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So the EPA will add new regulations to mercury emissions from coal that will drive up the cost of burning coal, and cause utilities to switch to gas because it will be cheaper than complying with the new coal regulations; and the railroads will thus suffer from a loss of coal hauling business.  Mr. Frailey calls it the perfect storm.     <?xml:namespace prefix = o ns = "urn:schemas-microsoft-com:office:office" /><o:p></o:p> That sounds like a reasonable analysis, but doesn’t this “perfect storm” also include the impending CO2 regulation of cap-and-trade legislation, which will drive up the cost of both coal and gas, and reduce the consumption of all forms of energy?  Cap and trade, which amounts to price rationing of energy, may reduce rail transport of coal far more than the mercury regulations.  Isn’t this the real “600-pound gorilla in the living room” component of this so-called perfect storm? <o:p></o:p> Mr. Frailey does make reference to the CO2 regulations with this sentence: “A bipartisan effort in the Senate to limit EPA’s power to regulate carbon dioxide wouldn’t affect the mercury rules.”  In reading the paragraph containing this sentence several times, however, I am not able to exactly understand his point.  I guess he was excluding that bipartisan effort per se from automatically reversing the new law on mercury.    But if I understand it correctly, we have just recently passed the point where a bipartisan effort to limit the EPA’s power to regulate CO2 was voted down in the Senate, so that horse has already left the barn.  Perhaps Mr. Frailey wrote his column just prior to this recent development.  In any case, I speculate that the Obama Administration, now having the unfettered power to impose cap and trade through the EPA, will make the mercury regulations seem mild by comparison.    Moreover, the reduction in consumption imposed by cap and trade will have adverse impact on rail traffic other than just coal.
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