The Economic Cost of Air Pollution in the U.S. & Florida    

                     B Windham (Ed)  (some cost data needs updating)


      Without estimates of pollution damage cost, it is impossible to determine the cost effectiveness of air pollution prevention or mitigation  methodologies or technologies. A White House report has found that the amount of money spent by businesses and the public to comply with federal regulatory policies -- especially environmental policies -- is overshadowed by the economic benefits that result from those expenditures (71).  The National Commission on Energy Policy found that efficiency policies for appliances, buildings, equipment, and vehicles have proved over the last 30 years to be an effective antidote to pervasive market failures that would otherwise lead to systematic under-investment in energy efficiency, and that the benefits of past efficiency policies have substantially outweighed their costs(24).   This paper is primarily an annotated bibliography summarizing cost estimates of some of the economic cost of environmental and health damage of various air pollutants, from studies listed in the Bibliography.     Detailed descriptions of the extent of the various damage or health effects are not included in this paper, but are available in other referenced papers detailing the environmental and health effects of acid pollutants, greenhouse gases, and toxic metals.       Summary tables will also be provided in an appendix.


World Energy Consumption and Emission Trends

        Dept. of Energy EIA reference case projections of world energy use between 2005 and 2025 are for an increase of 2% per year or a total of 47% over that period (23).  U.S. energy use growth is projected as 1.3% per year and a total of 27%.  World coal consumption is projected to increase by 2% per year for a total of 45%, while U.S. coal consumption is projected to increase by 1.5% for a total of 35% over the next 20 years. World carbon dioxide emissions based on this reference case are projected to increase by 2% per year with a total increase of 48% (23).  The goal of the Kyoto Accord on global warming which has been adopted by the majority of nations is to reduce global greenhouse gas emissions over this period.  The primary policies that have been implemented for this purpose are carbon emission caps, carbon emission allowance trading, and emission reduction incentives.


Greenhouse Gas Emissions and Global Warming


1. The Scientific Advisory Panel to the U.S. Dept. of Energy and the National Commission on Energy Policy(24) consider the greenhouse effect/global warming to be the number one energy problem in the U.S.  Three reports by the National Academy of Sciences and the Congressional Office of Technology Assessment support the position that global warming is a serious problem and action should be taken to reduce emissions(30.5). Several largescale studies make a strong case that the buildup of greenhouse gases have initiated a significant global warming over recent decades( 60,64,65,66), as also predicted by numerous atmospheric temperature computer models(16,21). A 2001 report by the U.N. International Panel on Climate Change indicates that surface temperatures have warmed significantly in the last 20 years and are expected to have large increases over the next century(1).  While plans for greenhouse gas emission reductions have recently been implemented by the majority of nations, that are party to the Kyuota Accord, for other industrial countries like the U.S. and China there are no restrictions where the largest increase is expected and where emissions are expected to double over the next 100 years.

    The global average temperature has increased at least 0.5 degrees Centigrade since 1900, and 0.2 degrees Centigrade since 1975(1,44.4,30.5,60,64,65,66).  A dramatic warming of ground surface temperatures has occurred in areas such as the North slope of Alaska and areas of Canada(62). All studies of groups of boreholes measuring ground surface temperatures have found a warming trend in recent decades(61). The increase in the eastern North American continent temperatures is over 1 degree Celsius.  Ocean surface temperatures have also been found to be increasing.

    Few scientists doubt that the planet's climate is indeed growing warmer. A report  last month confirmed that 2004 was among the four warmest on record and projected 2005 will be the warmest.  2002, 2003, 2004, and 2005  were all in the top 5 warmest years in history, with 2000 and 2001 also among the warmest years in history .  "There has been a strong warming trend over the past 30 years, a trend that has been shown to be due primarily to increasing greenhouse gases in the atmosphere," .  The 7 warmest years in recorded history have occurred since 1997 and the 12 warmest have all been since 1990.  The 1990s was the warmest decade in recorded history , with  1998 the warmest in recorded history and each month of 1998 setting all time highs. But the current decade appears it will surpass the 90s .  The global average temperature has increased about 1.5 degree Celsius since 1880, and 0.7 degrees Celsius since 1975 An even greater warming is seen in global average minimum temperatures which have increased by 1.1 degrees Celsius since 1950. Northern hemisphere sea surface temperatures have increased 0.5 degrees C since 1980.  There is strong evidence that this warming trend is due to the greenhouse effect related to a buildup of carbon dioxide and similar greenhouse chemicals related to manmade increases in fossil fuel emissions and atmospheric release of other chemicals .


Ice core boring projects by scientists in Greenland, Antartica, China, and Tibet have all confirmed that historically there has been a clear and significant association between the level of greenhouse gases and global temperature over the last 40,000 years (45,45.2,45.4,45.6).  These studies also found that there have been large changes in global temperature in relatively short time intervals.

    All over the world glaciers and ice packs are melting at unusually fast rates (26.3,26.4,26.5,45.6).  Glaciologists estimate that glaciers in the alps have lost over 50% and worldwide at least 15% in the last 100 years, with glaciers retreating at an average of 9.3 meters per year.   A research group for the Soviet Geophysical Group found over 85% of 408 Asian glaciers monitored retreated in the last 40 years, with retreat averaging 13.3 meters per year.  Mauri Pelto, Director, North Cascade Glacier Project, indicates that 91 of 114 glaciers monitored for the last decade in the Northwest U.S. have retreated(26.3,26.5),   and 24 glaciers in the Rocky Mountains are retreating by an average of 13.7 meters per year.  Since 1963, over 43% of the ice on Tanzania's Mount Kenya has disappeared and similar for ice in the Andes Mountains(45.6).  Similar findings were observed in Kazakhstan, Kenya, New Guinea, New Zealand, Scandinavia, the Canadian Rockies, and the Gulf of Alaska.   The average retreat of these glaciers is 6.7 to 14.9 meters per year(26.3).  The average temperature increase in these glacial areas for the last century was found to be 0.7 degrees Celsius (26.3).  Mountain plant communities were found to be unable to migrate upward fast enough to adapt to the changing climate(26.4).

    Gases having a greenhouse effect include carbon dioxide, methane, nitrous oxide, ozone, CFCs, and water vapor.  Carbon dioxide in the atmosphere has increased over 27% in the last century(26.7,31.6), and is increasing exponentially by about 3.5 billion metric tons or 0.5% per year(9,44.4).   Methane in the atmosphere has increased over 100% in the last 100 years and is increasing exponentially at 1% per year; methane has 3.7 times the warming potential of CO2(44.4).  Chlorofluorocarbons(CFCs) are increasing at 5% per year, and have 25,000 times more warming potential than CO2.  Nitrous oxide has 180 times more warming potential than CO2, and is increasing in the atmosphere at approx. 0.25% per year.  In the coming century, carbon dioxide, methane, CFCs, and nitrous oxide are projected to be responsible respectively for 50%, 18%, 14%, and 6% of future greenhouse warming(44.4). 

    While industrial countries have in the past released the majority of carbon dioxide, if the current trends continue Third World countries will release 4 times as much carbon dioxide by 2025 as developed countries do now (1,30.5,26.7).   China is the world's most coal dependent country and the largest producer of coal (25% of world supply).  China had a 65% increase in carbon dioxide emissions in the 1980s(26.7).  China also has vast supplies of natural gas and renewable resources that have not been widely developed.  Some scientists believe the results on temperature increases, weather pattern changes, regional climate changes impacting plants and crops, and rising sea levels could be catastrophic in the next 50 years if the present pattern continues.  Computer models suggest that average global surface temperatures will rise between 2.5 and 10.4 degrees Fahrenheit (1.4 and 5.8 degrees Celsius) by the end of this century(30.5).


   Until recently The U.S. produced over 20% of world greenhouse gas emissions(carbon dioxide, methane,nitrogen oxide,CFCs,etc.) but China is now close to U.S. levels.      Carbon dioxide is responsible for approx. 50% of greenhouse gas emissions.   Burning fuel releases approx. 6 billion tons of carbon into the atmosphere each year, with the largest amount coming from coal combustion(9,30.1,43).  CO2 emissions from fossil fuel combustion is increasing at approx. 3.6% per year(30).  Coal plants are responsible for over 80% of utility CO2 emissions in the U.S., with residual oil producing 80% as much CO2 per BTU of power produced as coal and natural gas producing 60% as much CO2 per BTU(44.4).  Electric power plants are responsible for approximately 35% of U.S.  carbon dioxide emissions(30), while the transportation system is responsible for 30%, the industrial sector for 24%, and residential/commercial users 11%.  Pulverized coal plants produce approx. 2 pounds of CO2 per kwh of generated electricity.


    A comprehensive analysis of greenhouse gas trends and impacts, as well as   a detailed analysis of alternative policies and options for stabilizing global warming are given in an EPA report(35.5).  There are other factors that cause "positive feedbacks" which augment the greenhouse effect, as well as factors that have the opposite effect of cooling.  Soot, sulfuric acid haze, and haze from burning tropical forests are factors that tend to promote cooling(31.8)  Several largescale studies have documented the cooling effect of these atmospheric pollutant aerosols(58,59,60,64); computer models predict that the cooling effect has been at least 0.5 degrees C and has offset the global warming caused by greenhouse gas buildup by this amount.  The computer models modeling global temperatures have been found to predict temperature patterns relatively accurately compared to observed global temperature patterns when both green house gas increases and pollutant aerosol patterns are taken into account (60,64,65,66).  Although there is direct global cooling due to global ozone layer loss (35.7), it has been found that the decline in ozone and the buildup of greenhouse gases also have significant mutually reinforcing mechanisms which make both more problematic (63). Global warming increases ice clouds in the stratosphere which increases ozone layer decline, while ozone layer decline increases ultraviolet radiation which causes decline in ocean phytoplankton which then causes reduction in ocean sequester of CO2 from the atmosphere.  The increasing level of world deforestation (1,9,30.5,44.4) and changes in the earth's albedo and cloud cover due to these other factors also have feedback effects which have been modeled in models to assess global warming.  Another positive feedback involves microbes in the soil which release CO2.  Some studies indicate that as global warming occurs, microbial action will substantially boost CO2 in the atmosphere over the next 50 years(32.3,32.7).  Some studies indicate considerable levels are already being released in the tundra areas of Alaska and Siberia, which was not occurring in the 1970s (32.7).   Studies have also found that the warmer ocean surface temperatures are causing major increases in the magnitude of hurricane winds and damages(69,69.5).


