power generating capacity
or coal conversions must also be taken into consideration. The report does
this by considering various scenarios. Necessary controls should be placed
on both existing and new power generating plants to prevent a worsening of
the acid precipitation problem.
10. Finally, it is critical that this report be regarded only as a first
step identifying the existence of the problem. As cited in the main report,
the greatest danger for the ORBES area is inaction and lack of a coherent
method for decision making. The need for interstate air resource management
is a necessity if the ORBES area is to have a sound economic/environmental
future.
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Ralph Madison
Vice President
Kentucky Audubon Council
Louisville, Kentucky
Inexcusably, there is no way in which the ORBES study can:
be viewed as an action report* It is, in fact, no more than a
magnificent example of statistics gathering, dedicated to and
destined to be used thoroughly by the utility industry. It will
serve only to confuse our SQ-called political decision makers
who will be forced to react only to the demands made by each
one's specific constituency*
It is deplorable that this study, costing in excess of
$4 million, was not designed to produce a recommendation on what
should be done* The information was gathered by faculty members
of some of our greatest universities in an outstanding and im-
posing example of in*.depth and critical research. Who, better
than this group of over 100 investigators could be in a position
to make a sound recommendation for the future?
The writer, together with many other citizen*, complained
years ago to the Environmental Protection Agency about the
threat of deteriorating air quality in the Ohio Valley. After
months of hemming and hawing, EPA finally decided to "look into
the matter" and soon the ORBES study was underway. It is now
revealed officially that an increasing number of deaths will
occur by 1990 under certain scenarios studied. It is also re-
vealed officially that there is a cascading effect up the valley
resulting in a "trans-boundary transport" of various pollutants.
These are only two of the many terrifying facts that have been
investigated and verified in the study. With such a commanding
array of evidence that there is "trouble in the Valley", it is
almost beyond belief that a specific set of far reaching
recommendations in setting limitations on numbers of plants, in
setting limitations on emissions, siting and political arrange-
ments should not have been required before allowing this group
of investigators to disband.
The report casually mentions that "It is not our responsi-
bility (the ORBES researchers) to recommend which path should
be followed". It is only their resposibility to "warn that
inaction could result in economic stagnation and accompanying
social problems capable of draining much-needed vitality from
the region and from the nation at large". We submit that these
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two statements truly point out the most glaring deficiency of
the entire report. All the investigators were aware of each
piece of research developed, and each piece was discussed.
Whether the information was scientifically, socially or politi-
cally oriented, it was thoroughly discussed in open sessions.
How could they be denied the authority and the responsibility
to make carefully authenticated recommendations to solve an
admittedly severe problem?
As a member of the advisory group, I was pleased by the
manner in which research reports were critically appraised be-
fore acceptance by the group. 1 am not pleased by the action
of SPA in stifling open recommendations for corrective and
preventive action. To be sure , they would not be binding on
any political entity but they would constitute annexposition
on.collective action which is so desperately needed. But what
do the "decision makers11 have now? Nothing but a host of truly
valuable but disconnected statistics with no starting point
spelled out for an attack on a devastating problem.
Ralph Madison
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A. Jenifer Robison
Project Director
Energy Program
Office of Technology Assessment
United States Congress
Washington, D.C.
Before beginning my substantive comments on the final report of the Ohio
River Basin Energy Study (ORBES), I would like to congratulate the Management
and Core Teams, Support Researchers, and Project Office Staff on the quality
and objectivity of the report. An overwhelming amount of data and analysis
have been pulled together into an extremely readable document. Moreover, the
research has been summarized in a manner that highlights the major points of
view on the Issues surrounding energy development in the Ohio River region
without emphasizing any one perspective over the others.
The ORBES final report is relevant to the Interests of the Office of
Technology Assessment (OTA)—and of the Congress as a whole—in several
respects. These include the ORBES experience in technology assessment as
well as the study's contribution to discussion of the issues related to
energy development and the environment—issues addressed in previous and
ongoing OTA studies and likely to be the focus of lively debate in the 97th
Congress.
As one of the few formal institutional mechanisms for conducting
policy-oriented technology assessments, OTA has a continuing interest in the
approach to and progress of such assessments. In this context, 1 have been
interested in the ORBES methodology for dealing with regional-based issues
and in the general management of such a broad study in the face of widespread
public interest. Of particular interest have been the analytical methods
used to disaggregate national- or state-based data to the regional level; the
problems involved in coordinating the activities of a large number of
geographically dispersed participants representing a wide array of
disciplines and interests; and the conduct of such a study under constant
scrutiny from the parties-at-interest and the media. These aspects of ORBES
contribute significantly to the body of experience with policy-oriented
technology assessments.
Moreover, many of the Issues addressed by ORBES are of interest to OTA
and the Congress as a whole, especially those concerning the relationships
among air quality, the economy, and energy development, and the Implications
of those relationships for the utility industry and for the upcoming
Congressional review of the Clean Air Act, the synthetic fuels program, and
other legislative proposals related to energy development and the
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environment. I would like to briefly review some of the ORBES findings with
respect to these issues in the context of previous and ongoing OTA studies
and the agenda of the 97th Congress.
Among the most significant ORBES findings are those on air quality. The
ORBES analysis has demonstrated the sensitivity of air quality—whether
measured as emissions or as ambient concentrations—to such factors as state
commitment to SIP compliance and enforcement; utility plant siting and
operating procedures; and financial considerations. These, in turn, have
been related in the ORBES analysis to consumer costs, agricultural
productivity, and public health. In terms of previous OTA studies, many of
these findings are directly in agreement with the conclusions of The Direct
Use Of Coal (OTA-E-86, April, 1979). For example, both studies addressed the
human health effects of pollutant loadings from coal combustion. Although
researchers in both studies felt that substantial controversy surrounds the
quantification of human health effects, they also felt that the evidence does
support the hypothesis that human exposure to some pollutants (particularly
TSP, SOX> NOX, and their transformation products such as sulfates and
nitrates) contributes to an increase in morbidity and mortality. The Clean
Air Act, which mandates standards for TSP, SOX, and NOX, is to be reviewed by
the 97th Congress. Although much additional research must be done before the
effects of air pollution on human health can be determined conclusively, the
ORBES findings become especially significant in light of widespread pressure
by special interest groups to relax the Clean Air Act standards.
The ORBES research on air quality also is relevant to an ongoing OTA
study of acid precipitation. In several respects, most notably the modeling
of long-range transport of air pollutants and the calculation of economic
damage functions from air pollution, the ORBES work is among the most
comprehensive to date. Although much basic research remains to be done In
the chemistry of pollutant transformations and in the effects of pollutants
and their transformation products on terrestrial and aquatic systems, the
ORBES results provide valuable background information for OTA's examination
of air pollution and acid precipitation. And, as with the ORBES findings on
the human health effects of the pollutants from coal combustion, the study's
research on long-range transport and on the economic Impacts of air pollution
becomes Increasingly important in light of Congressional review of the Clean
Air Act and the proposals for regulating trans-boundary air pollution and
currently unregulated air pollutants such as sulfates.
The ORBES findings on employment-related impacts also are in accord with
those of OTA's study The Direct Use Of Coal. That is, that although the
resulting stress on community services is not so pronounced in the ORBES
region as it is in the Rocky Mountain areas, it still is potentially severe.
The difference is that in the West such services have been adequate but break
down when confronted with rapid population growth, while in many of the
coal-mining regions of the East such services have historically been below
par and can only be strained further by population growth. These findings
should contribute to informed debate on legislative and other initiatives to
encourage the greater use of domestic coal (especially for the replacement of
oil and gas in electric generation and for the production of synthetic fuels)
as well as those to reduce the level of Federal support for community
services.
