First, Frum ignored the externalities associated with burning coal for electricity, and if merely considering the price paid for electricity, he also ignored the fact that renewable energy will become competitive with energy derived from coal and other fossil-fuel sources (but if considering externalities associated with burning coal—a dirty energy source—renewable energy is much much cheaper than coal). Furthermore, coal, like other fossil fuels, is subsidized (i.e., governments and society pick up the tab for the environmental and health consequences associated with burning coal). To illustrate the externalities associated with burning coal, I recently investigated whether coal can be clean:
When coal is burned, dozens of hazardous or toxic substances52 in addition to “trapped” carbon dioxide53—a greenhouse gas pollutant—are released.54 Consequently, some of these substances released through coal combustion, such as mercury, disseminate by means of deposition throughout the landscape and into aquatic environments.55 The hazardous substances not released directly into the atmosphere are present in combustion wastes such as fly ash.56 The coal combustion wastes released into the atmosphere are a public health hazard, and the corresponding healthcare costs are passed off to the consumer and government entities. In fact, states are seeking to abate combustion from some coal-fired power plants over economic, environmental, and public health concerns.57 Although the negative health impacts of burning coal may be not be readily recognized, healthcare costs have been estimated to be in the billions.58 For example, “the National Research Council has estimated the external costs associated with emissions of nitrogen oxides, sulfur dioxide, and PM from coal-fired power plants in the U.S. at $62 billion in 2005.”59 Another study released in 2010 found that “filthy air in California cost federal, state and private health insurers $193 million in hospital costs.”60 That same study determined that “Medicare and MediCal, California’s Medicaid program, paid for more than two-thirds of the costs, while private insurers paid the rest.”61 Granted, coal-fired power plants are not the sole contributor of air pollution, but they are a significant producer of air pollution.62 In fact, coal-fired power plants are significant contributors of carbon dioxide, mercury emissions, nitrogen oxide emissions, ozone pollution or smog, and particulate matter pollution.63 Furthermore, an EPA study found that “coal plants were found to release 67 different air toxics, many of which are known or probable human carcinogens and neurotoxins that can harm brain development and irritate the respiratory system.”64
Mercury, in particular, negatively impacts the health of ecosystems and the health of humans. The EPA has estimated “that about one third of U.S. [anthropogenic mercury] emissions are deposited within the contiguous U.S. and the remainder enters the global cycle.”65 Mercury emissions are problematic, because there is a connection between blood mercury levels and intellectual performance, and the costs to society over “lifelong diminution in intelligence” has been estimated to be $8.7 billion per year.66 As a result, mercury is recognized as posing a public health threat,67 since mercury is a neurotoxin.68 The most dangerous form of mercury is the organic form of mercury or methylmercury,69 which is produced by microbial activity in aquatic environments.70 Methylmercury is the most dangerous form of mercury, because it is easily absorbed by the human body.71 Furthermore, methylmercury is a bioaccumulative environmental toxicant,72 and as a result, undergoes biomagnification within food chains.73 As a result, seafood consumption is directly related to methylmercury intake by humans.74 In fact, the Food and Drug Administration (FDA) and the EPA advise “women who may become pregnant, pregnant women, nursing mothers, and young children to avoid some types of fish and eat fish and shellfish that are lower in mercury.”75 Despite warnings, according to the EPA, “it is estimated that more than 300,000 newborns each year may have increased risk of learning disabilities associated with in utero exposure to methylmercury.”76
. . .
52Alan H. Lockwood et al., Coal’s Assault on Human Health, (2009), available at http://www.psr.org/assets/pdfs/psr-coal-fullreport.pdf (Discussing that “coal combustion releases sulfur dioxide, particulate matter (Pm), nitrogen oxides, mercury, and dozens of other substances known to be hazardous to human health.”).
53The problem is that the burning fossil fuels, such as coal, results in a release of carbon dioxide that has been trapped for millions of years. As a result, burning coal contributes an increase in concentrations of atmospheric carbon dioxide over time. This additional carbon dioxide is problematic due to carbon dioxide’s warming effect. For this reason, carbon dioxide is a greenhouse gas. See The Carbon Dioxide Greenhouse Effect, http://www.aip.org/history/climate/co2.htm (last visited February 17, 2010).
54See American Institute of Physics, The Carbon Dioxide Greenhouse Effect, http://www.aip.org/history/climate/co2.htm (last visited March 1, 2010).
55See U.S. Envtl Prot. Agency, Environmental Effects of Mercury, http://www.epa.gov/hg/eco.htm (last visited February 27, 2010).