    Estimates of the future cost of greenhouse emissions vary widely, with most in the range 0.5 to 2.4 cents per kwh for power plants(12,26,28,44.4), but some are extremely high.    A study by economist William Cline estimated the total cost at $60 billion per year to the U.S., including: $18 billion for agriculture impact of heat stress and drought; $11 billion for addition cooling cost, and   $7 billion for damage from sea level rise(30.7).  An Urban Institute study assessing the infrastructure damage or needs to prevent damage from sea level rise to the city of Miami, estimated the cost over the next century at over $1 billion(20).   Data from a satellite launched in 1992 indicate that global sea levels are rising approx. 100 percent faster since 1992 than over the last century- about 3 millimeters per year(35.3).


   The relative cost damage due to carbon dioxide emissions from different electric power sources are proportional to the CO2 produced per unit of energy production.  The total carbon dioxide produced by different technologies(27) in metric tons per Giga‑Watt Hour(GWH) are:



         conventional coal plant                964

         conventional coal with wet scrubber   1030

         fluidized bed coal plant               980

         IGCC(Coal gasification combined cycle) 751

         oil fired plant                        726

         natural gas fired plant                484

         photovoltaics                            5

         solar thermal                            4


     The most cost effective measures for controlling carbon dioxide growth

appear to be  conservation programs/standards and  energy efficiency improvements.  Another innovative approach being investigated is carbon sequestering by ocean calcareous algae or by halophyte plants that grow in saline or desert soils(9).   Recent studies that assess cost effectiveness of methods to reduce greenhouse emissions include (27,30.5,30.9,44.4).  A U.S. Dept.  of Energy study(27) ranked CO2 reduction strategies as follows:


    Reduction Strategy           Cost              Maximum Percent

                                 ($/ton removed)        CO2 Reduction

    Conservation Standards

                 High                   < 0                    18%

                 Very High         280                    28%


    Reforestation Offsets          88                    50%

    Sequestering by Algae or      

        Halophyte plants        100 to 200


    Flue gas scrubbing            230

    (coal power plant)

    Carbon Tax    $100 /ton    565                    31%

                        $250 /ton       710                    51%


How Emission Prices and Emission Caps Would Work

Putting a price on carbon dioxide emissions--essentially taxing those emissions--would boost their cost, thereby encouraging firms as well as households to limit emissions (by using smaller amounts of fossil fuels or by relying on fossil fuels with relatively low carbon content) as long as the cost of doing so was below the tax or price. That price-based approach would establish an upper limit on the cost of individual emission reductions--the level of the price--but would not ensure that any particular emission target was met. That approach would balance expected benefits and actual costs provided that the price per ton was set equal to the expected benefits resulting from eliminating a ton of carbon emissions

Cap-and-trade programs, in contrast, offer a way to set an overall limit on the level of carbon dioxide emissions while relying on economic incentives to determine where and how emission controls take place. Under such a program, policymakers would establish an overall cap on emissions but allow firms to trade rights to those emissions, called allowances. Trading would allow firms that could control their emissions most cheaply to do so in order to sell some of their allowances at a profit to firms that face higher costs to limit their emissions. Furthermore, the price increases that would result from the cap would encourage households to consume smaller amounts of fossil fuels, thus leading to lower carbon emissions. A cap-and-trade program would achieve the emission target at the lowest possible cost, but (as described below) it would not necessarily balance actual costs with the expected benefits achieved by the target.

A cap-and-trade program with a "safety valve" combines an overall cap on total emissions with a ceiling on the allowance price(24). Under that hybrid approach, policymakers would establish an overall cap and allow firms to trade allowances, but they would also set an upper limit on the price for allowances, referred to as the safety-valve price. If the price of allowances rose to the safety-valve price, the government would sell as many allowances as was necessary to maintain that price. Thus, if the safety valve was triggered, the actual level of emissions would exceed the cap. The cap would be met only if the price of allowances never rose above the safety-valve price.

Emission Prices Are More Efficient than Emission Caps

If policymakers had complete and accurate information on both the costs and benefits of achieving various limits on emissions, they could achieve the limit that best balanced costs and benefits using either an emission price or an emission cap. With full information, policymakers could set the price or cap to the level at which the cost of the last reduction was equal to the benefit from that reduction. However, neither the costs nor the benefits are known with certainty. For that reason, the best policymakers can do is to choose the policy instrument that is most likely to minimize the cost of making a "wrong" choice. Choosing policies that are too stringent (by setting too high a price or too tight a cap) would result in excess costs that are not justified by their benefits. Alternatively, choosing policies that are too lenient (by setting too low a price or too loose a cap) would result in forgone benefits that would have outweighed the cost of obtaining them.

Analysts generally conclude that uncertainty about the cost of controlling carbon dioxide emissions makes price instruments preferable to quantity instruments because they are much more likely to minimize the adverse consequences (excess costs or forgone benefits) of choosing the wrong level of control.(1) The price approach would motivate people to control emissions up to the point where the cost of doing so was equal to the emission price. If actual costs were less than, or greater than, anticipated, people would limit emissions more than, or less than, policymakers projected. However, emissions would be reduced up to the point at which the cost of doing so was equal to the expected benefits, provided that the emission price was set equal to the expected benefits of reducing a ton of carbon dioxide emissions. In contrast, a strict cap on emissions could result in actual costs that were far greater (or less) than expected and that therefore exceeded, or fell below, the expected benefits.

The advantages of a price-based approach stem mainly from the fact that the cost of limiting a ton of emissions is expected to rise as the limit becomes more stringent, while the expected benefit of each ton of carbon reduced is roughly constant across the range of potential emission limitations in a given year. That constancy occurs because climate effects are driven by the total amount of carbon dioxide in the atmosphere, and emissions in any given year are a small portion of that total. Further, reductions in any given year probably would fall considerably short of total baseline emissions for that year.

  Northeastern U.S. States Regional Greenhouse Gas Plan

Seven states signed the plan in December 2005 to create a cap and trade CO2 emissions market called the Regional Greenhouse Gas Initiative. The states -- New York, New Jersey, Vermont, New Hampshire, Maine, Connecticut and Delaware -- hope to cap emissions from power plants at 1990 levels of about 121 million tons of CO2 through 2014 and then reduce it 10 percent below that level in 2018.  Maryland has since also voted to join the group.   
Power plants in the U.S. Northeast that face rules to cut carbon dioxide emissions would be allowed to save costs by methods such as planting trees and tapping landfills for methane, according to a draft plan by Northeastern states who have signed the country's first regional greenhouse gas plan.

In the cap and trade market the RGGI has developed, the states would hand power plants CO2 emissions targets. If the plants cut emissions under those limits -- by switching from coal to cleaner-burning natural gas for example -- they would earn credits.  The RGGI draft model on Thursday said the plan would cost homeowners about $3 to $16 more per average home in 2015, a reduction from the group's earlier predictions.

The RGGI estimates its CO2 allowances would cost far less, and it has set up "safety valves" if prices get too high. If the price of the emissions allowances rose above set limits, power plants could get credit for reducing emissions by other methods outside the RGGI region. Methods include planting trees or capturing and burning methane gas at landfills. Methane is about 20 times more potent a greenhouse gas than carbon dioxide.

Toxic Metals


2.   The U.S. Center for Disease Control ranks toxic metals as the number one environmental health threat to children, adversely affecting millions of children in the U.S. each year(2,3, 9-9.7,42) and thousands in Florida.   EPA and CDC indicate that over 3 million children have their health significantly adversely affected or learning ability significantly adversely affected by lead in drinking water, mercury in fish, cadmium in shellfish, or other toxic metals from emissions(2,3,8.5-9.7,37).  Toxic metals are also accumulating in the environment, food chain, and people at increasing levels and are one of the largest health problems affecting the U.S. and other industrial countries (9.7,42).  According to an EPA assessment, the toxic metals lead, mercury, cadmium, chromium, and nickel are all ranked in the top 12 toxics having the most adverse health effects on the U.S. public based on toxicity and current exposure levels(9.5,9).  Aluminum, mercury, and cadmium have been found to be accumulating in the brain and kidneys of large numbers of people exposed to metallic pollutants and toxic metals in the food chain and drinking water(2,9.7,42)- causing widespread serious neurological and kidney problems.   As later referenced, emissions are the main source of mercury in lakes and streams and acid pollutants are a major factor in the level of mercury or other toxic metals in fish and of lead or cadmium in drinking water(42,37,8).


    Hundreds of lakes and rivers in Florida and thousands in other states have been documented to have dangerous levels of mercury and other toxic metals in the fish and food chain(36.5,37,28.5,42).     Health warnings have been issued against eating fish in the thousands of lakes  or rivers affected, as well as against eating sharkmeat caught  throughout Florida or sea trout from areas of the Florida East Coast or Panhandle Gulf Coast due to dangerous levels of mercury in the fish(37,57).     Florida commercial fishermen sold 6.8 million pounds of sharkmeat in 1989, 36% of the U.S. total.  Other commercially important seafoods are also likely to have dangerous levels of mercury according to experts.  High levels of toxic metals have been found in shellfish in many areas of the state. This represents a major economic cost and risk to both Florida and the U.S.

   The current level of mercury emissions of Florida incinerators and coal plants (over 9 tons and 3 tons per year respectively) appear to be far above the level required for depositions over large areas of Florida to be above the level previously documented to be sufficient to bioaccumulate to dangerous levels in fish.  Many fish eating bird in Florida and 3 Florida panthers that eat fish eating animals have died from mercury poisoning, and toxic metals such as mercury and cadmium have been found to be estrogenic chemicals having adverse effects on hormonal and reproductive systems. The majority of Florida panthers have been found to have abnormally high estrogen levels, with males having higher estrogen levels than testosterone levels and severe reproductive problems(42,43).    Toxic levels of aluminum and other toxic metals also appear to be the main factor adversely affecting fish and other organisms in lakes or streams that are becoming acidic throughout the U.S.(8)    Commercial fishermen and the sportsfishing sector have already been seriously adversely affected.     There is consensus among researchers that the main source of the mercury in lakes is from air emissions, with the largest sources being incinerators and coal plants in most areas(28.5,42).   A study by Univ. of Florida scientists in the 1990s  found that the level of mercury deposition in wetland sediments was increasing(11).  There is also consensus that acidity and acid pollutants are major factors in the level of toxic metals getting into fish and the food chain(8).  