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The ORBES report also highlights a number of Issues related to utility
operations that are relevant to an ongoing OTA study that looks at possible
future paths for the utility industry in the context of cogeneration and
other on-site electric generating technologies. Of particular interest to
OTA here are the financial and economic implications to utilities of various
strategies for pollution control, including capital Investment in control
technology, least-emission versus least-cost dispatching, plant retirement
schedules, and the alternatives to central station coal-fired electric
generation. Again, in a time when Congress is likely to be asked to deal
with inflation, the costs of environmental protection, and the future
regulation or deregulation of electric generation, these issues are very
timely.
Finally, 1 would like to comment on the policy-oriented aspects of the
ORBES assessment. One of the most difficult tasks for the ORBES researchers
was to suggest mitigation strategies for the adverse impacts posed by their
energy development scenarios. In part, this task was difficult because of
the breadth of the issues they addressed. Thus, a mitigation strategy for
air pollution also had to deal with any resulting economic, social,
institutional and other effects. For the most part, however, the task of
devising mitigation strategies was difficult because of the wide range of
parties-at-interest (e.g., utilities and utility organizations, labor, state
and local governments, consumers, industry, environmentalists) who were
invited to participate in the ORBES project. Although the range of
participants made debate difficult at times, it also contributed a richness
to the study that made it possible for ORBES to investigate policy options
that transcend traditional jurlsdictional boundaries, such as those of state
and local governments or utility service areas. This added richness also
enabled the ORBES researchers to examine strategies outside the conventional
policy realms of legislation and regulation. In this light, I found
strategies for least-emission dispatching and for regional coordination among
utilities and governments to be especially intriguing, and ones that are
likely to stimulate and enliven the debate on regional development for some
time.
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Jack Schramm Rebecca W. Hanmer Valdas Adamkus, Acting
Regional Administrator Regional Administrator Regional Administrator
U.S. EPA, Region III U.S. EPA, Region IV U.S. EPA, Region V
Philadelphia, PA. Atlanta, Georgia Chicago, Illinois
These comments on the Ohio River Basin Energy Study (ORBES) Main Report
are compiled by the EPA Regional Administrators from Regions III (Jack
Schramm), IV (Rebecca W. Hanmer) and V (Valdas Adamkus, Acting). They
reflect a multimedia review from Regions III and IV and an air review
from Region V. As Regional Administrators, we would like to express our
appreciation to the Senate for the foresight to commission this study.
We also commend Professors Stukel and Keenan for their capable
leadership which inspired the diligent efforts by the Core Team in the
development of this comprehensive study. This report will be an
invaluable tool for Congress and the EPA because it provides a
comprehensive review of factors which should be considered in the
selection of energy and environmental options for the future of the Ohio
River Valley.
We acknowledge that in any study there are necessarily tradeoffs between
the number of issues examined and the detail with which each is
examined. We sympathize with the fact that because the ORBES was
intended to be so comprehensive in scope, it was difficult to adequately
condense the many specialized projects in one document. The Main Report
alludes to some of the basic methodological limitations in so broad a
study (Section 2.6, Underlying Methodological Issues, p 55), and
repeatedly cautions against utilizing the data as if they were
meaningful in the absolute sense (see pages 57, 102 and 142). The
report does generate data that can be utilized to compare the various
futures. We feel this is consistent with the Congressional mandate to
assess the potential environmental, social and economic impacts of a
proposed concentration of power plants in the Ohio River Basin. This
report provides a synthesis of opinions (some of which are supported
with varying degrees of technical analysis) relating to the potential
impacts which could occur under a variety of futures, and thus has
satisfied the objectives of the study. However, because of the
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methodological limitations, we are of the opinion that the report should
not become the basis for regulatory or legislative development but can
serve a useful purpose as a background document.
We have listed below, several issues that concern us:
1. The report does not address health impacts in as great a detail as
we desire; however, we are sympathetic to the problems of the
researchers since the state of the art for measuring health impacts
is not very advanced on a local scale. It is understandable that a
study such as this, which attempts to identify health impacts on a
regional scale, encounters difficulty in quantifying health impacts
in such a way as to compare with control costs. The ability to
quantify health effects is also limited by the state of the art of
long-range transport modeling techniques.
2. The report did not adequately address acid precipitation in the
northeastern U.S. because the impacts are outside the Ohio River
Basin. Although there is not sufficient information currently
available to quantify the effects of acid rain, to develop a
meaningful cost/benefit consideration would require some
investigation of impacts beyond the ORBES region.
3. We note that the report does not examine in any detail the impacts
of developing alternative energy technologies. We agree that within
the next 20 years (the ORBES time frame), these technologies will
probably not make a significant contribution. However, after the
year 2000, they may begin to make a significant contribution; hence
the reader should use caution in extrapolating findings beyond the
study period of the report.
4. The report did not adequately consider NOX controls. Throughout
the report NOX was assumed to be proportional to the generation of
electricity. Since NOX controls utilizing staged combustion
techniques appear to be feasible and relatively inexpensive for new
construction, it is unfortunate that a low NOX scenario was not
examined. Because of the chemical relationship between NOX and
ozone, and because ozone is such an important factor in crop damage,
a low NOX scenario may have provided some useful additional
information.
In spite of the methodological problems, we are of the collective
opinion that the ORBES is a relevant and highly useful study. Among the
considerations which led to this opinion are:
1. The ORBES is comprehensive. We know of no other study which has
examined such a broad range of issues in such detail. The reports
generated by this study have made a significant contribution to our
understanding of the myriad of factors affecting, and influenced by,
power generation and have indicated directions for future study by
EPA.
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2. ORBES has succeeded in striking a reasonable balance between main
issues and peripheral issues in the development of its conclusions.
3. This report is readable. Perhaps the most difficult task in any
study is to report the findings in a manner that will be
understandable to a broad readership. The ORBES report has
succeeded in presenting an extremely broad range of considerations
in a manner that is understandable, and should make interesting
reading for the Congress, the general public and the scientific
community.
In conclusion, we hope that this report will reach the broad readership
for which it is intended. We agree with the finding that a clean
environment and economic growth are not incompatible goals. However,
the readers must recognize the limitations of the assumptions in this
report when interpreting the findings.
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W. S. White, Jr.
Chairman and Chief Executive Officer
American Electric Power Company, Inc.
Columbus, Ohio
The ORBES Main Report, despite considerable improvement on the draft version
in terms of organization, remains a classic example of (i) very bad science
and (ii) a one-sided approach to highly complex and controversial subject
matters. These two general defects are so fundamental and so infect the en-
tire Main Report as to render it worse than useless as a policy tool—worse
than useless in the sense that the Main Report is misleading in many respects.
The infirmities to which the Utility Industry Advisors refer are catalogued
and spelled out in some detail in our following comments. Because the Main
Report is so scientifically defective and so warped, we urge that it be with-
drawn and discarded. Alternatively, we urge that before the Main Report is
permitted to infect public policy, it be subjected to rigorous peer review by
the Science Advisory Board (SAB) or the National Academy of Sciences (NAS).
We are confident that the Report's numerous technical weaknesses will not
withstand competent peer review and that the SAB or NAS will recommend that
it be scrapped or entirely redone.
