Testimony of

 Norris McDonald

Founder and President

African American Environmentalist Association

 On the

Emissions of Four Pollutants From Power Plants Act


Maryland 4P Act


[HB 1169]

 Presented to the

 Economic Matters Committee

Maryland House of Delegates

 March 1, 2005



            Mr. Chairman and members of the committee, my name is Norris McDonald and I am the founder and president of the African American Environmentalist Association (AAEA).  AAEA, founded in 1985, is an organization dedicated to protecting the environment, enhancing human, animal and plant ecologies and promoting the efficient use of natural resources.  AAEA includes an African American point of view in environmental policy decision-making and resolves environmental racism and injustice issues through the application of practical environmental solutions.  AAEA supports the Maryland 4P Act (HB 1169) and recommends passage of the legislation.

AAEA loves the utility industry.  The electric utility industry provides an invaluable service to us twenty-four hours a day, seven days a week, 365 days a year.  If there is a power outage, they will work tirelessly to restore service.  Our computers, furnaces, refrigerators, televisions, lamps, clocks, air conditioners, heat pumps, printers, modems, and light bulbs are all powered by our magnificent electric utilities.  Along with these incredible benefits, we have to acknowledge that electric power plant pollution is among the leading sources of air pollution in Maryland.  Smog is a dangerous respiratory irritant that affects the health of tens of thousands of Marylanders every year.

 I am a chronic, acute asthmatic with specialized knowledge about the impacts of smog.  I have been intubated twice (1991 & 1996) due to respiratory failure attributable to air pollution.  My son also has asthma. Our children deserve clean air, a reduction in asthma, and increased national security through a reduction in our reliance on imported oil.  Unfortunately, Maryland is consistently in the top ten Clean Air Act nonattainment states.  Power plant emissions improvements will protect our children from these threats. Increasing the use of low-emission vehicles would also reduce Maryland's contribution to global climate change.

The power plants in Maryland affected by this legislation include:

1.      H.A. Wagner, Units 2 & 3

2.      R.P. Smith, Units 3 & 4

3.      Morgantown Generation Station, Units 1 & 2

4.      Dickerson, Units 1,2, & 3

5.      C.P. Crane, Units 1 & 2

6.      Chalk Point Generating Station, Units 1 & 2 and

7.      Brandon Shores, Units 1 & 2

H.B.1169 provides appropriate caps, deadlines, reports and alternative techniques for the affected plants to achieve emissions reductions.  The plants listed above are the largest emitters in the state and are a logical target for accelerated retrofits.  AAEA hopes that the appropriate scrubber technologies and sequestration techniques will be enthusiastically adopted by the affected utilities.  It is unfortunate that the federal Clean Air Act has stalled in achieving additional reductions in stationary air pollution.  We have harvested the low hanging fruit of utility air pollution reductions.  It appears that states will have to legislate solutions to get to the high hanging fruit of emissions reductions. 

            The legislation targets the largest stationary emitters of nitrogen oxides (NOx), sulfur dioxide (SO2) and carbon dioxide (CO2):


NOx (2001 Approx)



Brandon Shores


C.P. Crane


Chalk Point






R.P. Smith


H.A. Wagner




SO2 (2001 Approx)




Brandon Shores


C.P. Crane


Chalk Point






R.P. Smith


H.A. Wagner




Utility Mercury (2001 Approx)




Brandon Shores


Chalk Point






H.A. Wagner


Source: Versar  

 According to the U.S. EPA ‘s National Emissions Trends (NET) Inventory, power plants account for power plants account for 34 percent of total NOx emissions in Maryland.  Mobile sources account for 38 percent, “area” sources (smaller sources not otherwise captured in the other source categories) account for 21 percent and industrial sources account for 7 percent of NOx emissions in Maryland.