    According to the Fla. Game & Fish Commission, the bass fishery in Fla. is responsible for over $1 billion per year to the Florida economy.  Over half of the fishery has been affected by health warnings and studies have indicated a decline of approx. 20 % in fishing in areas studied that have advisories.  Over 1 million acres of streams and lakes are affected by health advisories in Fla., with the affected areas producing approx. 20 harvestable bass(> 10 inches) per acre per year.  Thus the direct impact on the Fla. freshwater and saltwater fisheries appears to be in the hundreds of millions of dollars per year level.


     Mercury, lead, aluminum, and other toxic metals have been found to be accumulating in forest floors at levels high enough to cause forest declines and diebacks in some areas of Europe and the Eastern U.S(27.5).      Both inorganic and methyl mercury are toxic to spruce seedlings at levels of 0.4 to 0.5 ppm.   Many areas of Europe have passed this point in cumulative mercury buildup and some areas of the Eastern U.S. are approacing this level(27.5).


     If a conservative estimate  of the average annual cost per person having a significant adverse learning disability or health effect  were estimated at $3,000,  the annual health cost due to toxic metals would be over  $9 billion per year in the U.S.     The actual cost is likely much higher than this.    Florida appears to be one of the states most adversely affected(3,42,2).  A simple proration based on population would give $460 million for Florida.


     High levels of mercury have been found to evaporate from fly ash piles at temperatures higher than 70 degrees F.   Temperatures above 86 degrees would likely produce levels of mercury in the vicinity violating EPA ambient air guidelines(14.5,42).  Even after cooling, Florida ash piles can reach 140 degrees in the summer(14.5), and ash piles in plants using lime to control sulfur often get much hotter than this due to hydration.


     The coal and ash piles from coal plants or incinerators contain large amounts of toxic metals(as well as dioxins, furans, radioactive isotopes, etc.) which can affect both ground and surface water, as well as considerable particulate and toxic air emissions.  A coal plant with scrubbers per megawatt of power generated produces about 308 tons of fly ash, 77 tons of bottom ash, and 364 tons of flue gas desulfurization waste for landfilling- all containing toxic metals and other toxic constituents(50).  Most coal ash laboratory tests have found cadmium and arsenic at levels considered hazardous per EPA RCRA standards(50).  Toxic constituents from coal combustion waste disposal sites have been detected in both on-site and off-site ground water and surface water.  Where the depth to groundwater is less than 30 feet, "there is a reasonably high potential that leachate will reach groundwater" unless extensive precautions are taken(50).  The high PH that often characterizes Western coal tends to cause the release of harmful toxic metal such as arsenic, selenium, and manganese.

   The average cost of disposing of hazardous waste in bulk in the Midwest is $210 per ton(55).  The Dept. of Environmental Regulation reports that recent contracts for disposing of hazardous waste in bulk in Florida ranged from $250 to $360 per ton, including transportation and taxes.  Assuming that a conservative $150 per ton is the total cost of disposing of fly ash( or of related health and cleanup cost where not disposed of properly), that $100 per ton is the cost of disposing of bottom ash, and $50 per ton is the cost of disposing of desulfurization waste  gives a total cost of ash disposal per megawatt(MW) of coal plant power of(308 x $150 + 77 x $100 + 364 x $50) = $72,100 per year.  Assuming a 70 % capacity factor gives 6570 megawatt-hours per MW of power.  Thus the ash disposal cost would be 1.1 cents per kwh.


   The ash from incinerators contains more toxic metals and other toxics such as dioxins and furans than coal ash;  most incinerator fly ash tested has been shown to be toxic under EPA toxicity standards and much is in a soluble form (50.2,50.4,51.4 to 54).  The metals most commonly failing the toxicity test and cadmium and lead, but high levels of mercury, arsenic, and chromium have also been found(53).  Some states already require ash to be tested and disposed of as toxic waste.  Tests by the State of New York showed more than half of its incinerator waste tested was "hazardous" and all waste in New York will be disposed of in hazardous waste sites or special sites with additional precautions(18).  Bottom ash has also been found to have relatively high levels of toxics(53).  The toxics in ash has been documented to have widespread and serious health effects on those working with the ash at the facilities, and the health effects on the public from trace metals and dioxins have been shown to be higher than for the traditional pollution emissions normally considered(50.6). Ash disposal has also been found to face much higher cost than normal landfilling due to: abrasive impact on equipment tires, corrosive effect on equipment, unworkability when wet, and health effects on workers(51,2).  Many researchers think ash disposal and pollution cleanup from ash piles will become increasingly expensive.  Based on 1990s data, the 160 MSW incinerators operating then in the U.S. produced about 8 million tons of ash each year containing, by rough estimate, some 18,000 tons of lead, plus lesser quantities of other potent toxins such as cadmium, arsenic, mercury and dioxin.[ Assuming the 8 million tons are 90% bottom ash containing 2000 ppm lead and 10% fly ash containing 4000 ppm lead]  Ash containing 2000 ppm lead is contaminated at a level more than 5 times as high as the "level of concern" EPA recently set for lead in soil(50.2b).  


    A 1000 ton per day mass burn incinerator at 76% capacity producers 25 megawatts of power and 138 million kwh per year, along with 100 tons of fly ash and 200 tons of bottom ash per day.  At $200 per ton for fly ash disposal(55) and $50 per ton for bottom ash disposal, the total disposal cost would be $10,950,000

per year.  This give a cost of 7.9 cents per kwh.


     Florida utilities burned 27,955,400 tons of coal in 1991(56).  Based on the EPA estimate of .21 ppm mercury in Eastern coal, this would give approx. 5.8 tons of mercury in the coal burned in Florida per year.  Fla. utilities burned 48.3 million barrels of oil in 1991, and using EPA estimates for .06 ppm mercury in residual oil and .4 ppm in distillate oil, would give approx. 0.53 tons of mercury in oil burned by Fla. utilities.   Based on current technology it appears likely that the majority of such mercury was emitted directly or indirectly.

Similarly municipal solid waste incinerators were projected to burn approx.

5.8 million tons of garbage in 1991, with an average mercury content of 2 to 3 ppm according to EPA data.  This would give a content of approx. 12 tons of mercury, most of which would be emitted based on current controls.  DER estimates of MSW incinerator emissions are somewhat lower.  Based on this and previous studies by the Dept. of Environmental Regulation, it is assumed that coal power plants are responsible for approx. 15 % of Florida mercury emissions and MSW incinerators for 20% of mercury emissions.  Fla. coal plants generated 62,110,000,000 kilowatt hours of electricity in 1990(56) and MSW incinerators generated 7,951,000,000 kwh of electricity.  If economic cost due to mercury(and other toxic metals) is assumed to be $600 million per year, with coal plants responsible for 15% of emissions and MSW incinerators for 20% of emissions, then the economic cost would be 0.14 cents per kwh of electricity generated.  Likewise for MSW incinerators, the economic cost would be 1.51 cents per kwh generated.



Health Effects of Dioxin


2.5. Dioxin and related compounds have been found in significant levels in the food chain and people in the U.S. and other industrialized countries.  The main source of such dioxin is emissions from incinerators(43).  Dioxin has been found to be one of the most toxic and carcinogenic chemicals ever tested, and has been found to cause cancer, endocrine system and immune system damage, birth defects, learning disabilities, etc.  Dioxin is being found at dangerous levels in cows milk, mother's milk, sperm cells, etc.- especially near incinerators.  No studies were found that attempted to quantify the total cost of health effects due to dioxin, but studies indicate that impacts appear to be large and in the billions of dollars(43).


Land Impacts of Coal and Ash Piles


3. Coal plants require considerable extra land and facilities for handling coal brought in by barge or trains.     There are also considerable impacts from coal mining and transportation. The coal and ash piles from coal plants or incinerators contain large amounts of toxics which can affect both ground and surface water, as well as considerable particulate and toxic air emissions.     U.S. coal plants annually release over 900 tons of radioactive uranium and 2000 tons of thorium into the environment, most into coal ash which is usually radioactive(44.6).  More radioactivity was released by burning coal than is contained in the fuel of all nuclear power plants in the U.S., but without the regulatory oversite faced by nuclear facilities. Coal ash in Florida has been found to be releasing toxic metals and radionuclides into water bodies and the food chain.

    The ash from incinerators contains more toxic metals and other toxics such as dioxins or furans than coal  ash;  most incinerator ash tested has been shown to be toxic under EPA toxicity standards, and a new Federal court ruling has required that such waste that tests to be toxic be treated as toxic waste.  Some states had already required ash to be tested and disposed of as toxic waste.  Many researchers think ash disposal and pollution cleanup from ash pile toxics will become increasing expensive.  Based on an assumption of $200 per ton for fly ash disposal and $50 per ton for bottom ash disposal, the total disposal cost of incinerator ash would be $10,950,000 per year for a 1000 ton per day MSW facility, or a total of 7.9 cents per kilowatt-hour of energy generated(43.5). 

    The ash from incinerators contains more toxic metals and other toxics such as dioxins or furans than coal ash;  most incinerator ash tested has been shown to be toxic under EPA toxicity standards. Some states already require ash to be tested and disposed of as toxic waste.  Many researchers think ash disposal and pollution cleanup from ash pile toxics will become increasing expensive.

    High levels of mercury have been found to evaporate from fly ash piles at temperatures higher than 70 degrees F. Temperatures above 86 degrees would likely produce levels of mercury in the vicinity violating EPA ambient air guidelines(14.5,42).  Florida ash piles can reach 140 degrees in the summer(42), and ash piles of plants using lime to control sulfur often get much hotter than this due to hydration.  Statewide tests found over 30% of Floridians have dangerous levels of mercury exposure, and mercury is documented to commonly cause many types of chronic health conditions.