In our view, some of the failings of the Report are:
1. Unsupported Findings. Many of its startling conclusions are unsupported
by the Main Report itself or its underlying documents. This seriously de-
tracts from its role as a reliable piece of work. It does little good to
state that "many judgments were made based on inadequate data" in a "research
exercise" (p. 56) and then to state serious and frightening conclusions about
the consequence of an extrapolation of such judgments. Such conclusions in-
volve the effects of power supply facilities on air, water, crops, land,
society, and human health.
2. Negative View of Power Supply. The ORBES Main Report is based on an ex-
ceedingly negative treatment of all power supply facilities. The Report's
failure to treat the positive aspects of energy supply in any way or, alter-
natively, its failure to address the impacts of a lack of energy supply on
society is counter to the original charge of the Congress. That charge was
for "an assessment of the potential environmental, social, and economic im-
pacts of the proposed concentration of power plants in the Ohio River Basin".
The Foreword of the ORBES Main Report speaks (p. 3) of the "potential benefi-
cial and adverse impacts on the environment, society, the economy and public
health". (Emphasis added.) Yet nowhere in the document is there any mention
of the beneficial effects of energy supply facilities on such matters. Like-
wise, as stated in the executive summary (p. 81 of Main Report), the intent
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of the project was to investigate "possible impacts of an expanded generating
capacity in the context of a number of issues". Instead of examining the
positive effects of energy as well as the negative effects, a number of re-
searchers have consistently portrayed speculation, hypotheses, and innuendo
as "findings". This is hardly an objective guide for policymakers. Available
empirical data suggest that the positive effects of energy facilities far
outweigh the adverse impacts and that such facilities have a beneficial effect
on the quality of life in general. Research surveys recently conducted in
communities with power plants demonstrate overwhelmingly favorable individual
perceptions of beneficial impacts upon such sectors as property owners, young
adults, schools, housing, medical facilities, the local economy, employment
opportunities, and personal incomes.
The ORBES Main Report is focused on the environmental, social, and economic
costs of having electricity. However, no examination has been undertaken of
the pervasive costs and effects of not having an adequate and reliable supply
of electric power. In other words, what would be the implications for the
well-being of the Ohio River Basin region if necessary energy development
were not pursued? In our judgment, an enormous shortcoming of the ORBES Re-
port is that it stopped short of addressing the consequences of a failure to
meet electricity demands. The benefits of continued ability to meet such de-
mands can be conceptualized as the avoidance of costs of power interruptions.
Among the readily identifiable potential costs of power interruptions, which
we believe should have been evaluated by ORBES, are safety risks to popula-
tions, health impacts upon the elderly and the disabled, social disorganiza-
tion, and out-migration of inhabitants and industries from the ORBES region.
Each of these specific areas, which should have been thoroughly evaluated,
were not considered at all. For example, the Main Report (p. 55) states that
"the health benefits from electricity—such as its use for life support sys-
tems and air conditioning—are not entirely clear." What a patently absurd
statement! The health benefits from electricity are obvious and overwhelming.
Just ask someone on a life support system if he or she is receiving a health
benefit! As for air conditioning, recall last summer when more than
1,000 Americans died as the result of one of the worst heatwaves in our
nation's history. What would the death toll have been if our nation's power
plants had not been able to supply sufficient electricity to keep home and
office air conditioning systems running! There can be no question but that
the health benefits alone from electricity are enormous. The magnitude of
those benefits may, however, present problems of quantification—but this
certainly is no reason for discarding or ignoring those benefits.
Coupled with this, there is insufficient recognition throughout the Main Re-
port as to the manner in which reliable energy supply affects the capacity
for reasonable economic growth in the region. Along with this overall dis-
regard of reliability, there is an apparent lack of respect for "growth poli-
cies" adopted by several states which represent a coordinated effort by those
states to balance environmental concerns with growth and energy availability.
3. Unrealistic Scenarios. The alleged impacts reported in the ORBES Main
Report are based on fictional scenarios which bear little resemblance to
reality. This end result of three years or more of research contains little
information of practical value either to the policymaker or to the public
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which ultimately bears the cost of the effort. For example, all the scenarios
(Table ES-1) assume a constant economic growth rate of 2.47% with a variable
energy growth rate of 0.1% per year to 1.73% per year. This is entirely un-
realistic and totally ignores the relationship between adequate energy supply
and economic growth. A supporting document (Page, Gilmore & Hewings, An Ener-
gy and Fuel Demand Model for the Ohio River Basin Energy Study Report, p.73)
confirms that the basis of the ORBES assumption is absurdly simple and naive.
It states that the annual rate of growth is based on the assumption "that
labor productivity has increased in such a manner to allow an annual average
growth rate of 2.47 percent per annum. Besides the fact the people are
assumed to be better workers in the year 2000, we have essentially assumed
that input material requirements are the same as that in 1974."
Also, choosing a scenario labeled "non-compliance with state implementation
plans" is quite inappropriate, since it assumes an absence of federal and
state enforcement sanctions. Utilities are not exempted from compliance with
the law. This scenario suggests that they are.
The conservation scenario emphasizes two factors which, supposedly, account
for the low energy consumption. These are the achievement of "maximum prac-
tical end use efficiencies" and the adoption of cogeneration on a wide scale
throughout the ORBES region (pp. 251-252). The first factor was not quanti-
fied for the purposes of ORBES (p. 252 and p. 293). Therefore, all conserva-
tion effects are apparently the result of cogeneration. The summary of re-
sulting pollutants under this scenario (p. 255) shows a small decrease in
sulfur dioxide and particulate emissions and a significant decrease in NOX
emissions. However, the Report also notes that any possible improvements in
air quality resulting from cogeneration are dependent on the fuel utilized
(p. 294). No details on the fuel to be utilized by the cogenerators are
given. Based on our knowledge of fuel availability and costs in the Midwest,
it seems unlikely that cogenerators would use anything but coal, with a re-
sultant deterioration rather than improvement in air quality.
The export scenario of high electrical generation in the ORBES region unreal-
istically assumes a substantial delivery of power to the Northeast. To the
best of our knowledge, there is no^ intent or plan to install an additional
20,000 megawatts of generating capacity in the ORBES region for transmittal
to the Northeast—even if the financing capability existed to do so, which it
clearly does not. This is another example of the ridiculous nature of scena-
rio assumption. Incidentally, the Report presents a confusing and contra-
dictory position on the exporting of power from the region and demonstrates a
lack of knowledge on the part of the authors as to how bulk power systems are
planned and how power flows on the interconnected network. It notes (p. 67)
that a large amount of the electricity generated in the region is exported
and implies throughout the Report that there is something wrong in doing so.
During the course of the study, the ORBES Core Team was apprised of how sys-
tems were planned and why there was power flow over widely separate portions
of the ORBES boundary. It was pointed out how significantly the so-called
"export" changed when the boundary of the Phase I Study was expanded for the
Phase II Study. A statement (p. 227) that exports of power might be from
nuclear-fueled rather than coal-fired units indicates once again the authors'
lack of understanding of power system operation. Nuclear units with their
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low fuel cost would inherently be dispatched first to satisfy the regional
load and provide lowest cost to the regional customers. Any exports would be
from generation available byond the nuclear capability.
