On acid rain (JofC, Nov. 17) the debate certainly hasn't changed during the past three sessions of Congress. The scientific debate on the causes and effects and the adequacy of scientific data to make the decision continues to be the primary argument. Acid rain control legislation is expensive; the cost/ benefit argument - does it cost or does it pay? New combustion technology; will it be delayed or canceled if acid rain legislation is enacted?

Our organization, which represents more than 30 low-sulfur coal producers, transporters and consumers, has elected not to participate in the scientific debate, but rather to direct our efforts and support to economic principles which we think should be included in any acid rain legislation.We recognize that acid rain legislation will be expensive, but if emitters aren't given the freedom to choose the most cost-effective method in reducing their emissions, the cost will be more than double with no additional environmental benefits. We agree with those who conclude that scrubbers are an expensive option for SO2 emission reduction.

The use of low sulfur coal is not only economical but will provide early emission reductions, 6.5 million to 7 million tons of SO2 reductions per year. An added environmental benefit of using low-sulfur coal is the elimination of approximately 20 million tons of sulfur sludge a year based on the generation of approximately 3 tons of sludge for each ton of SO2 removed.

We are not aware of any study that has forecast the cost of managing this waste indefinitely nor the cost of land used for the waste storage, which certainly must be considered in the total cost of operating wet scrubbers.

The cost of the reductions should be borne by those who will be required to reduce their emissions, not subsidized by those who are currently paying for emission controls. Environmental law should not reward those who are last to comply nor penalize those who were first.

We recognize and support some additional cost-effective principles. These include: Emission averaging - annual averaging of large geographical areas and/or utility systems. Flexibility in emission reduction targets - allows mid-course correction based on additional scientific knowledge on the causes and effects of acid rain. Nox reductions - should be limited to those reductions that are deemed cost-effective.

The development of improved coal combustion technology for future coal- fired steam generating plants should be encouraged and does not have to be delayed or cancelled. The difference in the cost of acid rain legislation that contains our principles and legislation that mandates scrubbers is approximately $30 billion. This saving exceeds by approximately six times any research and development cost for improved coal combustion technology I have seen.

We have not supported any particular acid rain bill. We are convinced that Congress will pass acid rain legislation in response to the American public, or which the latest public opinion polls indicate more than 70 percent favor acid rain legislation. In addition, 45 governors have indicated that they too support acid rain legislation.

Acid rain legislation must be cost-effective, providing the maximum environmental benefit for each dollar the consumer pays.

Harold L. Storey President Alliance for Clean Energy Rosslyn, Va.

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