Radioactive Coal Ash and Emissions


3.5. Emissions and ash from burning coal contain large amounts of radioactivity. Waste ash at some sites in Florida have caused serious radioactive contamination of groundwater, surface waters, and bays.  Coal burning power plants in the U.S. release over 1000 tons of uranium and over 2000 tons of thorium into the environment(33.5).  People are being exposed to increasing amounts of radioactive isotopes from coal through air emissions, water runoff impacts, and the food chain.   Recent studies have shown that over 20% of cancers to people less than 20 years old are due to low level radiation in drinking water that meets Federal regulations. Thus radioactive emissions into water reservoirs such as Deerpoint Lake, Hillsboro River, Lake Okeechobee, etc. may be increasing cancer rates beyond that of the impact of breathing radioactive emissions.   No studies including estimates of these cost for the U.S. or Florida were found, but radioactivity is a major cause of cancer and birth defects.


Acid Pollutants: Damage to Lakes and Bays


4.  In addition to documented damage to fish populations of rivers and lakes which results in reduced recreational opportunities, acid pollution also causes other damage to lakes and bays. Acid rain, mainly in the form of nitrogen oxides, is causing serious damage and mass killings of aquatic life in Atlantic coastal waters and bays, as well as in large lakes.   Reversal of the rapid decline in Atlantic coastal waters and fisheries will require measures to control air pollution as well as sewage and dumping of waste(25,8).    Nitrogen oxides, produced mainly by vehicles and power plants, are producing damage to aquatic life not by acidification but through eutrophication.    The  excess nitrogen along with other nutrients creates excessive growth of algae, which chokes off the oxygen supply and blocks sunlight needed by other aquatic life.  In recent summers thousands of lobsters, crabs, etc. were killed by this mechanism in Long Island Sound. Other serious recent occurrences took place in Chesapeake Bay, Delaware Bay, the New York Bight, Long Island's Narragansett Bay, North Carolina's Albemarie‑ Pamlico Sound, Lake Okeechobee, Tampa Bay,etc.     Air emissions were estimated to be responsible for approx. 75% of the nitrates entering the Chesapeake Bay(25). Likewise, South Florida regional water management officials have estimated that pollutants in rainfall are responsible for at least 25% of the nitrogen entering Lake Okeechobee which is in serious decline and the source of much of south Florida's drinking water(25); and a recent DEP funded study of the Apalachicola River and Bay by FSU researchers found atmospheric emissions to be the major contributor to the nitrogen load of that system(39).      Environmental Defense Fund researchers indicate that the economic damage to rivers, lakes, and bays  along with lost recreational assets and lost food supply is several billion dollars(41).  Point sources were responsible for over 50% of Chesapeake Bay deposition, with the majority being from long range transport from utility plants(25).  


Crop Losses from Acid Pollutants


5.  A Congressionally funded 1985 study on air pollution effects on 4 major crops(soybeans, peanuts, wheat, corn) estimated that air pollution is costing farmers between 2 and 3 billion dollars per year(35).      For example average peanut yields were found to have been reduced by 24% due to air pollution. Similar levels of reduced yields have been found for tomatoes in some areas.         According to Walter Heck, Chairman of the National Crop Loss Assessment Committee (EPA), total crop losses in the U.S. due to ozone are over $5 billion per year(15).

  A study by Cornell University researchers estimated total U.S. crop losses due to  air pollution at over 12% per year and over $6.5 billion(6).     There is a strong influence by relative humidity level on internal pollutant uptake of sulfur dioxide and ozone by plants or crops such as soybeans. For the same exposure level, vegetation growing in humid areas experience a significantly greater internal flux of pollutants than that in more arid regions(19).    Florida is especially susceptible to plant damage by air pollutants because of its humid climate(41,8).


Materials Damage from Acid Pollutants


6. Acid fog(or humid acid air) in urban areas is becoming a serious problem.  The PH of urban fog is often much lower than that of acid rain and has been measured as low as 1.7 in some urban areas. Acid fog or acid air in humid areas has been found to often be between 10 to 100 times more acidic than acid rain in the same area.        Acid fog has significant adverse effects on materials, health, and plants(18,41).


7. Four major car importers have moved their import operations from Jacksonville due to acid rain damage to paint finish of cars(World Cars/BMW, Hyundai, Saab, and Peugeot).  Jacksonville Electric Authority and the Port Authority are being sued for millions of dollars by the importers for damage to car finishes (2).


8. A joint study by the U.S. Army Corps of Engineers, the Brookhaven National Laboratory, and EPA estimated the damage to buildings alone done by acid rain in 17 northeastern and Midwestern states as over $6 billion per year.  The study concluded an acid rain control program would probably pay for itself just in reduced damage to building materials and paint finishes alone(17).     H.L. Magaziner testifying before Congress for the American Institute of Architects indicated that corrosion costs are high and are several billion dollars per year(16).

     A Midwest Research Institute study estimated acid deposition damage to paint surfaces as over $35 billion per year(29). Scholle (31) summarizes a study by F.H. Haynie in which Haynie estimates the damage to zinc coated transmission lines as between .0028 mills and .0132 mills per kwh transmitted. A study published in the journal: Material Performance, estimated damage to metal buildings and structures at over $2 billion per year(32).


Health Effects of Air Pollution


9. New medical studies have found the health damage from small particulates, including soot and sulfates, to be much more serious than previously thought- affecting the health of large number of people throughout the U.S.(49-49.8,70)    Persons living in areas that exceed Federal Standards for particulates on 42 or more days per year had a much higher risk of respiratory disease, with a 33% chance of bronchitis and a 74% greater risk of asthma(49.6).  The cost of the air pollution related health damage due to air pollution beyond the Federal standards in a 4 county area including Los Angeles was estimated to be over $9.4 billion per year(9.8).  Adverse effects were also significant in areas not exceeding Federal standards.   An EPA study estimates that approx. 60,000 people per year die in the U.S. from lung damage caused by breathing particulates(31.2).    The study found a roughly 6% increase in deaths for every 50 gram increase in small particulates per cubic meter of air. Air pollution is a serious problem worldwide affecting children the most.  Respiratory problems is now the number one cause of death among children(68).  Particulate pollution from cars, power plants and factories leads to development of heart disease, with heart effects being even more significant than respiratory effects(70). Exposure to tiny-particle pollution can actually lead to ischemic heart disease, which causes heart attacks, as well as irregular heart rhythms, heart failure and cardiac arrest. Such PM2.5 pollution provoke low-grade pulmonary inflammation, accelerating development of atherosclerosis — a leading cause of heart disease — and altering heart function.



10. Studies have found that acid pollutants, especially nitrogen oxides combine with volatile organic compounds to form smog which affects most urban areas and has been found to have serious health effects.  In addition to direct health effects, such ozone has been found to infiltrate buildings and homes and to promote greatly increased volatile organic compound emissions from carpets and carpet backings.  Among the VOC emissions found at commonly found ozone levels  (at 28 to 44 parts per billion) were increased levels of suspected carcinogens such as formaldehyde and acetaldehyde, which increased by factors of 3 and 20 respectively(31.5).


11. There has been a dramatic increase in lung related illnesses and children’s asthma(31.2,41,49).   Annual asthma deaths have increased 77% in the last 10 years.  The percent of Americans with Asthma increased 33% during this period, and hospitalization for children under 15 doubled.   A recent Univ. of Southern California study found children in the heavy smog/ozone area of Los Angeles had 6 to 17 percent less lung capacity than those in less polluted areas.  Autopsies of adolescent victims of motor vehicle accidents in Los "Angeles found 80% had "notable lung abnormalities" and 27 % had severe lesions in lung areas known to be affected by noxious substances(23.5,67,68).  Asthma was much more prevalent and more serious is such areas of higher air pollution(68).


12. Nitrates in drinking water have been found to cause learning disabilities, birth defects, brain cancer, esophageal cancer, stomach cancer, etc.(21.5).      As previously noted atmospheric deposition is a major source of nitrates in reservoirs and water bodies.  Both sulfur and nitrogen oxides have been found to cause lung disease, as well as being precursors of ozone/smog(41).


13. Both sulfur and nitrogen oxides have been found to cause lung disease, as well as being precursors of ozone/smog(41,49.2).   An American Lung Association Study in 1988 estimated health costs and lost work productivity due to acid rain pollutants at over $40 billion per year(22).    A study commissioned by Los Angeles officials found that air pollution related health costs and lost work productivity in the Los Angeles area are over $10 billion per year(18). A study of fetal deaths in urban areas found that air pollution, especially nitrogen oxide(NO2) is a major factor in spontaneous abortions/fetal deaths due to hypoxia(insufficient oxygen).  In the study NO2 pollution appeared to be responsible for about 20% of fetal deaths(67).



13.3. Health Effects from Living Near an Incinerator:    A UK study found that there was an increased risk of lethal congenital anomaly such as spina bifida and heart defects for women living near incinerators(72a).  Two other studies (72bc) showed a significant increase in the risk of sarcoma, correlated both with the level and the length of environmental modeled exposure to dioxin-like substances. The risk excess is also evident in females, and, for both sexes taken together, for cancers of the connective and other soft tissue. Another study found that exposure to high levels of dioxin was correlated to significantly lower boy to girl birth ratio(72d).  An ATSDs investigation found an increased pattern of respiratory problems in community residents living near an incinerator(72e). In addition, residents complained about irritation of the airways and poor motor coordination.  Another study’s results indicated a significantly increased risk of mortality among women living in the vicinity of the incinerators compared with those living far away, for all causes, colon and breast cancer, diabetes, and cardiovascular diseases(72f).



13.5. Numerous studies have found that municipal and medical waste incinerators emit large amounts of pollutants including toxic metals, dioxins and furans, acid pollutants, and pollutants that adversely affect the ozone layer(43.5).    A major study of the health related cost of MSW incinerator emissions for the U.S. Dept. of Energy estimated the cost to be approx. 5.2 cents per kwh of energy generated(26).  A major study by the Bonneville Power Administration estimated an average cost for toxic emissions and ash from municipal incinerators as 11.1 cents per kwh of energy generated(46.5). These are comparable to costs developed and reviewed in (43.5).




Other Damage Cost Estimates


14. Visibility impairment due to sulfate haze impairs civilian and military air traffic, as well as the scenic view in National Parks and recreational areas.   Smog/haze curtails or slows commercial, military, or private air traffic from 2% to 12 % of the time in summer(35).  The National Park Service estimates tourist related losses due to visibility impairment at over $6 billion per year.