4. Institutional Mechanisms for Plant Siting. The ORBES Main Report states
that "existing institutional mechanisms are inadequate to ameliorate air
quality impacts, many of which transcend political boundaries" (p. 30) and
that "voluntary cooperation among utility companies...may not be realistic"
(p. 32) as a viable alternative for reconciling conflict. Although various
organizational approaches in facilitation of the siting of electric power
generating plants should be studied, it should be noted that the interstate
compact approach (p. 32), as represented by the Delaware River Basin Compact
(DRBC), has been judged a failure by several distinguished public policy ana-
lysts, including Dr. Aaron Wildavsky, of the University of California at
Berkeley, (Wildavsky/,A^in Speaking Truth to Power: The Art and Craft of
Policy Analysis) and Bruce Ackerman (Ackerman, B. et al., The Uncertain
Search for Environmental Quality), among others. The Ackerman and Wildavsky
works indicate that the planners, in their zeal, effectively foreclosed cer-
tain political options. Further, it is argued that the goals of DRBC were
"fundamentally misconceived" and did little to "reconcile in satisfactory
fashion the inevitable tensions between industrial man and nature". And if,
as the Foreword from the US Environmental Protection Agency suggests, ORBES
is to serve as a guide to policymakers, care must be taken to see that an ex-
cess of such zeal in technocratic analysis does not have the same effect here.
However, none of the foregoing is intended to reflect unfavorably on the study
of an interstate agreement that, unlike the DRBC, is a state-initiated re-
gional effort, without the federal government as the lead partner. The study
entitled "Siting of Major Energy-Related Facilities Along the Ohio River" now
under way by the Ohio River Valley Water Sanitation Commission (ORSANCO)—
with the Council of State Governments as contractor and funded by the John A.
Hartford Foundation—has its genesis in state action, consistent with the
National Governors Association's urging "action to expedite and encourage,
but not mandate, regional arrangements of states" with regard to siting.
ORSANCO seeks a comprehensive study of institutional mechanisms for siting
designed to promote a balance between environmental concerns and goals for
necessary economic growth. Consistent with the spirit of that sentiment, we
are inclined to view this alternative as generally promising, given safe-
guards for avoiding the DRBC experience.
Not to be ignored, however, is the option of voluntary, industry cooperation
in the region with respect to siting coordination. Reliability councils, such
as ECAR, can have valuable influence on resolution of many concerns in this
regard. ECAR has developed a plan for siting coordination. We agree with
the need for coordination, but we suggest a voluntary mechanism in preference
to the creation of another layer of government regulation. However, one must
bear in mind that the power plant siting process employed today is far from
arbitrary. It is utility site specific, with alternative site analysis re-
quired by the National Environmental Policy Act in environmental impact state-
ments. Both federal and state licensing processes provide substantial input
to the ultimate determination of a site.
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5. Socio-Economic Considerations. The Main Report's treatment of social
values (p. 107) is largely based on H. R. Potter's support research document
(Potter, H. and Norville, H., "Ohio River Basin Energy Study: Social Values
and Energy Policy," Purdue University). In this document, Dr. Potter indi-
cates a major shortcoming in his own research: "One of these limitations
often is the adequacy of the data for the specific problem. That is, indeed,
a limitation in this study since no original data were collected, and that
which was available for secondary analysis was not uniform across the study
region." (p. 2). As a result, Potter's study contains little in the way of
basic scientific or original empirical information to establish the basis for
policy analysis.
The ORBES Main Report states: "In general, the ORBES region has a worse
health status...than does the nation." (p. 96) Two pages later (p. 98) it
continues by saying that "the use of coal for electrical generation by utili-
ties results in potential health impacts in the ORBES region", i.e., coal
mining deaths, injuries, etc. As such, there is a strong implication that
increased levels of coal consumption are responsible for the region's dubious
health. The question one must raise is whether health conditions are direct-
ly resultant from coal development and burning or whether they might at least
be partially attributable to the fact that the region's per capita gross
product is considerably less than the nation's (p. 69).
A major shortcoming of the ORBES Main Report is the statement "whether utility
expansion contributes to economic growth is unknown" (p. 55). Thus, ORBES
researchers—for whatever reason— consciously decided to ignore the possible
beneficial impacts of adequate energy supply which, despite their assertions
to the contrary, are well documented. For example, a study prepared by the
Academy for Contemporary Problems ("Stimulating the Economy of the Great Lakes
States: A Survey for the Committee for Great Lakes Economic Action") gives
credence to this premise by placing the contributions of the manufacturing
sector and energy supply into clear focus. It concludes, among other things,
that: "uncertainty about energy supply" represents one of the "impediments
that must be overcome if new growth in the regional economy is to be stimu-
lated" (p. E-3); "heavy manufacturing, which long undergirded this region's
economic dominance, is growing slowly in the United States, still more slowly
in the region" (p. E-2); and 'lnonmanufacturing jobs in the region are not
growing fast enough to absorb those displaced by the substitution of capital
for labor, absolute losses of employment in some basic industries, natural
increase in the size of the labor force, and increased participations! the labor
force" (p. E-2). Even the Main Report Foreword (p. 2) itself demonstrates a
certain degree of inconsistency by attributing the decline in electricity
demand growth rate to several factors, including "changing demographic and
economic conditions".
6. Coal Use and Energy Independence. The ORBES Report ignores entirely the
strategy of encouraging the use of coal in the interests of this nation's
energy independence. By stressing only the negative effects of increased
coal use, the Report implies, for example, that end-use substitution of nat-
ural gas in one scenario would be preferable to increased use of coal for
electricity generation. The support documents, however, recognize a benefit
to be obtained from the substitution of more abundant fuels for scarce fuels.
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The aforementioned Page support document states (pp. 51-52): "The 'push to
coal1 scenarios assume a widespread use of heat pumps for space heating.
Since the net energy cost of space heating via heat pumps is approximately
the same as the energy required in space heating by direct combustion of fos-
sil fuels, the use of heat pumps would promote energy efficiency and would
decrease dependency upon fuels that are more scarce."
In addition to national security, reliance on coal lends itself to greater
prosperity and serves as an economic stimulus, particularly in the very region
which is the subject of this study. Those portions of the Report that deal
with the public health-morbidity/moribundity effects of coal burning in the
ORBES region constitute additional examples of "bad science". For a detailed
critique of these matters, refer to "Utility Industry Advisors' Comments on
ORBES Air Quality Analyses". However, we would like to note that here again
the ORBES Report is totally one-sided, focusing only on the negative effects
of coal burning. For example, what about the new hospitals in rural Appala-
chia which heretofore did not exist, or local miners who now are able to
afford medical care? We ask, "Why have positive effects been disregarded?"
7. Air Quality Impacts. The ORBES Report fails to provide the facts on air
quality necessary to support its key findings. A detailed critique of this
area is contained in "Utility Industry Advisors' Comments on ORBES Air
Quality Analyses".
8. Agricultural Impacts. Projections of crop losses have been arrived at by
ORBES researchers, to our knowledge, without the introduction of adequate
scientific data from actual field studies around coal-fired power plants.
Extensive bio-monitoring and vegetation field surveys conducted for over nine
years have failed to detect significant injury and productivity losses
attributable to S02 emissions from generating facilities. Statements such as
"Crop gains that could have been achieved from complete abatement of sulfur
dioxide concentrations (ranging from 867,000 bushels to 6.1 million bushels)"
represent nothing more than a mere statistical extrapolation. Detailed com-
ments on crop losses are included in "Utility Industry Advisors' Comments on
ORBES Air Quality Analyses".
9. Water Quality Impacts. Once again, an evaluation of the ORBES Main Report
is complicated by the fact that some references cited are documents produced
during other phases of the ORBES project and, as such, may not provide the
original source of the information. For a scientific work of the magnitude
of the ORBES Main Report, the location of the data and standards used to draw
conclusions should be clearly cited.