There are currently no programs that regulate mercury emissions for utility power plants. The legislation does not target non-utility emitters of mercury (Hg):

Non-Utility Mercury (2001 Approx)  
Medical Wastes Associates, Inc. .70 tons/year
Baltimore Resco .50 tons/year
Harford County Waste to Energy Facility .250 tons/year
Phoenix Services, Inc .125 tons/year
Medx .125 tons/year
Waste Energy Partners .075 tons/year
Mercy Hospital Center .075 tons/year
BFI Waste Systems of NA .075 tons/year
Sinai Hospital .050 tons/year
Lehigh Portland Cement .050 tons/year
Ogs Montgomery .050 tons/year
Northwest Hospital Center, Inc .050 tons/year
Montgomery County RRF .030 tons/year
Fort Detrick .025 tons/year
St. Joseph Hospital .025 tons/year
Source: Versar  

Of the top 20 mercury emitters in Maryland, coal-fired power plants account for about 30 percent of such emissions, with municipal waste combustors, medical waste incinerators and hazardous incinerators contributing the majority of mercury emissions. Maybe the legislation should be amended to include these non coal-fired power plant sources of mercury emissions. (Source: Versar)

            Power plants also emit carbon dioxide (CO2), methane (CH4), nitrous oxide (N2)), and sulfur hexafluoride (SF6). Only CO2 is covered in this legislation. The primary greenhouse gas (GHG) by volume emitted by human activity is CO2.  

CO2 Emissions from Md Power Plants

Power Plant

Million Metric Tons/year



Brandon Shores


C.P. Crane


Chalk Point






R.P. Smith


H.A. Wagner




Source: Versar


             Passing carbon reduction legislation in Maryland will reduce emissions and will provide a good example for other states in the absence significant federal action   AAEA believes that global climate change is the most important environmental issue facing the world today.

            Summer is the time of year when ozone pollution becomes an important public health and environmental concern, as it should be.  And starting this summer, policy makers throughout Maryland will be facing intense scrutiny to develop and implement a comprehensive plan that significantly reduces ground-level ozone emissions.

The U.S. Environmental Protection Agency (EPA) National Ambient Air Quality Standards (NAAQS) apply to six pollutants, known as criteria pollutants, which are:

1.      Carbon monoxide (CO),

2.      Nitrogen dioxide (NO2),

3.      Lead,

4.      Particulate matter (PM),

5.      Sulfur dioxide (SO2), and

6.      Ozone (O3)

Primary standards are supposed to protect the health of sensitive populations, such as asthmatics, children, and the elderly.  Secondary standards are supposed to protect the public welfare by preventing damage to crops, animals, vegetation and visibility.

EPA designated numerous counties in Maryland as being in “nonattainment” of EPA ozone standards.  The non-attainment classification formally took effect on June 15, 2004.  By June 2010, the counties must comply with newly tightened EPA standards.

            Ozone forms when emissions of nitrogen oxides (NOx) and volatile organic compounds (VOCs) are heated in the sun.  As the primary ingredient in smog, ozone is unhealthy.  During outdoors physical activity ozone penetrates into lung area that are more vulnerable to injury.  Ozone is particularly harmful for those with respiratory diseases as well as adults and children who are active outdoors.

            Children with asthma, especially those in the inner city, are most vulnerable.  As the EPA notes, “When ozone levels are high, more people with asthma have attacks that require a doctor’s attention or use of medication.  One reason this happens is that ozone makes people more sensitive to allergens, the most common triggers of asthma attacks.1

There are other dire effects from ozone.  The EPA also recently reminded us that,  “Breathing ozone can irritate air passages, reduce lung function, aggravate asthma, and inflame and damage the cells lining the lungs.  It also may aggravate chronic lung diseases like emphysema and bronchitis…”2

For policy makers, there is no turning back when it comes to reducing ozone pollution.  After a prolonged court fight, and much scientific study, the EPA has prevailed in being able to adopt much tougher, and healthier, ozone standards that it first sought to put in place in 1997.  The big targets for ozone pollution reduction are cars, trucks, refineries, power plants, and diesel engines.  So what can policy makers at the state level do to reduce air pollution?

The broad brush of solutions includes reducing emissions from industrial facilities, better transportation planning (to avoid traffic tie-ups and higher pollution), and gasoline vapor controls.  To be sure, this is a tall order that will increase energy costs and other business costs as well.

The EPA, however, wields a big stick when it comes to compliance.  Together with other federal government agencies it can impose significant sanctions by reducing highway funds and curtailing industrial development in an area if it does not comply with the new standards.  While the EPA is quick to point out that this has occurred very rarely in the past, today’s standards are much more rigorous than the previous ones.

