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Nov 17 / admin

Super Advocate vs. Weak EPA on Power Plant Rule at Ecocentric

Our friends over at Ecocentric have just published a great article about Reed Super and our parts in the case for closed-cycle cooling, and the latest version of the regulation.  The article covers why closed-cycle cooling is important, and why it is actually economically feasible.

You can read the full article on Ecocentric.

Sep 20 / sbell

How Energy Drains Water Supplies – NY Times

There is more cost involved in energy production than the damage to the ecology of aquatic habitats, according to a recent New York Times article.  All along the  energy production chain water is consumed and removed from the water cycle, using around 35.1 billion cubic meters (that is 9.25 trillion gallons or about 8 cubic miles) of fresh water each year, about 4% of the available fresh water in the US.

Power plants aren’t the only part of the energy generation process that consume large amounts of water, with fuel extractors and manufacturers being major consumers as well, with both fracking and tar sand extraction processes being named as large consumers.

You can read more about the effects of energy generation on our water supply here.


Aug 23 / admin

Sierra Club’s Beyond Coal Campaign and the Coal Rush That Wasn’t

Originally posted at Ecocentric.

As a new mom, Mary Ann Hitt knows that “this fight is the single biggest thing” she can do to protect her daughter’s future.

The fight? To foil plans–conceived about a decade ago–for a new “coal rush” that would have put 150 new coal-fired power plants into operation.

“People said we were crazy to take on one of the most powerful special interests in the country,” says Mary Ann, Director of Sierra Club’s Beyond Coal Campaign. “But we decided to launch a campaign that would move the conversation out of backrooms in Washington and challenge every one of these new coal plants, doing what the Sierra Club does best — grassroots community organizing, powerful communications, and litigation.”

The campaign started as a three-person effort in 2002 and has since developed into a powerful and highly effective campaign: “A force to be reckoned with,” says Mary Ann.

To date, the campaign has played a key role in stopping the construction of 153 proposed coal plants that would have emitted roughly the same amount of carbon pollution as 36 million passenger vehicles, as well as other toxic pollutants that have been linked to birth defects, developmental problems in babies and young children, asthma and heart disease. Threats to the environment and public health are also associated with each step in the life cycle of coal, from cradle (e.g. mining) to grave (e.g. coal ash waste).

The campaign has garnered interest and praise from Michael Bloomberg (known in some circles as the Mayor of New York City). In July, Bloomberg Philanthropies, which has made climate change a key issue, committed $50 million over four years to the Beyond Coal campaign.

“The Beyond Coal Campaign has had great success in stopping more than 150 new coal-fired power plants over the past few years, and is empowering local communities to lead from the front while Congress continues to watch from the back,” says Bloomberg. “That is why I’m pleased to support the Sierra Club and its allies, and I encourage others to do the same.”

“If we are going to get serious about reducing our carbon footprint in the United States, we have to get serious about coal,” states Bloomberg. “Ending coal power production is the right thing to do, because while it may seem to be an inexpensive energy source the impact on our environment and the impact on public health [is] significant.”

Sierra Club has brought the coal rush to a halt.  But they’re not finished yet: Mary Ann explains, “Now we’re turning our efforts to making sure that the existing fleet of outdated coal plants gets cleaned up or phased out — and is replaced by solar and wind energy that’s ready to fill our energy needs, create new jobs, and jump-start the green economy.”

The partnership between Sierra Club and Bloomberg Philanthropies will be crucial to helping the Sierra Club achieve their big picture goals of:

  • Cutting coal production by 30% by 2020;
  • Reducing mercury pollution by 90% by 2020; and
  • Replacing a majority of coal-fired power with clean energy.

Michael Brune, Sierra Club’s Executive Director, refers to the partnership with Bloomberg as a “game changer” in the battle against coal that will help his organization work with communities across the nation “as they tell one coal plant after another that inflicting asthma and other diseases on their children is unacceptable.”

“We can’t do it alone,” says Mary Ann.  “The chance to move our nation beyond coal and toward clean energy is in our hands.”