A general assumption of no strict effluent controls on the water discharges
from power plants was made for all scenarios except that of strict environ-
mental controls. This assumption comes dangerously close to making the ORBES
Main Report invalid on its face. Water discharges from power plants are per-
haps the most strictly controlled of all water discharges. Specifically, the
references (p. 7) to stream desiccation and fish kills are inappropriate.
During the past ten years there have been no fish kills in the ORBES region
due to 7-day - 10-year low flow (7Q10 flow), as theoretically assumed 'for
1976, or due to ambient water quality. Fish kills have occurred during this
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time period—but only during an emergency event such as a toxic chemical
spill. Also, it is inconceivable that the majority of rivers in the ORBES
region could experience any eutrophication even during a 7Q10 flow event.
Both current and navigational traffic would prevent eutrophication. Also,
the study fails to take into account the beneficial effects of the water
treatment systems, such as settling ponds, used by power plants. These sys-
tems act in a cleaning capacity for large streams in the region such as the
Ohio Main Stem and Mississippi. This effect is also evident on smaller,
heavily industrialized rivers like the Kanawha. There appears to be an error
(p. 89) in the number of streams classified in either the A or B category.
Only 24 streams were classified, yet 18 were designated A and 8 designated B.
This does not equal 24 streams. The postulated impact on aquatic life (p. 95)
implies that these projected impacts result from power plant operations. The
third paragraph on page 96 indicates that this is not so and that high back-
ground pollutant levels associated with the 7Q10 flow are the primary factors.
This fact was not stressed strongly enough. The impacts of entrainment and
impingement are greatly overstated (p. 217). With the introduction and use
of new intake design technology, such as slotted pipe and small mesh screen
intakes, the "devastating entrainment-impingement impact on the main stem"
will not occur. These types of intakes have been installed and are operating
successfully at several power plants on the Ohio River Main Stem.
Another fundamental shortcoming of the treatment of water quality impacts in-
volves the selection of the reference concentrations of pollutants. One
reference concentration was selected for each of the 20 pollutants examined.
EPA criteria, ORSANCO standards, and individual state standards were reviewed
and, in general, ORBES researchers adopted the most stringent criteria as the
ORBES reference concentration. These reference concentrations were assumed
to apply to all water bodies in the ORBES region. No single ORBES reference
concentration can be used to assess the water quality impacts of the region's
water bodies. The natural variability among aquatic systems, or even within
a single aquatic system, cannot be identified with a single numerical value.
Factors such as hardness, pH, sediment characteristics, and types of aquatic
organisms present often impact on the pollutant's effect on the aquatic envir-
onment. A water quality standard consists of two parts: 1) a designated use
and 2) numerical or qualitative criteria developed to attain the designated
use. Each state is delegated the responsibility of adopting water quality
standards to ensure protection of state-designated uses, e.g., industrial,
agricultural, public drinking source, fisheries, etc. The designated uses
for the 24 streams evaluated in the Main Report were entirely ignored. Thus,
conclusions that a given number of streams would violate certain pollutant
standards under various scenarios are incorrect and misleading. Individual
state standards should have been used as they apply to the individual state's
waters. ORSANCO standards should have been referenced for the Ohio River
mainstream.
10. Land Use and Terrestrial Ecosystem Impacts. Land use changes were
assessed in the ORBES Main Report by projecting the acreage converted as a
result of coal mine, power plant, and transmission line development. Terres-
trial ecosystem impacts were assessed by establishing county level indices
for four ecological resource variables and projecting the effects according
to the various siting configurations. Thus, if a county had an index of ten,
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each 650 megawatts of capacity sited in this county would be assessed ten
"terrestrial ecosystem assessment units" (TEAU). The four ecological resource
variables used were percentage of forest lands, percentage of Class I and II
soils, number of natural areas, and number of endangered species.
There are several basic deficiencies in the approaches used by the ORBES re-
searchers, including limited data bases, invalid assumptions, and a disregard
with respect to the realities of siting an energy facility. Based on land-use
requirements for five new plants, the ORBES researchers deduced that for every
650 mw of installed capacity, 1,100 acres are converted for power plant re-
quirements and 800 acres are converted for the associated transmission lines.
Of the five facilities examined by the ORBES researchers, acreage requirements
per 650 mw of capacity ranged from 644 to 1,749 acres for power plants and
from 262 to 1,677 acres for transmission lines. However, it is very likely
that a substantial portion of the land at some of the "data base" plants is
reserved for future unit additions beyond those presently planned by the
utilities. In short, the ORBES Main Report appears to overstate land require-
ments for energy facilities.
Terrestrial ecosystem impacts based on county-wide TEAUs should be viewed
with extreme caution. The Main Report imples that certain ORBES states would
be less severely affected ecologically than other states in a given scenario
and certain scenarios would be less damaging ecologically than others. Since
each state applies different criteria for classifying a species as endangered
and ORBES states vary in the emphasis placed on natural area programs, com-
parisons between states for any given scenario would be meaningless. Further,
ecological impacts are directly related to ORBES1 adopted policies inherent
in the siting model. Thus, a policy which shifts generating capacity to a
state(s) with lower county level ecological indices may imply that the
scenario has less of an ecological impact when, in reality, the difference
may be explained by inconsistencies in state data bases. Since "scenario
addition" plants were only sited to the county level, land use impacts were
assessed by assuming that energy facilities displacement would be directly
proportional to county level land use data. If half of a county were in
forested use, half of the acreage displaced by the new energy facility would
be forest lands. This rationale ignores the realities of siting energy
facilities to the sub-county and site-specific levels. In essence, the
researchers proportioned site-specific impacts according to the county level
data base.
Likewise, just, because an energy facility is sited in a county with a parti-
cular TEAU value does not mean that the facility would have negative impacts
on the TEAUs. In practice, a utility would apply ecological siting criteria
to the sub-county level and thus either avoid or provide mitigative measures
to ensure protection of ecologically sensitive habitats.
11. Conclusion. I appreciate this opportunity to comment on this document.
I trust that these observations will be helpful to you and the United States
Congress in its further deliberation. While it has not been possible to
fully evaluate all support documents developed since the beginning of this
undertaking three or more years ago, we have made a concerted effort to point
out areas of concern in utilizing the ORBES Main Report as a tool for
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evaluating policy alternatives. The comments contained herein have the
support of the other members of the Utility Industry Advisors Group and, for
purposes of assuring continuity of response in addressing the issue of the
ORBES Main Report, should be considered as part of that group's response.
W. S. White, Jr.
February 17, 1981
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Appendices
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APPENDIX A
ORBES Publications
Phase II
Donald A. Blome, University of Kentucky, Coal Mine Siting for the Ohio River
Basin Energy Study. Grant No. EPA R805590
E. Downey Brill, Jr., Shoou-Yuh Chang/ Robert W. Fuessle, and Randolph M.
Lyon, University of Illinois at Urbana-Champaign, Potential Water Quantity
and Water Quality Impacts of Power Development Scenarios QQ Major Rivers in
the Ohio Basin. Subcontract under Prime Contract EPA R805588
Vincent P. Cardi, West Virginia University, editor, Hest Virginia Baseline,
Grant No. EPA R805585
Vincent P. Cardi, Larry Harless, and Thomas Sweet, West Virginia University,
Legal and Institutional Issues in the Ohio River Basin Energy Study. Grant
No. EPA R805585 and Subcontract under Prime Contract EPA R805588
Duane Chapman, Kathleen Cole, and Michael Slott, Cornell University, Energy
Production and Residential Heating: Taxation, Subsidies, and Comparative
Costs, Subcontract under Prime Contract EPA R805588
Comments on the Ohio River Basin Energy Study, collected by James J. Stukel,
University of Illinois at Urbana-Champaign, and Boyd R. Keenan, University
of Illinois at Chicago Circle, Cooperative Agreement No. EPA CR807395
Control Data Corporation, International Research and Technology Corporation,
and the MITRE Corporation, Environmental Residual Trends in the Ohio River
Gary L. Fowler, University of Illinois at Chicago Circle; J.C. Randolph,
Indiana University; Robert E. Bailey, The Ohio State University; Steven I.