15. A recent EPA report estimated that the economic damage from sulfur dioxide emissions was between $490 to $728 per ton of emissions(36).   Another EPA report estimated the cost of small particulate matter(under 10 microns) at $2400 to $9000 per ton of particulate emissions.    This would yield a cost in Florida based on Florida emissions  and the most conservative EPA estimate of approximately $500 million per year for sulfur dioxide emissions alone.     The EPA studies and a study by Olav Holmeyer(12) for the Commission of European Communities found that the uncounted "societal cost" of unscrubbed coal power production are almost as much as the direct cost that is typically considered in

energy policy decisions.   Holmeyer's estimates for the range of damage from sulfur dioxide was between .3 to 1.6 cents per kwh and for nitrogen oxides was between .35 to 1.8 cents per kwh.     An assessment by the New York Public Service Commission put the societal economic cost of coal power at 1.4 cents per kwh (28).


16. "OTA's analysis of acid deposition and other transported air pollutants concludes that these substances pose substantial risks and costs to American resources."  "Any program to reduce emissions significantly would require 7 to 10 years to implement, and perhaps longer for major impacts on the problem"(35).




Studies of the Economic Cost of Health and Environmental Impacts


17. Based on studies and evaluations performed by Staff of the New York Public Service Commission, the New York PSC uses a cost of 1.405 cents per kwh in policy and bidding procedures as the environmental cost of standard coal plants with a defined set of emission rates and other impacts(28).     Technologies with lower emission rates or impacts get assigned proportionately lower environmental costs. Of the above total .905 cents is related to air emissions  with .25 cents for sulfur dioxide, .55 cents for nitrogen oxides, .005 cents for suspended

particulates, and .1 cents for carbon dioxide.   Only 20 % of the full carbon dioxide estimate of .5 cents per kwh was included for official purposes due to controversy over the impacts of global warming.   The other .5 cents per kwh recognized the higher land and water impacts of coal plants due to coal piles, coal handling facilities, and ash disposal.


18. The California Energy Commission staff performed a study of atmospheric pollution and abatement cost for the South Coast Air Basin in Los Angeles. Out of an estimated total external cost for coal plants of 7.85 cents per kwh,  3.53 cent was for sulfur dioxide, 3.56 cents was for nitrogen oxides, and .76 cents was for carbon dioxide(1 & 14).


19. The Wisconsin Public Service Commission and Northwest Power Planning Councils use adders of 15% and 10% respectively for environmental and health costs when comparing coal plants to conservation or alternative energy options(14).


20. A 1989 study of Schillberg for the State of California estimated a total external environmental/health cost of 2.71 cents per kwh‑‑ of which 0.31 cents was for sulfur dioxide,  0.83 cents was for nitrogen oxides, and 1.58 cents was for carbon dioxide(14).


21. Estimates of the societal cost of increased health care expenditures, environmental degradation, and lost employment due to atmospheric emissions range from $100 billion to $300 billion per year(13).


22. Even before the Persian Gulf War, the U.S. Department of Defense was spending at least $20 billion per year to safeguard oil supplies in the Persian Gulf area.     This amounts to a cost of at least $20 per barrel of oil imported to the U.S. from the Middle East, and is a subsidy of a lower price of oil both in the U.S. and abroad(13).   Other hidden tax credits and subsidies keep oil and gas prices low in the U.S. and encourage overuse; energy imports are the major factor in

the U.S.  balance of trade deficits which have made the U.S. the worlds' greatest debtor nation.    The U.S. has more tax credits and much lower taxes on fuel than our major foreign competitors.


23. A recent Pace University study of the societal costs of generating electricity commissioned by the U.S. Dept. of Energy estimated the societal cost of sulfur dioxide emissions as over $4000 per ton(26).   Their estimate of the total societal cost of a wide variety of electric generating options is given in Table 1.  The study also points out that 20 states have required utilities to include environmental externality costs in some manner in planning, bidding, or other resource acquisition procedures, and at least 9 more state have current formal processes considering inclusion of such cost.  Table 2 combines the Pace Univ. study societal costs(4) with estimates of variable production costs  for the different plant options to give estimates of total societal operating costs.


24. A study by D.L. Block of the Florida Solar Energy Center developed estimates of the direct environmental and health cost of emissions by utilities in Florida. The estimate of the composite cost of emissions was 2.0 cents per kwh(5).



Ozone Layer Depletion


25.  The ozone layer over the U.S. has been found to be thinning,  which is likely to have serious health and biological implications(1,31.4).  There has been a resulting increase of approx. 0.5% per year in ultraviolet radiation(UV) since the mid 1980s, with an even larger increase of approx. 2% in 1992 augmented by the Mount Pinatubo volcanic eruption(7.3).  Biologists indicate that the increased ultraviolet light due to ozone declines is already having significant adverse impacts on ocean plankton, coral reefs, and ocean food chains.     A 1% increase in ozone in the atmosphere has been found to lead to an approx. 2% to 3% increase in skin cancer, as well as to damage of the immune system, crops, plants, and plankton.  According to the Skin Cancer Foundation of New York, the number of cases of the most serious type of skin cancer, melanoma, has risen by over 6% per year over the last decade, and other types of skin cancer are also increasing(19.5).  UV exposure also adversely affects the immune system, and has been documented to be related to immune system diseases and genetic or metabolic problems such as herpes simplex, tuberculosis, leprosy, lupus, etc.  Higher doses of UVB appear to have even more widespread adverse effects on plants, animal, and ecosystems.  Frogs and amphibians are disappearing all over the world and the increase in ultraviolet radiation(B) has been found to be a major factor by damaging frog eggs.  Forests have also been found to be adversely affected.  UVB also damages polymers used in building materials, paints, packaging, etc(7.5).


          The ozone layer  declined globally over 4 % between 1979 and 1993, and even more over northern U.S.  latitudes.  Satellite measurements by Nimbus-7 in 1992 and 1993 show levels  reached record lows over much of the earth and are declined much more rapidly in 1992 than ever before, perhaps aided by aerosols from the Mt. Pinatubo eruption(1).  The global decline in 1992 alone was over 2 %. The Antarctic ozone hole in 2003 was the second largest ever observed, say scientists from three U.S. federal agencies. Researchers from the National Oceanic and Atmospheric Administration (NOAA), the National Aeronautics and Space administration (NASA), and the Naval Research Laboratory made the observations. The seasonal ozone hole over Antarctica widened sharply in 2005, making

it the biggest hole since 2000 and the third largest on record, according to measurements reported here on Tuesday by the European Space Agency (ESA).


        An ozone hole has been found to be forming over the Artic area similar to the one previously documented over Antarctica.   Scientists have found concentrations of ozone destroying chlorine monoxide over the U.S.  to be much higher than previously expected.  Chlorine compounds such as chlorofluorocarbons(CFCs) and other ozone layer destroyers such as nitrous oxide have been found to be rapidly increasing in the atmosphere in recent years.  NASA has found natural chlorine to account for only 20% of the chlorine effect on ozone in the stratosphere(1). 

     This decline could have large effects on Florida's sun based tourist businesses, as well as on increased health costs and crop losses(7.5).    Florida tourism is a multibillion dollar industry, and insurance cost of skin cancer treatment are already rapidly increasing.  A Florida Dept. of Commerce official indicated that there appears to have been a significant decline in beach tourism in the last 5 years due to ultraviolet skin damage concerns.  Tourist related sales in beach areas amount to over $10 billion per year, not counting large amounts of uncounted real estate business, so even a decline of 1% would result in reduced tourism spending in the hundreds of millions of dollars.


     Air conditioning systems are a major user of CFCs, and will be both less efficient and more expensive in the future due to limits or bans on the use of CFCs. New cooling technologies that do not use CFCs such as natural gas chillers, natural gas heat pumps, heat pipe cooling systems, and desiccant cooling systems appear to be cost effective for many applications and are likely to expand their share of the cooling market.


Acid Pollutant Reduction Strategies


26.  Florida manmade sources are estimated by the FCG(12) to account for 66% of sulfur dioxide deposition in Florida.  Electric power plants were estimated to be responsible for 68% of sulfur dioxide emissions.   Some of the reduction strategies for sulfur dioxide include conservation, energy efficiency improvements, coal plant limestone injection or wet scrubber systems, coal cleaning methodologies, coal gasification, and fuel switching from high sulfur coal to low sulfur coal.  Many studies indicate that the most cost effective of these are conservation or energy efficiency improvements.  Studies such as (14.7)

indicate that 50% reductions in SO2 could be accomplished at no net cost through cost effective conservation or energy efficiency improvements while also similarly reducing emissions of nitrogen oxides, carbon dioxide, and toxic metals.   RMI(14.7) and other energy consulting firms have staff constantly updating lists of the latest cost effective energy efficiency improvement options for buildings and industrial processes.  The U.S. Dept. of Energy also has research programs and funds programs in most states to advise agencies and companies on energy efficiency improvement options.

     The options chosen by consumers to provide an energy service make a large difference in emissions that is not included in price of an appliance. For example, use of a natural gas water heater that was 90% efficient as opposed to using an electric water heater using electricity from a gas power plant, that had a net efficiency of 30% due to power plant and transmission losses, would result in 1/3 as much emissions of carbon dioxide, nitrogen oxide, sulfur oxide, etc.

If the comparison was between a solar water heater and an electric water heater using electricity from a coal plant, the emissions difference and environmental cost difference would be even larger. Cost data such as that in Table 2 of the appendix can be used to assess the environmental cost difference of such options.


     Mechanical coal cleaning technologies can remove considerable amounts of sulfur from some types of coal for less than $100 per ton of SO2 removed.   More expensive chemical coal cleaning technologies for removing pollutants such as sulfur and toxic metals are also available.   Electric power plant fuel switching or scrubbers usually cost from $300 to $500 per ton of SO2 removed, but cost can vary widely depending on transportation distance and other factors.  Scrubber or limestone injection power plant  systems also generate large volumes of waste containing toxic metals and other toxics.