Author’s note:

Beyond Coal Campaign successes to date include:

  • Stopping 153 new coal-fired power plants from being built, preserving market space for clean energy.
  • Pushing existing plants closer to retirement. Nearly 10% of the current coal fleet is now slated for retirement.
  • Slowing the issuance of new mountaintop removal mining permits to a trickle.
  • Achieving victories at 16 colleges and universities, where Sierra Student Coalition members have won fights to shut down coal plants on their campuses.
  • Mobilizing hundreds of thousands of people in support of strong clean air and water protections.
Aug 9 / gchambers

Sierra Club Releases New Report on Giant Fish Blenders

How Power Plants Kill Fish & Damage Our Waterways (And What Can Be Done to Stop Them)

Washington, D.C . –  Today, the Sierra Club released a new report detailing the damage from outdated once-through cooling systems used by power plants in the Gulf of Mexico; the Mississippi River; the Hudson River, New York Harbor and Long Island Sound; the California Coast; the Great Lakes and the Chesapeake Bay.

As detailed in the report titled Giant Fish Blenders: How Power Plants Kill Fish & Damage Our Waterways (And What Can Be Done to Stop Them), it is estimated that billions of fish and other aquatic organisms are killed each year by water-intake systems on outdated power plants, including coal-fired power plants. The federal Environmental Protection Agency (EPA) has proposed new standards for these cooling water systems and is currently accepting public comment on the draft standards, which unfortunately fall far short of what is needed to protect fisheries and waterways.

Antiquated power plants throughout the nation use water-intake systems to help cool equipment that has generated heat during the energy-making process. These cooling pipes sit below the water’s surface and suck in not only water, but also anything else in the vicinity. After the water is drawn through the power plant, it is discharged at high temperatures back into the body of water. The process threatens the full spectrum of wildlife in the aquatic ecosystem at all life stages—from tiny photosynthetic organisms to fish, shrimp, crabs, birds and marine mammals. Some areas face devastating economic repercussions as fisheries are threatened and recreational uses are diminished. This outdated process is demonstrated in this popular animation by Pulitzer Prize-winning cartoonist Mark Fiore

“Power plants suck more than 200 billion gallons of water a day from America’s waterways,” says Dalal Aboulhosn, Washington Representative for the Sierra Club.  “Forty-nine percent of all of the water use in America is from the power industry. That’s more water than all of our nation’s irrigation and public water supplies combined.”

The EPA is charged with implementing Section 316(b) of the Clean Water Act, which requires the use of the best technologies available to minimize the environmental harm of power plants’ water use. “Closed-cycle cooling” is the best technology available to reduce the threats of cooling water systems and is both cost-effective and already in use across the country. Closed-cycle cooling reduces water intakes by approximately 95 percent, drastically reducing the amount of water needed for power plant operations, and resulting in a corresponding reduction of the damages to fish and other species and the surrounding ecosystem. However, the EPA has proposed new federal cooling water standards that would not require utilities to use these updated systems. The public comment period for those draft standards closes on August 18 and comments can be submitted by visiting

“Under intense pressure from powerful industry interests, the EPA has decided not to require power plants to use the best technology available,” said Mary Anne Hitt, Director of the Sierra Club’s Beyond Coal Campaign. “Instead, EPA issued a proposed standard that largely maintains the status quo, offering little-to-no improvement in the technologies required to protect our waterways and our wildlife. The cooling water guidelines currently proposed by the EPA will do little to address the devastation described in this report. We hope that the report will illuminate the harmful effects of once-through cooling on the health of our fisheries and waterways, and will encourage the EPA to require higher standards for these systems.”

For a copy of the report, visit
For a fact sheet on cooling systems, visit

Claire Orphan, 312-251-1680 x146

Aug 3 / admin

EPA Takes Power Plants to the Mat over Toxic Air Pollutants

*As published on Ecocentric Blog

by Kyle Rabin | 08.02.2011

Digital montage by Jamie Leo, based on photos by Alfred T. Palmer (Library of Congress collection), Donncha O. Caoimh and Kyle Rabin.

If you ever want to see an Ecocentric writer get all worked up, just mention the nation’s aging power plants and the havoc they wreak on the environment and public health. As you know, we have devoted a series on the negative impacts that these old plants have on aquatic life. But the most obvious attack on the environment (and human health) is what comes belching out of the stack and into the air.