Gordon, The Ohio State University; Steven D. Jansen, University of Illinois
at Chicago Circle; and W.W. Jones, Indiana University, Xh& Ohio. River Basin
Energy Facility Siting Model. Grant Nos. EPA R805588, R805589, and R805609
and Subcontract under Prime Contract EPA R805588
Vol. I. Methodology
Vol. II. Sites and On-Line Dates
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Steven I. Gordon and Christopher Badger, The Ohio State University, A Model of
Migration in the OJjio_ River Basin Energy Study. Region/ Subcontract under
Prime Contract EPA R805588
Steven I. Gordon and Anna S. Graham, The Ohio State University, Regional
Socioeconomic Impacts of Alternative Energy Scenarios for the Ohio River-
Basin Energy Study Region. Grant No. EPA R805589
Steven I. Gordon and Anna S. Graham, The Ohio State University,
Socioeconomic Impacts! £gy£H Case. Studies in £h£ Qhifi Riyer. Basin
Study Region. Grant No. EPA R805589
James P. Hartnett and Jan L. Saper, University of Illinois at Chicago Circle,
Energy Consumption Patterns; Illinois. Indiana. Kentucky. {Mo.,
Pennsylvania, and West Virginia (1975) , Grant No. EPA R805588
Steven D. Jansen, University of Illinois at Chicago Circle, Electrical
Generating Unit Inventory. 1976-1986; Illinois. Indiana. Kentucky. Ohio.,
Pennsylvania, and West Virginia, Grant No. EPA R805588
Steven D. Jansen, James P. Hartnett, R. Mastaniah, and Dan Merilatt,
University of Illinois at Chicago Circle; Robert E. Bailey, The Ohio State
University; J.C. Randolph, Indiana University; Maurice A. Shapiro,
University of Pittsburgh; and Hugh T. Spencer, University of Louisville,
Nuclear Energy Risks and Benefits. Grant Nos. EPA R804816, R805588,
R805608, and R805609 and Subcontracts under Prime Contract EPA R805588
Boyd R. Keenan, University of Illinois at Chicago Circle, Ohio. Basin
Interstate Energy Options; Constraints of Federalism. Grant No. EPA
R805588
Clara Leuthart and Hugh T. Spencer, University of Louisville, Zish Resources
and Aquatic pahifcat Impact Assessment Methodology for the QfalQ River, Basin
Energy Study Region. Grant No. EPA R804816
Orie Loucks, Thomas V. Armentano, Roland Usher, and Wayne Williams, The
Institute of Ecology; Richard W. Miller, The Institute of Ecology and
Butler University; and Larry Wong, Indiana University, Crop snd Bxest.
Losses Due £0. Current and Projected Emissions from Coal-EiEfid. Puwet Plants.
JH the Ohio River Basin. Subcontract under Prime Contract EPA R805588
Patrick C. Mann and Tom S. Witt, West Virginia University, An Economic
Analysis flf. the Electric Utility Sector in £ne. flbifl BiXSL Basin Region/
Subcontract under Prime Contract EPA R805588
James A. Mclaughlin, West Virginia University, Legal and Institutional
£f interstate Power Plant Development in the Ohio River Basin Energy Study.
Region. Subcontract under Prime Contract EPA R805588
Richard Newcomb and Bruce Bancroft, West Virginia University, Capital
Requirements and Busbar Costs £QE. £QUS£. in ibfi. Ohio. J&xgr. Basin, 12B5. and
2000. Subcontract under Prime Contract EPA R805588
128
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QRBES Core Team, Ohio River Basin Energy Study (ORBES): Main Report. Grant
Nos. EPA R804618, R805585, R805588, R805589, R805590, R805603, R805608,
R805609, and R806451 and Cooperative Agreement No. EPA CR807395; also
published as U.S. Environmental Protection Agency, Interagency
Energy/Environment Research and Development Program Report, EPA-600/7-81-
008 (January 1981)
Walter P. Page, West Virginia University, An Economic- Analysis of £oal Supply
in the Ohio River Basin Energy Study Region. Grant No. EPA R805585
Walter P. Page, West Virginia University, Energy Consumption in the Ohio River
Basin Energy Study Region. 1974. by End User and Fuel Type. Grant No. EPA
R805585
Walter P. Page, James Ciecka, and Gary Arbogast, West Virginia University, and
Robert G. Fabian, Estimating Regional Losses to Agricultural Producers from
Airborne Residuals in the Ohio River Basin Energy Study Region. 1976-2000.
Grant No. EPA R805585 and Subcontract under Prime Contract EPA R805588
Walter P. Page, West Virginia University, and Doug Gilmore and Geoffrey
Hewings, University of Illinois at Urbana-Champaign, An Energy and Fuel
Demand Model for the Ohio River Basin Energy Study Region, Grant No. EPA
R805585 and Subcontract under Prime Contract EPA R805588
Walter P. Page and John Gowdy, West Virginia University, Gross Regional
Product in the Ohio River Basin Energy Study Region. 1960-1975. Subcontract
under Prime Contract EPA R805588
Walter P. Page and John M. Gowdy, West Virginia University, Economic Losses in
the Columbus SMSA Due £o_ Long-Range Transport of Airborne Residuals in the
Ohio River Basin Energy Study Region. Grant No. EPA R805585
Harry R. Potter and Heather Norville, Purdue University, Ohio River Basin
Energy Study; Social Values and Energy Policy. Grant No. EPA R806451 and
Subcontract under Prime Contract EPA R805588
Edward P. Radford, University of Pittsburgh, Impacts on Human Health from the
Coal and Nuclear Fuel Cycles and Other Technologies Associated with
Electric Power Generation and Transmission. Subcontract under Prime
Contract EPA R805588
J.C. Randolph and W.W. Jones, Indiana University, Ohio River Basin Energy
Study; Land Use and Terrestrial Ecology. Grant No. EPA R805609
Jan L. Saper and James P. Hartnett, University of Illinois at Chicago Circle,
editors; Vincent P. Cardi and Thomas Sweet, West Virginia University; and
Gary L. Fowler, Rita Harmata, Steven D. Jansen, and Boyd R. Keenan,
University of Illinois at Chicago Circle, The Current Status of the
Electric Utility industry in the Ohio River Basin Energy Study States,
Grant Nos. EPA R805585 and R805588
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Maurice A. Shapiro, University of Pittsburgh, editor, Pennsylvania Baseline,
Grant No. EPA R805608
Maurice A. Shapiro and A.A. Sooky, University of Pittsburgh, Ohio River Basin
Energy. Study; Health Aspects. Grant No. EPA R805608 and Subcontract under
Prime Contract EPA R805588
James J. Stukel, University of Illinois at Urbana-Champaign, editor, Ohio
River Basin Energy Study; Air Quality and Related Impacts
Vol. I. James J. Stukel and Brand L. Niemann, University of Illinois
at Urbana-Champaign, Documentation in Support oJL Key ORBES Air Quality
Findings. Grant No. EPA R805588
Vol. II. Teknekron Research, Inc., Air Quality and Meteorology in the
Ohio River Basin; Baseline and Future Impacts. Subcontract under
Prime Contract EPA R805588
Vol. III. Teknekron Research, Inc., Selected Impacts ol Electric
Utility Operations in the Ohio River Basin (1976-2000): An
Application of the utility Simulation Model. Subcontract under Prime
Contract EPA R805588
Symposium on Energy and Human Health; Human Costs pi. Electric Power
Generation. Grant NO. EPA R805608 and Subcontract under Prime Contract EPA
R805588
David S. Walls, Dwight B. Billings, Mary P. Payne, and Joe F. Childers, Jr.,
University of Kentucky, A. Baseline Assessment of Coal Industry Structure in
the Ohio River Basin Energy Study Region. Subcontract under Prime Contract
EPA R805588
Elbert E. Whitlatch and John A. Aldrich, The Ohio State University, Energy
Facility Siting Procedures. Criteria, and Public Participation in the Ohio
River Basin Energy Study Region. Grant Nos. EPA R805589 and R805603
Daniel E. Willard, Michael A. Ewert, Mary Ellen Hogan, and Jeffrey D. Martin,
Indiana University, A Land Use Analysis oi. Existing and Potential Coal
Surface Mining Areas, in .the Ohio. River Basin Energy study Region.
