Don Marsh, Editor
Fuzzy math is the latest weapon for environmental groups to whom recyclable fly ash is a pawn in the war on coal. Their latest ploy to undermine an energy resource that underpins our economy follows a trajectory from batch plant silo to power generating station via the U.S. Green Building Council’s (USGBC) LEED [Leadership in Energy and Environmental Design] rating system.
A group of federal and state environmental and law enforcement agency officials calling themselves Public Employees for Environmental Responsibility (PEER) contends that construction-grade fly ash—the most widely used coal combustion residual (CCR)—should not qualify as a recycled material for LEED rating. It conveyed that last month to the USGBC during the first of two public comment periods for a revised LEED version due in late 2012.
“LEED gives green credit for what is an ultimately brown act—putting coal ash into our homes, schools, and office buildings,” claims PEER Executive Director Jeff Ruch. The coal ash market constitutes a multi-billion dollar subsidy to coal-fired power, he adds, noting, “If coal power generators had to responsibly handle their wastes, coal would not be so much cheaper than solar and other renewable power sources.”
Announcing its LEED revision comment, PEER described coal combustion wastes as “unquestionably toxic.” In an era where payrolls and pension obligations have brought state and local governments to the brink of bankruptcy, does a group bearing the most toxic of labels—public employee—evoke any credibility?
A consensus process driving a standard like LEED separates substance from preposterous claims; on a scale of the latter, USGBC should find PEER peerless. Setting aside decades of scientific studies and concrete practice that support fly ash recycling, consider the group’s subsidy claim versus hard U.S. Department of Energy/Energy Information Administration numbers. Under a “Subsidies and Support to Electricity Production” chart in a 2007 report, the agency calculated tax breaks and other incentives in these dollars/megawatt hour terms: coal, 44 cents; solar, $24.34.
By PEER arithmetic, coal-fired power costs might be more in line with solar if fly ash recycling were removed from construction—kind of like hardwood flooring would be more common if landfill operators increased tipping fees for carpet. The LEED comment stunt coincides with other environmental groups’ rallying for a stringent Environmental Protection Agency-proposed rule covering utilities’ CCR. Widely opposed by fly ash marketing and construction materials interests, as Concrete Products has noted this past year, the rule would see landfill-bound, non-construction grade CCR listed under Resource Conservation & Recovery Act Subtitle C—a classification reserved for known hazardous wastes.
Concrete and cement interests stress the stigma factor ASTM C618 fly ash would carry under Subtitle C. The proposed “Identification and Listing of Special Wastes: Disposal of Coal Combustion Residuals From Electric Utilities” rule was subject to a public comment period through mid-November—past the midterm elections.
After leaders of an energized Republican party indicated that federal regulations would see greater House scrutiny in 2011, a coalition of the Subtitle C rule proponents challenged the annual dollar value attached to CCR recycling by the White House Office of Management and Budget (OMB), whose economic impact calculations are required for EPA rulemaking. Led by Sierra Club-affiliated Earthjustice, it claimed a figure of $1.5 billion against the OMB’s $23 billion estimate.
In the pretend world of Earthjustice and PEER, our booming economy and budget surplus-laden federal government can subsidize purported clean energy at any level necessary to sunset coal-fired power and render fly ash recycling moot.