Power plants are the nation’s largest source of toxic air pollutants. Coal-fired power plants emit 50 percent of mercury emissions, 50 percent of acid gas emissions, and 25 percent of toxic metal emissions generated in the United States.  These pollutants from coal- and oil-fired power plants pose serious health threats to every American, including brain damage in newborn infants, cancer and cardiovascular, dermal, respiratory and immune system damage.

According to the U.S. Environmental Protection Agency (EPA), mercury can harm children’s developing brains affecting memory, attention, language, and fine motor and visual spatial skills. Other toxic metals such as arsenic, chromium and nickel can cause cancer.Mercury and many of the other toxic pollutants also harm the environment and contaminate our nation’s lakes, streams and fish.

Despite the dangers they pose to our health and the natural world, there are no national limits on the amount of mercury and other toxins released from power plant smokestacks.  But now the EPA is proposing Mercury and Air Toxics Standards (MATS) for Power Plants to limit toxic pollution, keeping 91 percent of the mercury in coal from being released to the air. Harmful particle pollution will also be reduced, preventing hundreds of thousands of illnesses and up to 17,000 premature deaths each year. Reducing toxic power plant emissions will also prevent tens of thousands of heart attacks, bronchitis cases and asthma attacks. In short, the new MATS rule will save lives and protect millions of Americans from preventable disease.

EPA estimates that the value of the improvements to health alone will total $59 billion to $140 billion in 2016. This means that for every dollar spent to reduce pollution from power plants, the American people get $5 to $13 in health benefits. Now that’s an excellent return on investment that should make us all happy.

EPA wants to hear what you think about this new rule. Comments may be submitted by August 4th via (enter “EPA-HQ-OAR-2011-0044-0001” in the search bar).


Jul 13 / admin

10 Things to Know about Power Plant Water Use, 10 Reasons to Care

by Kyle Rabin and Peter Hanlon

10 Things to Know about Power Plant Water Use:

  1. Some things get better with age. Not power plants. The nation’s older power plants that still rely on antiquated and damaging once-through cooling systems have a huge thirst for water. These plants are capable of withdrawing approximately 100 trillion gallons each year directly from rivers, lakes, estuaries and oceans; profiting from a free public resource.
  2. A single plant with an outmoded once-through cooling system can take in several billion gallons of water in a single day – more than a million gallons per minute.
  3. Outdated power plant cooling water intake systems indiscriminately devour aquatic life, sucking in eggs and larvae, trapping adult fish and wildlife on intake screens, and spewing heated, lifeless, chemical-laden water downstream.
  4. The killing of trillions of fish, shellfish and other species at all life stages through this practice has stressed and depleted our waters, disrupted the food chain and undermined ecological integrity. (Download a PDF of this report)
  5. Power plants’ toll on some fisheries rivals, and in some cases exceeds, that of the fishing industry.
  6. This destruction has been going on for decades while power companies have tenaciously resisted upgrading their cooling systems. As a result, roughly half of U.S. power plants still use once-through cooling and…
  7. …these same plants also pollute the air because most of them are old, inefficient, and lack emissions controls.
  8. The federal Clean Water Act requires power plants to use the Best Technology Available (BTA) to minimize the adverse environmental impacts of cooling water intake structures.
  9. In 2001, U.S. Environmental Protection Agency (EPA) issued national regulations identifying closed-cycle cooling as BTA for new plants.
  10. In April, the EPA proposed BTA requirements for existing power plants. Environmental groups and others are disappointed in the proposed requirements. The comment period ends July 19, 2011. Comments may be submitted via (enter “EPA-HQ-OW-2008-0667-0110″ in the search bar). The agency must take final action on those requirements by August 18th, 2012.