56See Tim Lucas, Toxic Coal Ash Threatens Health And Environment, Duke University, Aug. 18, 2009, http://news.duke.edu/2009/08/toxiccoal.html (Discussing how hazardous elements remain in fly ash and how toxic ash can leave storage ponds or spill sites by becoming “re-suspended in the air as dust [upon drying] and could have a severe health impact on local residents or workers who inhale them”).
57See North Carolina ex rel. Cooper v. Tennessee Valley Authority, 515 F.3d 344 (4th Cir. 2008) (Due to impacts to human health and environmental quality, the State of North Carolina brought a public nuisance action against Tennessee Valley Authority seeking an injunction prohibiting it from operating its plants in a harmful manner.).
58For the FY 2008, EPA estimates that its 10 largest civil enforcement actions against stationary source Clean Air Act violations of emissions of sulfur oxides, nitrogen oxides, and particulate matter resulted in annual health benefits valued at $35 billion. According to the EPA, some of these health benefits translated into thousands of avoided premature deaths, fewer emergency room visits, fewer cases of chronic and acute bronchitis, fewer nonfatal heart attacks, fewer cases of respiratory problems, and a reduction of days of people missing school or work. U.S. Environmental Protection Agency, EPA FY2008 Enforcement & Compliance Annual Results (2008), available at http://www.epa.gov/compliance/resources/reports/endofyear/eoy2008/fy2008results.pdf.
59Alan H. Lockwood et al., Coal’s Assault on Human Health 10, (2009), available at http://www.psr.org/assets/pdfs/psr-coal-fullreport.pdf.
60Kristina Shevory, Health Costs of California Air Pollution, New York Times, March 12, 2010, http://greeninc.blogs.nytimes.com/2010/03/12/health-costs-of-california-air-pollution.
61Id.
62See Physicians for Social Responsibility, Coal-Fired Power Plants: Understanding the Health Costs of a Dirty Energy Source, available at http://action.psr.org/site/DocServer/Coal_Power_Fact_Sheet.pdf?docID=2821.
63Id.
64Id.
65U.S. Envtl Prot. Agency, Human Exposure to Mercury, http://www.epa.gov/hg/exposure.htm (last visited February 27, 2010).
66Physicians for Social Responsibility, Coal’s Effects on the Nervous System 32, available at http://www.psr.org/assets/pdfs/coals-assault-chapter-5.pdf.
67See U.S. Envtl Prot. Agency, Former Mercury Mine Above Cottage Grove Reservoir Proposed for Federal Cleanup List, http://yosemite.epa.gov/opa/admpress.nsf/d0cf6618525a9efb85257359003fb69d/d76a7f9d4c5368448525763a007f0099!OpenDocument (last visited February 27, 2010).
68U.S. Envtl Prot. Agency, Human Health and Mercury, http://www.epa.gov/hg/health.htm (last visited February 27, 2010).
69See U.S. Envtl Prot. Agency, Health Effects and Mercury, http://www.epa.gov/hg/effects.htm (last visited February 27, 2010).
70U.S. Envtl Prot. Agency, Environmental Effects, http://www.epa.gov/hg/eco.htm (last visited on March 22, 2010).
71Laura Griesbauer, Methylmercury Contamination in Fish and Shellfish, http://www.csa.com/discoveryguides/mercury/review.pdf (last visited April 13, 2010).
72Wikipedia, Methylmercury, http://en.wikipedia.org/wiki/Methylmercury (last visited on March 22, 2010).
73Frances Solomon, Impacts of Metals on Aquatic Ecosystems and Human Health (2008), available at http://www.infomine.com/publications/docs/Mining.com/Apr2008c.pdf.
74See Raquel Rutledge, Mercury in sushi can hit risky levels, Milwaukee Journal Sentinel, Jan. 11, 2008, http://www.jsonline.com/news/29548599.html (“But while sushi is packed with protein and essential omega-3 fatty acids, some types are also tainted with methyl mercury, a dangerous neurotoxin that causes brain damage in babies and other problems for adults who ingest too much. . . . Tests showed the two pieces of tuna had potentially dangerous, and nearly illegal, levels of mercury. Most of the other samples, such as shrimp, salmon and mackerel, contained only trace amounts.”).
75U.S. Food and Drug Admin., Seafood, http://www.fda.gov/food/foodsafety/product-specificinformation/seafood/ (last visited on March 22, 2010).
76U.S. Envtl Prot. Agency, Human Exposure to Mercury, http://www.epa.gov/hg/exposure.htm (last visited on March 22, 2010).