     Florida utilities are responsible for approx. 32% of Fla. nitrogen oxide emissions(12). The most effective NOx control for cyclone type coal boilers appears to be selective catalytic reduction(SCR), but the cost is high($3000 to $4000 per ton) and other operational and waste problems are created. For pulverized coal plants, low-NOx burners can be added, which reduce nitrogen oxide emissions by operating at lower temperatures.  The cost of low-NOx burners range between $5/KW to $15/KW, depending on several factors including whether an overfire air system is also installed.  Conventional low-NOx burners without OFA reduce NOx emissions 20 to 40%.  Nalco Fuel Tech's NOx OUT process costs approx. $15/KW installed and can remove 55 to 70% of NOx.  Babcock & Wilcox Low-NOx Cell plugs into existing standard cell burners and cost $8 to $12/KW installed, with reductions of NOx emissions of approx. 55%. Some plants, such as fluidized bed plants, when burning at lower temperatures have been found to produce much larger amounts of nitrous oxide however, which is both a greenhouse gas and ozone layer



    The cost of installing a wet scrubber to remove SO2 at a recent existing coal plant site was approx. $300 per kilowatt(46). Scrubbers for new coal plant can run as low as $150 per KW, but can vary considerably depending on the site, technology chosen, and other parameters.  Energy Biosystems Corp. of Houston, Texas has a desulfurization process using microorganisms that appears to offer lower cost sulfur removal than current methods with little loss in fuel heat content(46).

     Natural gas cofiring technologies are available that reduce emissions considerably at existing coal plants or incinerators, while also improving efficiency in some applications(11.5). Gas cofiring (20% gas) at cyclone coal plants has been demonstrated to reduce nitrogen oxide emissions    50 to 60 percent. Gas cofiring (11%) at a tangentially fired coal plant reduced sulfur dioxide emissions 18.5%.  Gas cofiring at a mass burn incinerator at the 12 to 15 percent level reduced nitrogen oxide emissions by 60%, carbon monoxide emissions by 35%, and improved boiler efficiency by 2.5%(11.5).


     Combined cycle gas plants, which are the cleanest and most efficient fossil fuel power plants, also appear to be the cheapest to operate when total cost is taken into account (see Table 4). Coal gasification appears to be the coal burning technology that is currently the cleanest and cheapest for new facilities when total cost is considered, though coal cleaning technologies may be cost effective in some circumstances and technology is rapidly changing.   Wind and solar thermal power plants appear to be approaching the cost of coal plants for use in some areas when total cost is taken into account.



(1) International Panel on Climate Change,  IPCC 2001 report  'Climate Change 2001: The Scientific Basis'

 (2)  Neurological effects of toxic metals, Annotated Bibliog.,

(3) The Atlanta Constitution, "CDC: Lead levels still poisoning kids"    Charles Sebrook, July 17,1990; &    The Orlando Sentinel, "Lot of Lead Found in Drinking Water",   4‑28‑89 ; &  NRDC Newsline, "Why Johnny Can't Read", April 1991.                    

(4) S. Bernow et al, "Full Cost Economic Dispatch: Recognizing Environmental        Externalities", in (21).                         

(5) D.L. Block, Florida Solar Energy Center, "Environmental and Societal Costs      of Electricty", Oct 1990.                        

(6) Boyce Thompson Institute for Plant Research, Cornell Univ.,1986,

(7) J.F. Gleason et al, N.A.S.A., "Record Low Global Ozone in 1992",Science,        April 23, 1993 and Science News,  April 24, 1993   &     "NASA identifies cause of ozone depletion", Science News, Vol 146, p422:  &  Annotated bibliography,

(7.3) Kerr et al, Science, Vol 262, 1993, p1022  &      T. Eck et al, Geophysical Research Letters, Feb/Mar 1995  &      National Aeronautics and Space Administration & National Oceanic and       Atmospheric Administration, in Florida Times Union, page B1, 12-27-92.

(7.5) U.S. EPA, in Science News, 1988; & Ultraviolet Radiation, Ohio State Univ. Fact Sheet,; & United Nations Environmental Program, Environmental effects of ozone depletion:1998 Assessment November 1998


 (8) Electric Power Research Institute, "Atmospheric Pollutant Effect on Crops", Electric Light and Power, Jan 1989,p22.    &

(8.5) Electric Power Research Institute, "Mercury in the Environment"

     EPRI Journal, April/May 1990; &   Electric Power Research Institute, EPRI Journal, April/May 1993, p44-47.

(9) Agency for Toxic Substances and Disease Registry, U.S. Public Health   Service, Toxicological Profile for Mercury , 1999; & Jan 2003 Media Advisory, New MRLs for toxic substances, MRL:elemental mercury vapor/inhalation/chronic & MRL:   methyl mercury/ oral/acute; &

(9.5) ATSDR/EPA Priority List for 2005: Top 20 Hazardous Substances, Agency for Toxic Substances and Disease         Registry, U.S. Department of Health and Human Services,     

(9.7) H.R. Casdorph, Toxic Metal Syndrome, Avery Publishing Group, 1995 & S.E.      Levick, Yale Univ. School of Medicine, New England Journal of Medicine,         July 17, 1980  &  C.N. Martyn et al, "Geographical relation between             Alzheimer's disease and aluminum in drinking water", The Lancet, Jan 14,1989.

(10) Florida Electric Power Coordinating Group, Florida Acid Deposition Study,

     Final Report, March 1986; &  Florida Acid Rain Deposition Study, Phase III.          

(11) J.Delfino, Univ. of Florida Dept. of Environmental Engineering, study         summarized in:  Florida Environments, August, 1992.

(11.5) Gas Research Institute,1992 R&D Program Plan,June 1991(FERC RP91-170)  

(12) Olav H. Hohmeyer, Commission of European Communities,  "Macroeconomic View       of Energy Resources" in Sunworld,volume 13,  number 13, 1989.          

13) H.M. Hubbard, "The Real Cost of Energy", Scientific American,  April 1991. 

(14) Jonathan Koomey, Lawrence Berkeley Laboratory, Energy Analysis Program,        "Comparative Analyis of Monetary Estimates of External Environmental Costs       Associated with Combustion of Fossil Fuels,  July 1990.         

(14.5) S.E. Lindberg, "Emission and Depostion of Atmospheric Mercury Vapor", in        Lead,Mercury,Cadmium, and Arsenic in the Environment , John Wiley & Sons,         Ltd, NY,1987.

(14.7) Amory Lovins,"Abating Acid Precipitation at Negative Cost",  Rocky             Mountain Institute,

(15) J. MacKenzie and M. El Ashry, "Ill Winds: Airborne Pollutions' Toll on Trees and Crops", World Resources Institute, Washington, D.C. 1988. (summary article in Technology Review, April 1989)

(16) H.L. Magaziner, American Institute of Architects, testimony in (22.4).

(17) Materials Damage Assessment, joint study by EPA, Brookhaven  National           Laboratory, and the U.S. Army Corps of Engineers,1986.

(18) J. Matthews, "Smog‑Control Study Targets Medical Costs", Washington Post,       July 11, 1989.                               

(19) S.B. McLaughlin(1981), "Relative Humidity: Important Modifier of   Pollutant Uptake in Plants", Science, Vol 211, 9 Jan 1981.      

(19.5) The Miami Herald, "Lifetime Skin Cancer Risk Projected to Hit 1 in 75",  June 3,1991.

(20) T.R. Miller et al, The Urban Institute, Global Climate Change: A Challenge to Urban Infrastructure Planners, 1989.              

(21) National Association of Regulatory Utility Commissioners, Proceedings of the      National Conference on Environmental Externalities, Jackson Hole, Wyoming,       Oct 1‑3, 1990.           

(21.5) National Network to Prevent Birth Defects, "Medical and Environmental           Studies on Nitrates, Nitrites, and Nitroso-Compounds", Aug 1,1987.

(22) American Lung Association, 1988, in New York Times, June 10, 1988                           (23) Energy Information Administration(EIA), U.S. Dept. of Energy, International Energy Outlook, 2005. 

(24) The National Commission on Energy Policy, A Bipartisan Strategy to Meet Americas Energy Challenges, Dec 2004

  (25) R. Dennis(NOAA) & Bill Matuszeski(U.S.EPA), EPA Chesapeake Bay Projuect,      in: Clean Air Compliance Review, Aug 12, 1996.     &  M. Oppenheimer et al,      Polluted Coastal Waters: The Role of Acid Rain , Environmental Defense Fund,     April 1988.

(26) Pace University Center for Environmental legal Studies, Environmental Costs       of Electricity, for U.S. Dept of Energy,  Sept. 1990.               

(26.3) J. Oerlemans, "Quantifying Global Warming from the Retreat of Glaciers",       Science, April 8, 1994;   &  Derek Denniston, World Watch(magazine), "Icy       Indicators of Global Warming",  Jan/Feb 1993     &  Science News, Vol 141,       page 148.

(26.4) R.L. Peters et al(ed.), Global Warming and Biological Diversity  , Yale

      University Press, 1992   & Worldwatch Institute, Conserving Mountain  

      Ecosystems, February 1995.

(26.5) M.S. Pelto,"The Annual Balance of North Cascade Glaciers", Journal of           Glaciology", N117, 1991.

(26.7) Nicholas Lenssen, World Watch(magazine), Mar/Apr 1993.

(27) E. Peterson, U.S. Dept. of Energy, " A Least Cost Strategy for Carbon           Dioxide Reductions", in (21)                             

(27.3) Power magazine, "AFBC Update", March 1991.                    

(27.5) Proceedings,International Conference on Mercury as an Environmental             Pollutant, Gavle, Sweden, June 11‑13,1990.      

(28) S.N. Putta, New York Dept. of Public Service," Weighing Externalities in       New York State", The Electricity Journal,  July 1990.                   

(28.5) J.Raloff, "Mercurial Risks from Acids' Reign", Science News, March 9,1991.

(29) R.L. Salmon, Systems Analysis of the Effects of Air Pollution on Materials,           Midwest Research Institute,1970.(also see 31)    

(30) Dr. R.L. San Martin, Deputy Assistant Secretary, U.S. Dept. of Energy,           Environmental Emissions from Energy Technology Systems,

      Wash. D.C., April 1989.  

(30.1) World Watch Magazine, May 1993.                                      

(30.3) T.P. Barnett, Scripps Institution of Oceanography, in Science News,

       Jan 23,1993.

(30.5) Government Climate Change Research Plan Provides Guiding Vision  And Should Be Implemented, But Needs Additional Funding,  National Academy of Sciences,, Feb 18, 2004,

&  Leading Climate Scientists Advise White House on Global Warming,  National Academy of Sciences,,   June 2001,

& The Evidence for Warming, National Academy of Sciences,

(30.7) William Cline, Long Term Economic Effects of Global Warming, Institute        for International Economics, 1992.