10 Reasons to Care:

  1. None of this damage is necessary because modern closed-cycle cooling (CCC) systems recirculate cooling water, reducing withdrawals and fish kills by about 95 percent. Virtually all gas-fired plants and more than 75 percent of coal-fired plants built in the past 30 years (as well as 40 percent of existing nuclear plants) use CCC.
    Requiring the electric power industry to significantly reduce its water withdrawal/water use will be good for fish and other aquatic life…
  2. …and if it’s good for fish and other aquatic life then it is good for the ecosystem as a whole…
  3. …and if it’s good for the ecosystem then it’s good for water-dependent businesses…
  4. …and good for local fisheries that support recreational and commercial fishing…
  5. …and that’s all good for the local economy.
  6. Contrary to the power industry’s claims, requiring older plants to install the same cooling technology as their modern counterparts would cost consumers pennies or at most a few dollars per month on household electric bills.
  7. Only the most antiquated and marginal plants that can barely afford to operate might choose to close down rather than upgrade to CCC.
  8. Requiring cooling system upgrades may even clean the air. As a nation we need to phase out the older, polluting and inefficient power plants by pursuing renewable energy and energy efficiency.
  9. The U.S. Environmental Protection Agency (EPA) wants to know what you think. As mentioned above, the comment period on EPA’s proposed requirements ends August 18th, 2011. Comments may be submitted by entering “EPA-HQ-OW-2008-0667-0110″ in the search bar at

Today’s content is courtesy the Ecocentric Blog.

Jun 15 / admin

Protecting our Waterways From Power Plants: Why it matters to the future of America’s majestic rivers

Originally published at Ecocentric

Paul Gallay, Executive Director & Hudson Riverkeeper and environmental attorney Reed Super talk about how power plants using once-through cooling technology to cool their turbines and produce electricity are destroying the Hudson River’s fish and aquatic life in this important new video.

Each year, power plants using once-through cooling suck in nearly 100 trillion gallons of water from many majestic waterways throughout the nation, including the Hudson River.  The Hudson River has a rich and long history of commercial fishing, which has been compromised by this outdated technology. As a result of pollution and power plant intakes, Shad and blue crab are the only commercial species remaining in the Hudson and there is currently a ban on commercial and recreational fishing for Shad in order to allow this historically important species to recover.

The U.S. Environmental Protection Agency (EPA) recently proposed a regulation that was supposed to address the power plant fish kill problem, and which has been delayed for decades by fierce industry resistance. But EPA’s proposed rule fails to require plants to install closed-cycle cooling, a widely used and proven technology that has been available for decades and can reduce the number of fish killed by 95% or more.

Requiring cooling system upgrades would not only protect fish and aquatic life; it would create jobs, improve the economy, and potentially improve air quality. Some of these marginal plants will choose to repower their facilities, which will transform them into a state-of-the-art modern facility, allowing them to produce clean electricity more efficiently and at a lower cost, an all-around win for the environment, consumers, and the economy.

Learn more about the damage caused by the nation’s older power plants, and take action today to urge the EPA to adopt a strong standard for modernizing power plant cooling systems in its final rule by requiring closed-cycle cooling.

Jun 1 / admin

Stand up to dirty power (and end the fish massacre!)

Power plant cooling water intake systems kill billions of fish and other aquatic creatures every year and currently require more water than any other industry in the United States. Many of these plants are located on some of the nation’s most beautiful and treasured waterways. “Closed-cycle cooling” will help to reduce the number of fish killed every year, as well as reducing the negative environmental impacts. This video by the Sierra Club asks the Environmental Protection Agency (EPA) to stop dirty power and use the newer and cleaner technology that is available. Currently, over 200 million gallons of water is used for “once-through cooling,” a system that sucks water into the plant’s cooling system and then releases it back into the waterways at much hotter temperatures, in turn killing millions of fish.

Take action today to modernize America’s power plants and protect our water resources from the harmful impacts of once-through cooling. Sign the ePetition above by July 19, 2011 and tell the EPA to adopt a cooling water rule, based on closed-cycle cooling, that ensures the protection of the Hudson and our Nation’s other waterways.

May 18 / admin

A View to a (Fish) Kill: A Firsthand Perspective on Fish-killing Cooling Systems

*As published on Ecocentric Blog

by Kyle Rabin | 05.18.2011 |

Main Image for: A View to a (Fish) Kill: A Firsthand Perspective on Fish-killing Cooling Systems 
Rob Weltner, President of Operation SPLASH
[Photo courtesy of Dulce Fernandes]

Rob Weltner grew up on the south shore of Long Island so the South Shore Estuary looms large in his life.

“Ever since I was walking I was always by the water or in the water or under the water,” says Rob. “Life for me revolves around the bay and the ocean and what’s in it.”