Subcontract under Prime Contract EPA R805588
NOTE: Copies of the above reports can be obtained from Office of Research and
Development Publications, U.S. Environmental Protection Agency, Center for
Environmental Research Information, 26 West St. Clair, Cincinnati, Ohio 45268
(513/684-7562).
130
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Phase I
R.E. Bailey, R.G. Barile, D.D. Gray, R.B. Jacko, P. O'Leary, R.A. Rao, and
J.E. Reinhardt, Purdue University, pmin«-ani- Transport Models for the QRBES
Region, vol. III-H, Grant No. EPA R804849
Donald A. Blome and James E. Jones, Jr., University of Kentucky, Regional
Assessment g£ the Impact of Synthetic Fuel Production, vol. III-J, Grant
NO. EPA R804817
E. Downey Brill, Jr., Glenn E. Stout, Robert W. Fuessle, Randolph M. Lyon, and
Keith E. Wojnarowski, University of Illinois at Urbana-Champaign, Issues
Related to Water Allocation in the Lower Ohio River Basin, vol. III-G,
Grant No. EPA R804821
Robert C. Dauffenbach and Thomas P. Milke, University of Illinois at Urbana-
Champaign, Labor Demand Impact and. Tahnr Market Feasibility of. Energy
Conversion Facilities in the Ohio River Basin, vol. III-A, Grant No. EPA
R804821
Development s£. Baseline Data for the Ohio River Basin Energy Study, vol. I-B,
University of Louisville, university of Kentucky, University of Illinois at
Chicago Circle and at Urbana-Champaign, Indiana University, Purdue
University, The Ohio State University, and Project Management, Grant Nos.
EPA R804816, R804817, R804821, R804849, R804851, and R804848
Independent Comments, vol. IV, Grant No. EPA R804848
Sue Johnson and Esther Weil, University of Kentucky, Social Aspects s£ Power
Plant Siting, vol. III-D, Grant No. EPA R80817
Clara A. Leuthart and Hugh T. Spencer, University of Louisville, Radionuclide
and Metal Ion Content of Late Summer Ohio River Sediments! McAlpine Pool
I27JL, vol. III-I, Grant No. EPA R804816
Sven B. Lundstedt, Henry L. Hunker, and Clark Leavitt, The Ohio State
University, Subjective Quality pi Life in £he_ Ohio. River Basin a§ Related
£a £utllEe. £neigy. Development, vol. III-C, Grant No. EPA R804851
Preliminary Technology Assessment Rejgoct, Vol. II-A, 3 pts»r Indiana
University, The Ohio State University, and Purdue University, Grant No. EPA
R804849
Preliminary Technology Assessment Report. Vol. II-B, University of Kentucky
and University of Louisville, Grant Nos. EPA R804816 and EPA R804817
Preliminary Technology Assessment Report. Vol. II-C, University of Illinois at
Chicago Circle and at Urbana-Champaign, Grant No. EPA R804821
131
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Michael Rieber, University of Illinois at Urbana-Champaign, Energy
Transportation/Distribution in the Ohio River Basin, vol. III-F, Grant No.
EPA R804821
James J. Stukel, University of Illinois at Urbana-Champaign, and Boyd R.
Keenan, University of Illinois at Chicago Circle, QRBES Phase £: interim
Findings, vol. I-A, Grant No. EPA R805848; also published as U.S.
Environmental Protection Agency, Interagency Energy-Environmental Research
and Development Program Report, EPA-600/7-77-120 (November 1977)
Richard A. Tybout, The Ohio State University, A. Benefit-Cost Analysis $£ Power
in £h£ QBEES Region, vol. III-B, Grant No. EPA R804851
Nicholas L. White and John F. Fitzgerald, Indiana University, Legal Analysis
of Institutional ACCflu.ntflhT'liity for the Ohio River Basin, vol. III-E, Grant
No. EPA R804849
132
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APPENDIX B
ORBES Phase II Participants
Project Management: Team
Lowell Smith, ORBES Project Officer and Director, Program Integration and
Policy Staff, Office of Environmental Engineering and Technology, Office
of Research and Development, U.S. Environmental Protection Agency,
Washington, D.C.
James J. Stukel, Professor of Environmental Engineering and Mechanical
Engineering and Director, Office of Energy Research, University of
Illinois at Urbana-Champaign, Urbana, Illinois
Boyd R. Keenan, Professor of Political Science, University of Illinois at
Chicago Circle and Institute of Government and Public Affairs, Chicago,
Illinois
David Hopkins, U.S. Environmental Protection Agency, Region IV, Atlanta,
Georgia
Victor F. Jelen, Industrial Environmental Research Laboratory, U.S.
Environmental Protection Agency, Cincinnati, Ohio
James H. Phillips, U.S. Environmental Protection Agency, Region V, Chicago,
Illinois
Project Office Staff
Stephanie L. Kay1in, Staff Associate, Office of Energy Research, University of
Illinois at Urbana-Champaign, Urbana, Illinois
Cathy Coffman, Assistant Editor, Office of Energy Research, University of
Illinois at Urbana-Champaign, Urbana, Illinois
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Core Team
Robert E. Bailey, Professor of Nuclear Engineering and Director, Program on
Energy Research, Education, and Public Service, The Ohio State
University, Columbus, Ohio
Donald A. Blome, Research Scientist, Institute for Mining and Mineral
Research, Energy Research Laboratory, University of Kentucky, Lexington,
Kentucky
Vincent P. Cardi, Professor of Law, West Virginia University, Morgantown, West
Virginia
Gary L. Fowler, Associate Professor of Geography and Associate Director,
Energy Resources Center, University of Illinois at Chicago Circle,
Chicago, Illinois
Steven I. Gordon, Assistant Professor of City and Regional Planning, The Ohio
State University, Columbus, Ohio
James P. Hartnett, Professor of Energy Engineering and Director, Energy
Resources Center, University of Illinois at Chicago Circle, Chicago,
Illinois
Boyd R. Keenan, Professor of Political Science, University of Illinois at
Chicago Circle and Institute of Government and Public Affairs, Chicago,
Illinois
Walter P. Page, Associate Professor of Economics, West Virginia University,
Morgantown, West Virginia
Harry R. Potter, Associate Professor of Sociology, Purdue University, West
Lafayette, Indiana
James C. Randolph, Associate Professor of Ecology and Director of
Environmental Programs, School of Public and Environmental Affairs,
Indiana University, Bloomington, Indiana
Maurice A. Shapiro, Professor of Environmental Health Engineering, University
of Pittsburgh, Pittsburgh, Pennsylvania
Hugh T. Spencer, Associate Professor of Environmental Engineering, University
of Louisville, Louisville, Kentucky
James J. Stukel, Professor of Environmental Engineering and Mechanical
Engineering and Director, Office of Energy Research, University of
Illinois at UrDana-Champaign, Urbana, Illinois
Persons who made substantial contributions working with individual core
team members include Anna S. Graham, The Ohio State University; Rita Harmata
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and Steven D. Jansen, university of Illinois at Chicago Circle; W.W. Jones,
Indiana University; Clara Leuthart, University of Louisville; and A.A. Sooky,
University of Pittsburgh.