(30.9) N. Rader & J. Hamrin,"The Role of Renewable Energy in Global Warming      Mitigation- A Critique of Trusted Assessments", The Electricity Journal, July 1992

(31) S.R. Scholle, "Acid Deposition and the Materials Damage Question"

       Environment, Vol 25, No.8, 1983, P25‑32.                      

(31.2) Science News, Volume 139; & Science News, Volume 141,page 4;  & World    Meteorological Organization, United Nations, in Tallahassee Democrat, 5-2-96,p8A.  (31.4) J.Herman, NASA Goddard Space Flight Center, "Ozone Depletion at Northern      and Southern Latitudes- 1979 to 1991", Journal of Geophysical Research,         Volume 98, 1993, p12738   & J.of Geophysical R., Vol 99, 1994, p3483  &         Science News, April 13,1991    &  Science News, Vol 139    & Science News,      Volume 138, p198 and p228,  &     Science, Volume 252, p204.

(31.5) Science News, December 19, 1992  & December 26, 1992.

(31.6) Tallahassee Democrat, August 17,1990.

(31.8) Intergovernmental Panel on climate Change, Science News, vol 141,page 232

       & Science News, vol141,page 343.

(31.9) Science News, Vol 142, page 37.

(32) Solar Today, Nov/Dec 1989.       

(32.3)T.M. Smith et al, Univ. of Virginia, Nature, Feb 11, 1993.

(32.5) Science News, Vol 142,page 282.                              

(32.7)W.C. Oechel et al, San Diego State Univ., Science News, Feb 13,1993    &

      S.A. Zimov, Journal of Geophysical Research, March 20, 1993(& S.N.,4-24-93)

(33) Roger Sweets, paper presented at Dept. of Environmental Regulation

       Acid Rain Symposium, Oct 1990.                                

(33.5) W.A. Gabbard, Oak Ridge National Laboratory, in Tallahassee Democrat,        October 10, 1994.

(34) The Tampa Tribune, "The Poison From Our Skies: Mercury Taints Rivers,            Streams:, 7‑3‑89.                                     

(35) U.S. Congress, Office of Technology Assessment, Acid Rain and Transported       Air Pollutants: Implications for Public Policy,  OTA‑O‑204, June 1984.     (35.3) "Satellite Detects Global Sea Rise", Science News, Vol 146, 12-10-94,p388.

(35.5) U.S. EPA, Policy Options for Stabilizing Global Climate,  Dec 1990.

(35.7) "Cloudy Effects of Ozone Loss", Science News, Dec 24, 1994, p427.

(36) U.S. EPA, Regulatory Impact Analysis on the National Ambient Air Quality       Standards for Sulfur Oxides, March 1988.  &          

     U.S. EPA, Regulatory Impact Analysis on the National Ambient

       Air Quality Standards for Particulate Matter, 1988.          

(36.2) U.S. Water News, July, 1987.

(36.5) Forrest Ware, Game & Freshwater Fish Commission, "Results of Tests for          Mercury in Florida Bass", 1990.

(37) Mercury levels in Florida and Gulf Coast Fish, annotated bibliography,

(38) Dr. J.W. Winchester, "Regional Anomalies in Chronic Pulmonary Disease;          Comparison with Acid Air Pollution Particulate Characteristics", Archives       of Environmental Contamination and Toxicology, bol 18,p291‑306(1989).  

(39) Dr. John Winchester,  " The Role of Acid Rain in Atmospheric

       Deposition", FSU Dept. of Oceanography,  Dec 31,1990.

(40) Dr. John Winchester, FSU Dept. of Oceanography, in  J.M. Pacyna

       and B. Ottar(editors), Control and Fate of Atmospheric Trace Metals,

       Kluwer Academic Publishers, 1989, p311‑320.          

(41)  "Health and Environmental Impacts of Air Pollution:

       The Situation in Florida and the Southeast", Dec 1991.        

(42)  "Environmental and Health Effects of Toxic Metals & the

     Relationship to Acid Pollutants and Incineration", 1998(annotated bibliog.)

(43)  "Health Effects of Dioxin and endocrine disrupting chemicals", 5-3-03 (annotated bibliography); & RACHEL'S ENVIRONMENT & HEALTH WEEKLY #457 ---August 31, 1995---

(43.5) "Economic Cost of Incineration in Florida", 9-1-99.

(44) World Watch Magazine, May 1993

(44.2)Nature, 529, April 5,1990.

(44.4) U.S.EPA, Intergovernmental Panel on Climate Change, Working Group 2,

      Potential Impact of Climate Change, June 1990.

(44.6) "Radioactivity from Burning Coal", Science News, Vol 146, Oct 8, 1994.

      & W.A. Gabbard, Oak Ridge National Laboratory Review, Fall, 1994.

(45) D.J.Frederic, National Geographic Special, in St Petersburg Times, 7-27-93.

(45.2) Paul Mayewski, Chief Scientist, U.S. Greenland Ice Core Project, in(45)

(45.4) E.S. Sattzman, Univ. of Miami, Vostoc Antarctica Ice Core Project;  &

       P. Grootes, Univ. of Washington, in (45).

(45.6) L.T. Thompson, Byrd Polar Research Center, U.S.-Tibetan Plateu Ice Core          Project, in (45).

(46) Compliance Strategies Review, July 5, 1993.

(46.5) Bonneville Power Administration, Estimating Cost and Benefits for Five

    Generating Resources: Final Report, March, 1986.

(47) William Marcus, New Perspectives on Cost of Control Versus Damage Estimates     as a Proxy for Externality Valuation JBS Energy, Sacramento,Calif. Sept 1992

(47.5) National Renewable Energy Laboratory, Issues and Methods in Incorporating      Environmental Externalities into the Integrated Resource Planning Process,     U.S. Dept. of Energy , November, 1994.

(48) Order No. 89-507 "In the Matter of Investigation into Least Cost Planning     for Resource Acquisitions by Energy Utilities", Oregon DOE/PUC, April 20, 1989.

(48.2) Docket No. 89-752, "In Regard to Rule Making Regarding Resource Planning",

    Nevada Public Service Commission, Nov 19, 1990.

(48.4) DPU 89-239,  Dept. of Public Utilities, Commonwealth of Massachussetts,

   "Investigation by the Dept. of Public Utilities on its own motion into           proposed rules to implement integrated resource management practices for        electric companies in th Commonwealth".

(48.6) Vermont VGS, Docket No. 5330, Application of 24 Electric Utilities for a

    Certificate of Public Good Authorizing Execution and Performance of a Firm      Power and Energy Contract with Hydro Quebec"

(49)D,Slater, J.Schwarz, et al,  U.S.EPA & Univ. of Washington Dept. of            Environmental Health, "Particulate Air Pollution and Hospital Emergency Room     Visits for Asthma in Seattle", American Review of Respiratory Disease, Vol      147,  1993m p826-831.

(49.2) A.Pope, D. Dockery et al, Harvard School of Public Health, "Mortality       Risks of Air Pollution: A Prospective Cohort Study", International Conference     of The American Lung Association, April, 1993.

 (49.4) J. Schwarz(EPA) & D. Dockery, "Increased Mortality in Philadelphia         Associated with Daily Air Pollution Concentrations", American Review of          Respiratory Disease, March, 1993.

(49.6) D.Abbey, Scientific American, Oct 1993, p38   &  R. Detels, U.C.L.A.,

                Scientific American, Oct 1993, p38.

(49.8) South Coast Air Quality Management District, 1989, & in(49.6).

(50) U.S. EPA, Waste from the Combustion of Coal Power Plants, Report to             Congress, Feb, 1988.

(50.2) U.S. EPA, Municipal Waste Combustion Study, Report to Congress, EPA/530-

       5w-87-021a, June 1987; & RACHEL'S HAZARDOUS WASTE  News  #403,  1994,

(50.4) Congressional Office of Technology Assessment, Facing America's Trash,

       OTA-00424, U.S. Government Printing Office, Oct 1989.

(50.6) Radian Corporation/ U.S. EPA, Assessment of Health Risks Associated with         Municipal Waste Combustion Emissions, EPA/530-SW-87-02, 1989.

(50.8) Journal of Chromatography, Vol 389, 1987, pp127-137 & Dr. Barry Commoner,

    in Remote Access Chemical Hazards Electronic Library(RACHEL), Hazardous Waste

    News, No. 45, Oct 5, 1987  &   Science, Vol 237, Aug 14,1987, pp754-756.

(51) Wall Street Journal, Oct 13, 1987.

(51.2) The Sentinel, Rome N.Y., July 1986.

(51.4) U.S. EPA, Region III, Environmental News, Oct 31, 1984.

(51.6) Waste Age, Feb 1981, p66-68.

(51.8)U.S. Bureau of Mines, Bulletin 683,Resource Recovery from Municipal Waste.

(52) Environmental Pollution(Series A) 38, pp339-360, 1985.

(53) Environmental Health Perspectives, 59,pp159-162, 1985.

(54) RACHEL, Hazardous Waste News, No. 22, April 27,1987.

(55) City of Chicago official, in New York Times, 11-17-92.

(56) Florida Public Service Commission, Statistics of the Florida Electric

     Utility Industry, 1991.

(57) Tom Atkeson, Florida Dept. of Environmental Protection, in "Warning Issued

     on High Mercury Levels in Sea Trout", Tallahassee Democrat, 9-12-93.

(58) Science, Feb 7, 1992, p683.

(59) Science, Vol 268, May 12, 1995, p802.

(60) Science, Vol 268, June 16, 1995, p1567.

(61) Science, Vol 268, June 16, 1995, p1576.

(62) A.H. Lachenbruch & B.V. Marshall, Science Vol 234, 1986, p689.

(63) Science, Vol 269, July 21, 1995, p359.

(64) T.R. Karl et al, National Climatic Data Center, in Aerosol Forcing of Climate, R.J. Charlson(Ed.), John Wiley & Sons, 1995, p363-382.

(65) researchers at Max Planck Institute, Journal of Climate, 1995. &(60)

(66) B. Santer et al, Lawrence Livermore National Laboratory, Climate Dynamics,       1995.