For over a decade, Rob has been an environmental champion for this critical coastal aquatic habitat. A former contractor who worked at several metropolitan-area power plants, he brings to the table some unique experiences including what he observed regarding one particular threat to the estuary: an aging power plant’s massive water withdrawal via antiquated once-through cooling water intake structures.

For Rob, who now heads up the volunteer non-profit Operation SPLASH, a certain power plant stands out from his contractor days: the E.F. Barrett facility in Island Park, which also happens to be three villages away from where he grew up. While working at the Barrett plant, Rob witnessed the devastating impact that an outdated cooling water intake system can have on aquatic life.

On one occasion, Rob saw hundreds of horseshoe crabs trapped against the facility’s cooling water intake screen. He and a few colleagues rescued as many of the prehistoric crabs as they could by raking them off the screen and tossing them back into the bay as far from the intakes as possible. How many crabs were killed or injured wasn’t clear to Rob, but what was painfully obvious was that this amazing creature – which has survived for tens of millions of years – was no match for the thirsty power plant.

While horseshoe crabs are not endangered (yet), there are a variety of concerns about the future of this primeval species, most notably the loss or degradation of its habitat. “It’s a shame,” Rob points out, given the arthropod’s unique biological and ecological importance.

According to a 2005 New York State wildlife conservation report:

The horseshoe crab is an interesting species because it has evolved little in the last 250 million years. It is used widely in medical research, harvested as eel bait, and its eggs are an important spring food source for migratory shore birds.

Interestingly, sampling studies conducted from February 2003 to February 2004 – a handful of years after Rob’s experience – by the Barrett plant’s owner makes only a passing reference to horseshoe crabs but they do reveal the wide range of other species impacted by the once-through cooling systems. According to the New York State Department of Environmental Conservation (DEC), these studies indicated that approximately 1.2 billion fish eggs and larvae were entrained (sucked in through the intake screens and into the system), and approximately 178,000 fish were impinged on (or trapped against) the screens by the pressure of the intake flow. A DEC fact sheet includes the following information regarding the species found in the sampling studies:

Thirty-three taxonomic groups of fish were collected in entrainment sampling, with five taxa (cunner, bay anchovy, tautog, windowpane, and searobin) comprising more than 90 percent of the sample. Fifty-seven species of fish were collected in impingement sampling. Atlantic silverside, Atlantic menhaden, mummichog, striped killifish, and winter flounder comprised more than 92 percent of the sample. In addition, a total of 1,394 individuals of selected macroinvertebrate species were also collected in the impingement monitoring at Barrett.  Blue crab was the dominant species impinged, both numerically and by weight.

According to the DEC, of the five Long Island central station power plants, Barrett ranks first in regards to annual impingement. The DEC’s findings show that the most recent estimates place Barrett within the top 10 power plants in New York State for impingement and entrainment.

“These numbers speak volumes,” Rob affirms.

This is why DEC is proposing to modify Barrett’s State Pollutant Discharge Elimination System (SPDES) permit based on the Department’s determination that the plant’s owner must install a closed-cycle cooling system, which would reduce the amount of water being withdrawn by approximately 95% (and subsequently would decrease the number of fish destroyed by 95%).

“My hat’s off to the DEC for having the guts to make this decision regarding Barrett,” Rob says. “They stood their ground and made the correct decision.”

While the DEC may be on the right track, the Environmental Protection Agency (EPA) seems to have fallen off course. After issuing its long-awaited proposed rule – under section 316(b) of the Clean Water Act for all existing power generating facilities and existing manufacturing and industrial facilities – the EPA came under fire by several of the nation’s leading environmental groups which blasted the rule as being ineffective and criticized the agency for caving in to industry interests.

Rob is concerned that the EPA’s proposed rule could undermine broader efforts to get plants to retrofit to closed-cycle cooling. “I’m very disappointed in the EPA for not standing up to the industry. The proposed rule is weak and not only will it do nothing to protect the local environment it will also adversely impact local economies with water-dependent recreational businesses. I’m particularly worried what the EPA’s proposed rule means for plants like Barrett because, without strong direction from the EPA, DEC and other state agencies won’t always have the fortitude to stand up and do the right thing.”