Support Researchers
Dwight B. Billings, Assistant Professor, Appalachian Center, University of
Kentucky, Lexington, Kentucky
E. Downey Brill, Jr., Associate Professor of Civil Engineering, University of
Illinois at Urbana-Champaign, Urbana, Illinois
Duane Chapman, Associate Professor of Agricultural Economics, Cornell
University, Ithaca, New York
Doug Gilmore, Research Engineer, University of Illinois at Urbana-Champaign,
Urbana, Illinois
Geoffrey Hewings, Associate Professor of Geography, University of Illinois at
Urbana-Champaign, Urbana, Illinois
Orie Loucks, Science Director, The Institute of Ecology, Holcomb Research
Institute, Indianapolis, Indiana
Patrick C. Mann, Professor of Economics, West Virginia University, Morgantown,
West Virginia
James A. Mclaughlin, Professor of Law, West Virginia University, Morgantown,
West Virginia
Thomas P. Milke, Westat Corporation, Rockville, Maryland
Richard Newcomb, Professor of Mineral Economics, West Virginia University,
Morgantown, West Virginia
Edward P. Radford, M.D., Professor of Environmental Epidemiology, University
of Pittsburgh, Pittsburgh, Pennsylvania
Teknekron Research, Inc., Berkeley, California, and Waltham, Massachusetts
Burkhard von Rabenau, Associate Professor of City and Regional Planning, The
Ohio State University, Columbus, Ohio
David S. Walls, Assistant Professor, Appalachian Center, University of
Kentucky, Lexington, Kentucky
E. Earl Whitlatch, Associate Professor of Civil Engineering, The Ohio State
University, Columbus, Ohio
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Daniel E. Willard, Associate Professor, Environmental Systems Application
Center, School of Public and Environmental Affairs, Indiana University,
Bloomington, Indiana
Tom S. Witt, Associate Professor of Economics, West Virginia University,
Morgantown, West Virginia
Advisory Committee
John P. Apel, Vice President, Columbus and Southern Ohio Electric Company,
Columbus, Ohio
Charles Bareis, Illinois Archaeological Society, Urbana, Illinois
Hugh A. Barker, Chairman and Chief Executive Officer, Public Service Indiana,
Plainfield, Indiana
Frank Beal, Director, Illinois Institute of Natural Resources, Chicago,
Illinois
Harold G. Cassidy, Save The Valley, Madison, Indiana
Thomas Duncan, President, Kentucky Coal Association, Lexington, Kentucky
C. Wayne Fox, Chief Electrical Engineer, Illinois Commerce Commission,
Springfield, Illinois
John D. Geary, President, Ohio River Company, Cincinnati, Ohio
W.C. Gerstner, Executive Vice President, Illinois Power Company, Decatur,
Illinois
Oscar Geralds, Secretary, Kentucky Department of Environmental Protection,
Louisville, Kentucky
Benjamin C. Greene, President, West Virginia Surface Mining and Reclamation
Association, Charleston, West Virginia
Major General Harry A. Griffith, Division Engineer, U.S. Army Corps of
Engineers, Cincinnati, Ohio
Damon W. Harrison, Commissioner, Kentucky Department of Energy, Frankfort,
Kentucky
Fred Hauck, Save The Valley, Shelbyville, Kentucky
Rebecca Hanmer, Regional Administrator, U.S. Environmental Protection Agency,
Region IV, Atlanta, Georgia
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L. John Hoover, Assistant Director, Energy and Environmental Systems Division,
Argonne National Laboratory, Argonne, Illinois (through Nay 1980)
Brian Kiernan, Assistant Director for Research, Kentucky Legislative Research
Commission, Frankfort, Kentucky
Fred J. Krumholtz, Chairman, Ohio River Basin Commission, Cincinnati, Ohio
Eugene Land, International Legislative Representative, United Auto Workers,
Region III, Lexington, Kentucky
Owen Lentz, Executive Manager, East Central Area Reliability Council, Canton,
Ohio
Edward Light, Appalachian Research and Defense Fund, Inc., Charleston, West
Virginia
Walter A. Lyon, Deputy Secretary, Pennsylvania Department of Environmental
Resources, Harrisburg, Pennsylvania
Ralph Madison, Vice President, Kentucky Audubon Council, Louisville, Kentucky
James S. McAvoy, Director, Ohio Environmental Protection Agency, Columbus,
Ohio
Mitch McConnell, Judge, Jefferson County, Louisville, Kentucky
Dandridge McDonald, Chairman, West Virginia Public Service Commission,
Charleston, West Virginia
John McGuire, Regional Administrator, U.S. Environmental Protection Agency,
Region V, Chicago, Illinois (through February 8, 1981; Valdas V. Adamkus
assumed the post of Acting Regional Administrator on February 9, 1981)
Representative Daniel Pierce, Illinois Energy Resources Commission, Highland
Park, Illinois (through December 1979)
A. Jenifer Robison, Project Director, Dispersed Electric Generating Tech-
nologies, Office of Technology Assessment, U.S. Congress, Washington,
D.C.
Senator Walter Rollins, West Virginia Commission on Interstate Cooperation,
Kenova, West Virginia
Greg Rowe, Environmental Planner, OKI Regional Council of Governments,
Cincinnati, Ohio
Robert Ryan, Director, Ohio Energy and Resource Development Agency, Columbus,
Ohio
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Jack Schramm, Regional Administrator, U.S. Environmental Protection Agency,
Region III, Philadelphia, Pennsylvania
William B. Stanbury, Mayor, City of Louisville, Louisville, Kentucky
Charles C. Tillotson, Rising Sun, Indiana
Carl B. Vance, Executive Vice-President for Operations, Indianapolis Power and
Light Company, Indianapolis, Indiana (retired during ORBES project period
and replaced by R.A. McKnight)
Leo Weaver, Executive Director, Ohio River Valley Water Sanitation Commission,
Cincinnati, Ohio
David Whaley, Louisville, Kentucky (through June 1980)
W.S. White, Chairman of the Board, American Electric Power Company, Inc., New
York, New York
John H. Williams, Office of Utility Systems, Division of Power Supply and
Reliability, Economic Regulatory Administration, U.S. Department of
Energy, Washington, D.C.
Jack Wilson, Commissioner, Bureau of Environmental Protection, Kentucky
Department of Natural Resources and Environmental Protection/ Frankfort,
Kentucky
Willis Zagrovich, President, Indiana AFL-CIO, Greenwood, Indiana
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