(67) Fetal Deaths Climb with Air Pollution, Science News, vol 153, May 16,1998,       P309;   & L.Periera, Environmental Health Perspectives, June 1998;

     & R.A. Levinson, EX. Dir., Amer. Public Health Assoc., Wash. D.C.,1998.


(68) WHO, World Health Organization, Feb 1999; & News on Earth, Mar 1999.

(69) (a) Emanuel, K. A., 2005: Increasing destructiveness of tropical cyclones over the past 30 years. Nature, 436, 686-688; & Emanuel, K., S. Ravela, E. Vivant and C. Risi. 2006: A Statistical-Deterministic Approach to Hurricane Risk Assessment. Bull. Amer. Meteor. Soc., 87, 299–314; & (b)Changes in Tropical Cyclone Number, Duration, and Intensity in a Warming Environment, P. J. Webster,1 G. J. Holland,2 J. A. Curry,1 H.-R. Chang1 .   Science 16 September 2005: Vol. 309. no. 5742, pp. 1844 – 1846,  & (c) J.  Curry et al, Georgia Institute of Technology, Warming Oceans are the Main Factor in Stronger Hurricanes, Science, Mar 17, 2006. (d) NOAA  Geophysical Fluid Dynamics Laboratory, Global Warming and Hurricanes,

(70) Arden Pope et al, BYU, Air pollution can cause heart conditions, Circulation: Journal of the American Heart Association, rapid access issue, Dec 2003.

(71) Economic benefits of compliance outpace costs,   Office of Budget and Management, 2004

(72) (a) Adverse pregnancy outcomes around incinerators and crematoriums in Cumbria, north west England, 1956–93 ; T J B Dummer, H O Dickinson, L Parker; J Epidemiol Community Health 2003;57:456-461; & (b) Sarcoma risk and dioxin emissions from incinerators and industrial plants: a population-based case-control study (Italy),  P. Zambon et al, Environmental Health 2007, 6:19,; & (c ) Risk of soft tissue sarcomas and residence in the neighbourhood of an incinerator of industrial wastes, P. Comba et al, Occup Environ Med 2003;60:680-683;  & (d) Birth Sex Ratio and Dioxin exposure, P. Mocarelli et al, The Lancet, May, 2000; (e) & Agency for Toxic Substances and Disease Registry, U.S. DOH, 1994,; & (f) Incinerator and Spatial Exposure Distribution: An Example of Small Area Study in Italy, A Ranzi et al, Epidemiology: November 2006 - Volume 17 - Issue 6 - pp S114-S115





                          TABLE 1

    Summary of Range of Environmental and Health Damage Cost

          Estimates from Reviewed Studies(see text)‑

    and a proration of costs to Florida utilities


Type Damage       United States    Florida        Cost for average

  Cost              Total           Total        Florida coal plant

                   (billions)     (billions)       (cents/kwh)

___________       ____________    __________     __________________


Greenhouse Effect $18 to $140     $0.9 to $7.2     0.3 to 2.4


Toxic Metals **    10 to 60        0.5 to 3.0      0.15 to 0.80


Materials Damage   10 to 35        0.5 to 1.7      0.25 to 0.8


Crop Damage         5 to 6.5       0.25 to 0.3     0.12 to 0.14


Sulfur Dioxide **  52 to 122       2.5 to 6.1       1.25 to 3.1


   airline delays     12


   productivity    30 to 100

  lakes/recreation    10

Nitrogen Oxide **  25 to 55        1.25 to 3.3       0.6 to 1.6

  health/work loss 10 to 40


   eutrophication      5

  lakes/rivers/rec     5

  ozone layer damage/

   nitrous oxide(N2O)  5


Particulates/Health 5.6 to 48       0.3 to 2.4        0.15 to 1.2


Land/water impacts    14               0.7              0.37


Health/Radioactive     5               0.25             0.12



Volatile Organics   0 to 44           0 to 2.2          0 to 1.1


  Total           145 to 530         7 to 28         3.3 to 11.5


* utilities are assumed to be responsible for 50% of the total

  state damage cost from acidic emissions, since utilties

  contribute approx. 50 % of combined sulfur dioxide and nitrogen

  oxide emissions.  utilities are assumed to be responsible for 30%

  of toxic metal emissions and 33% of greenhouse gas emissions.

      Cost were allocated to Fla. proportional to population and

  Fla. cost estimates were spread across the 97,654 giga watt hours

  of fossil fuel generation in Fla. in 1988(the inclusion of GWH

  from cleaner gas and oil plants in the denominator tends to make

  this a conservative estimate for coal plants; however the

  assumption of zero net interstate transport and other assumptions

  probably counterbalance this).

** Cost estimates for health effects cannot be accurately separated

  between toxic metals, acid pollutants, and particulates due to

  coexistance and synergistic interactions. Some of the effects

  some attribute to acid pollutants are due to interactive effects

  with ozone formed by chemical interactions with acid pollutants,

  along with toxic metals and particulates.
































                                 TABLE 2


    Range of Estimated Environmental/Health Costs for a Coal Power Plant

         by Type of Pollutant in Recent Studies Reviewed in (14)*


          Carbon Dioxide  Sulfur Dioxide  Nitrogen Oxide  Particulates   VOCs



cents/kwh   .40 to 3.8    .27 to 1.6        .6 to 7.2     .14 to 3.7   1.0 to 4.9


converted      $4 to          $300 to           $69 to      $167 to     $1180 to

to $/ton**       $40            $1726            $7526        $4400        $5900


EPRI(1987)                     $420 to          $40 to

 rural Penn.                     $1700            $460

 in (14)


EPRI(1987)                     $960 to           $40 to

suburban N.Y.                    $4620             $460

 in (14)


EPA(36)                        $490 to          $2400 to

                                  $728             $9900


Holmeyer(12)                    $466 to          $584 to        $566 to

                                  $2488            $3120          $2488


Chernick et al   $84            $1840              $3160         $5260

    in (14)


New York P.S.C.   $4             $960              $1880         $2020

    in (28)

California PUC                  $1726              $7526         $1306     $1306

 $/ton, from(47)                                                 (PM10)

Massachussetts DPU  $24         $1700              $7200         $4400    $5900

  (1992 $/ton)                                                   (TSP)

Minnesota PUC     $6 to            $0                $69        $167 to    $1190     (1994)        $13.60       to $300           to $1640    (PM10)$2380


Nevada PSC          $22         $1560              $6800         $4180     $1180

   (1990)                                                        (PM10)

Oregon PUC       $10 to                         $2000 to       $2000 to   

  (1990)            $40                            $5000     (TSP)$4000


Bonneville                      $1500             $69 to        $167 to          Power Admin.                                       $884    (TSP) $1540


* summary of the most quoted recent studies estimating environmental/

  health costs of the major air pollutants, including those used

  officially by the states of New York, California, and Wisconsin

** assumes:  964 metric tons of CO2 emissions per GWH of electricity

             8.40 tons of sulfur dioxide emissions per GWH

             2.66 tons of nitrogen oxide emissions per GWH



                          Table 4


             Variable Costs of Operating Fossil Fuel Plants

                                    (cents per kwh)

                          Capital   Variable    Emissions  Full Societal

                         Expense  Production               Operating  Cost

                                 *      Costs       Value        Related   with

                                                          Cost     Capital


Coal w/o scrubber,1% sulfur  2.3       2.5    4.3      9.1

Coal with scrubber                3.9      2.7      3.4     10.0

Fluidized Bed(AFBC) coal     4.6      2.7     2.6       9.9

Coal Gasification(IGCC)      4.6      3.1       3.6      11.5

#6 oil, 1% sulfur                    3.1    6.4       3.4       12.9

#6 oil, 0.5% sulfur                  3.1   6.8       2.9       12.8

Gas combustion turbine(CT)   4.9   8.4      1.6       14.9

Gas combined cycle(CC)       3.3     5.5     1.6       10.4   

Solar Thermal **            11.0**   1.4        0.4          12.8

Solar Photovoltaic          15.0     1.2        0.4          16.6



* first year capital expense based on estimates and common assumptions

  used for Investor Owned Utilites including return on investment and

  depreciation expense with recently observed capital cost estimates.

  capital cost can vary considerably depending on local circumstances

  and choices.


** the capital cost of a combination solar thermal plant with natural

  gas backup might be reduced since it would be spread across

  more kwh.







                                               TABLE 3


              Societal Externality Cost for Electric Generation Alternatives


           Waste    Coal Plant   Coal Plant  AFBC    IGCC   #6 Oil   #2 Oil     Gas  

              to           w/o         with     Coal    Coal     1%S    0.5% s               CC

           Energy    Scrubber     Scrubber   Plant      to       sulfur     

            Plant     1% sulfur                                    Gas



Sulfur dioxide    1.80    1.10      0.55       0.48      1.08      0.54       0.16    0.01     -

   (1) (2)


Nitrogen oxide    0.61   0.58      0.30    0.10        0.29       0.36    0.50      0.42      -

    (1) (2)


Particulates        0.15    0.03      0.03    0.01       0.09       0.06    0.04      0.01      -



Carbon Dioxide             2.09        2.09      2.09    1.65   1.69     1.69    1.61  1.10    -

  (1)  (3)


Land/Water                 0.37        0.37        0.37    0.27   0.27     0.27    0.17  0.24    -



Radioactive                0.10        0.10      0.10       0.05      0        0           0     0         -



TOTAL                      5.12        4.27      3.44    2.56    3.42     2.92    2.48   1.78         -

($/ MMBTU)


Heat Rate        10,000   10,000  10,000  10,000 10,400  10,400  13,600    7200



TotalCost(c/kwh) 5.1 4.3 3.4 2.6 3.6 3.4 3.3 1.3  

(cents per       (1)                                                                           (1)




(1) source is (26)‑Pace Univ. study


(2) the cost estimates for sulfur and nitrogen oxides are assumed to include health/

    work productivity impacts, interactions with toxic metal emissions and ozone,

    crop and forest damage, materials damage, lake/fish/recreation impacts of acid

    pollutants and toxic metals, and eutrophication impacts of nitrogen oxide


(3) the estimate of carbon dioxide impacts is assumed to include greenhouse effects

    and ozone layer damage from nitrous oxide and other greenhouse gas emissions


(4) cost estimates used in policy decisions by New York Public Service Commission