There is a certain degree of irony from Rob’s perspective. “On Long Island, all fishermen — commercial and recreational — have strict limits on the size and number of fish we can take from the water. If they violate those limits, they get heavy fines and possible jail time. Yet these power plants get a free pass to kill all kinds of marine life without restrictions all for the sake of the power company’s profit margin. How is this allowed to happen? It’s just a tremendous waste of life. Anything we can do to help to improve the various fish stocks should be a no brainer. In the long run it will pay off for the various species, the health of the estuary and the local economy. The power companies can afford to make these changes. What society can’t afford is to allow these power companies to get away with business-as-usual.”



A close encounter of a different kind: While Rob Weltner’s up close experience with power plant cooling intake structures was downright extraordinary, the encounter that scuba diver John Vincent had last year was simply terrifying.  Vincent was sucked into the cooling water intake pipe at the Scattergood power plant in Playa del Rey, California.  Fortunately, he lived to tell his story and in the process, helped to bring some attention to this lesser known environmental impact caused by aging power plants.

May 16 / admin

Power plant cooling rules aim to reduce fish kills

By Kari Lydersen

*As published on Midwest Energy News

The Environmental Protection Agency is proposing new steps to reduce the number of fish killed by power plant cooling systems, but critics say the plan, which relies on state-level enforcement, will be ineffective.

Every year billions of fish are killed by coal-fired and nuclear power plants across the Midwest. As these plants suck in water from lakes and rivers, adult fish perish pressed against the intake screens, while juvenile fish, larva and eggs are sucked right into the system.

Many of these systems also expel water at up to 30 degrees warmer than it was taken in, which contributes to blooms of toxic and oxygen-depleting algae that can kill fish and foul water.

On April 20, the EPA proposed a new rule meant to reduce the number of fish killed by older power plants with open cooling systems (as opposed to the closed cooling systems that reuse the same water and have been the industry standard for new plants for several decades).

Critics say the proposed rule does little to change the status quo, since it largely delegates authority to resource-strapped state agencies to come up with specific requirements for individual plants and to enforce those requirements.

Natural Resources Defense Council attorney Thom Cmar called the rule “a big punt by the EPA to the states,” opening the door for a loose patchwork of approaches rather than stricter, streamlined requirements.

The proposed rule, open for public comment until July 19, changes the way section 316b of the Clean Water Act is implemented. It applies to any plants that take in more than 2 million gallons of water per day and uses at least a quarter of it for cooling. Paper mills, textile mills, metal manufacturers and other industries fall in this category, but power plants are by far the largest such water users.

Half of all the water withdrawn each day in the U.S. – about 200 billion gallons – is for cooling power plants, according to the U.S. Geological Survey.

Power industry officials have said a revised Clean Water Act rule requiring significant changes to cooling systems could have a major economic impact, forcing power plants to close and leading to rate increases. Officials with the Edison Electric Institute, an association of shareholder-owned electric companies, said industry representatives are still analyzing the likely impact of the proposed rule.

‘The lowest common denominator’

Environmental groups have long pressed for stricter standards, with many advocating that all plants be required to convert to closed-cycle cooling systems. The new rule was sparked in part by a lawsuit filed by the New York organization Riverkeeper and the NRDC.

The rule deals with impingement, or fish caught against intake screens and structures; and entrainment, or fish sucked into the cooling system. A separate part of the Clean Water Act (section 316a) regulates the temperature of water released from power plants.

For entrainment, the proposed rule basically leaves it up to most state governments to decide what regulations, if any, to impose. The rule lays out standards for determining best technology available to reduce entrainment as part of the state permitting process.

“The big problem is they’re leaving it to a case-by-case determination,” said Sierra Club Great Lakes Program director Emily Green. “The states do not have the capacity. To think we’re going to do a reasonable job of looking at every power plant and making a case-by-case determination, we don’t believe that’s going to work.”

Regarding impingement, the proposed rule says plants can either reduce the speed of the water being sucked into their system, or they must prove that no more than 12 percent, annually, of fish that are impinged on intake structures die. If power plants reduce the water speed, they don’t have to meet any numerical fish mortality limits, since it is assumed fish will then be able to swim away.