Fossil fuel-based electricity is projected to account for more than 40 percent of global greenhouse gas emissions by 2020.  In the U.S., 90 percent of the carbon emissions from electricity generation come from coal-fired generation, even though this accounts for only 52 percent of the electricity produced.3

                Coal Mining in Maryland is confined to Garrett County and the western portion of Allegany County.  Maryland’s coal reserves are estimated to exceed 1 billion tons.  Approximately 490 million tons of bituminous coal is considered recoverable using conventional mining methods with today’s technology. Coal-fired power plants in Maryland consume approximately 10 million tons of bituminous coal annually.  Approximately 400,000 tons per year are burned at the AES Warrior Run facility near Cumberland.  Some of this coal is mined in Maryland, but the majority of the coal burned in Maryland originates from other states in the Appalachian Basin (Kentucky, Pennsylvania, Virginia, and West Virginia).4

            Natural gas reserves in Maryland are minimal and uneconomic to extract; therefore, natural gas is imported into the state.  Maryland receives bulk natural gas from four interstate pipelines:

1.      Transco

2.      Columbia Gas Transmission Corporation

3.      Consolidated Natural Gas Corporation, and

4.      Eastern Shore Natural Gas

Electric utilities consume about 20,000 million cubic feet (about 10%) of the total natural gas consumed in Maryland. 5 There are no petroleum reserves in Maryland; therefore all petroleum arrives in the state via pipelines, overland hauling, and barge.  About 12 million gallons of petroleum are consumed in the state each day, with about half of that amount consumed as transportation fuel.  A number of power plants in the state use petroleum products (distillate and residual fuel oil) as either a primary or backup fuel:

        As a backup fuel, oil allows power plants to continue operating when natural gas supplies are interrupted, such as cold winter days when priority is given to residential heating.  But oil is more expensive than gas and a plant’s are restricted on the number of hours that the plant can burn oil.

        Plants that burn oil as primary fuel are either small or run only during peak demand hours.  Maryland has approximately 2,500 megawatts (MW) of oil-fired (or dual-fuel) capacity, with the largest single facility being the Chalk Point plant (6 of 12 units burning oil for about 1,500 MW).

Alternative technologies, such as wind power, are also beginning to provide some contributions to electricity production.  However, so called ‘fossil fuels’ and nuclear power will continue to provide the vast majority of electrical power in Maryland.

            Inhaling ground-level ozone (smog) inflames lung tissue, decreases oxygen intake and can exacerbate or lead to asthma, bronchitis, emphysema and other respiratory problems. Our children deserve clean air, a reduction in asthma triggers, and the freedom to play outside during the summer season.  All Marylanders deserve to breathe clean air.

Although many counties meet attainment for ozone, the urban and suburban areas of Maryland are not meeting the NAAQS, thus, because ozone is recognized as a regional issue, the entire State of Maryland is treated as an ozone nonattainment area.  During the summer of 2004, air pollution monitors in Maryland registered 37 instances when smog levels exceeded EPA health standards.  In 5 of the past 6 years, Maryland’s smog levels have been among the ten worst in the country. (MaryPIRG)

In conclusion, the Emissions of Four Pollutants from Power Plants Act is designed to limit emissions of air pollutants to protect the public health and welfare.  The legislation would provide significant benefits to air quality in Maryland. We respectfully urge the committee to report favorably on the bill.

1 U.S. Environmental Protection Agency, 8-Hour Ground-level Ozone Designations, p. 3 (“What are the health effects of ozone?”), May 6, 2004, see: http://www.epa.gov/ozonedesignations.faq.htm .

2 U.S. Environmental Protection Agency, Fact Sheet: Clean Air Ozone Rules of 2004, p. 4 (“About the 8-Hour Ozone Standard,”), April 15, 2004.  The document can be found  on the EPA’s website at: www.epa.gov/ozonedesignations/finrulesfs.htm .

3 Massachusetts Institute of Technology, MIT News Office, “MIT releases study on nuclear energy’s future,” July 29, 2003, see:  http://web.mit.edu/newsoffice/nr/2003/nuclear.html .

4 Versar, Maryland Cummulative Environmental Impact Report – 12th Edition, Chapter 4 – Fuel Supply Issues, p. 89.

5 Ibid., pp. 89-90