Cmar and other advocates are skeptical the rule will result in meaningful changes.

“Experience has shown that the Midwestern states lack both the political will and the expertise to evaluate the engineering details of a plant’s cooling water intake and require changes that will minimize their environmental impact – even though that’s what the Clean Water Act requires,” Cmar said. “And the EPA has failed to step in and enforce the Clean Water Act in the states’ absence. It’s taken decades of litigation by environmental groups just to get the EPA to make the woefully inadequate proposal that’s currently on the table.”

Eric Uram, a Wisconsin angler and environmental consultant, said delegating environmental decision-making to state agencies leads to “the lowest common denominator.”

“If you have one state doing one thing, it lowers the bar,” he said. “Most of the time what you end up getting is, ‘We’re not going to do any more than what anyone else is going to do.’”

The ‘Bass-o-matic’

Technology options described in the rule include fabric walls or nets blocking off the water intake area, and structures to divert fish. The EPA says the best technology may be screens outfitted with hoses that spray fish into buckets to return them to the water unharmed. Cmar called it a “Rube Goldberg-esque contraption developed so companies can continue to make this massive, massive withdrawal of water.”

The EPA estimates the proposed rule will prevent the deaths of 615 million fish (or their ecological equivalent) each year. Two other options the EPA considered would have saved about three times as many fish, but were not deemed economically or practically viable.

A controversial U.S. Supreme Court ruling found that a cost-benefit analysis can be considered in deciding how to implement 316b, meaning that the technology that saves the most fish won’t necessarily be mandated, but rather the one that saves fish the most “efficiently” considering costs.

Cmar said this is problematic since such analyses might not adequately account for the cumulative economic value of smaller “forage” fish and other organisms that aren’t prized by anglers but are key to the food chain.

“How do you capture all the benefits of not killing massive numbers of those fish that are supporting more valuable fish?” asked Cmar.

The NRDC studied the effects of the cooling system at FirstEnergy’s Bay Shore coal-fired power on Lake Erie’s Maumee Bay near Toledo. The NRDC dubbed the plant the “bass-o-matic” for the high number of fish killed: about 50 million adult fish through impingement, and almost 14 million juvenile fish, two billion larval fish and 200 million fish eggs sucked into the system.

The Ohio EPA has ordered the Bayshore plant to reduce the number of fish killed, though the NRDC and other critics said its requirements still aren’t strict enough. The plant is located in one of the Great Lakes most fertile spawning areas, and the NRDC estimated the economic impact of the Bay Shore plant’s cooling system on fisheries at $30 million a year.

The EPA estimates that about 350 power plants with open cooling systems will be subject to the new rule, including 37 power plants that draw water directly from the Great Lakes. Analyzing an EPA database, the Sierra Club has identifies 67 coal-fired power plants with open cooling systems on the Great Lakes or nearby on tributaries.

Are cooling towers the best option?

New plants are already required to have a closed cooling system, which usually entails a cooling tower. Environmental groups including the NRDC, the Sierra Club and Riverkeeper want the EPA to impose strict limits on the number of fish impinged and entrained at existing plants, limits that might only be obtainable by converting to a closed cooling system.

In the proposed rule, the EPA says it decided not to require closed cooling systems because they would not be feasible at all locations. Some plants lack space to build a cooling tower, the EPA said, and running a closed cooling system requires burning more fuel which increases air emissions and could violate a facility’s air permit. It might not make financial sense to invest in new cooling towers at older plants, the EPA added, and the requirement might affect the reliability of local power supplies.

“The fact that we have built new facilities with closed-cycle cooling may be true, but what doesn’t transpose is that therefore…we can do it at all other existing facilities,” said Rich McMahon of Edison Electric Institute. He said the monitoring requirements in the rule are “excessive,” especially measuring the mortality rates of fish caught on screens.

“There’s a difference between monitoring a pollutant that’s coming out of a facility and trying to accurately and precisely monitor the interaction between living critters and an intake structure,” McMahon said. “The facilities covered by this aren’t in the business of raising and tending fish. But here they are supposed to capture the ones impinged, babysit them for two days, and see how many survive.”

Kari Lydersen is a Chicago-based freelancer and author whose work appears in The Washington Post, The New York Times and other outlets.