Stanley Feld M.D.,FACP,MACE

There is no shortage of opinions about the value of EMRs. There are a lot of intelligent people writing about the advantages and disadvantages of the Electronic Medical Record.

No one has figured out how to break the physician resistance barrier. If someone would develop an EMR that would add value to the advantage of the physician and the patient, utilizing an easy learning curve, I think the universal EMR would spread like wildfire.

First, we need an enlightened and respected leader who could force the healthcare system to face its problems, namely the inefficient costs of administration, price opacity, lack of systems of care for chronic disease, and the lack patient control of their healthcare dollar.

The inefficiencies of administration of the healthcare system by facilitator stakeholders waste $150 billion dollars a year. I can understand why a facilitator stakeholder such as an insurance company or hospital resists eliminating this waste. There is a large profit margin in waste. In order to protect this income generating inefficiency, multiple excuses and barriers to fixing the waste are constructed. These stakeholders always seem to blame the physicians and the patients for the waste.

The following two comments from nationally prominent physicians sum up the problem and perceptions about EMR of most physicians.

The first comment is from a nationally prominent specialist who at one time was the head of a 300 physician multi-specialty IPA (Independent Practice Association). He subsequently headed a large single specialty group of physicians. He had start up experience with EMRs in both practice groups. His view is cynical but in my opinion accurate.

“Stan,
The EMR is expensive awkward technology. EPIC possibly the most widely developed (in part owned by Kaiser I believe) is not user friendly, requires much administrative support and has so many bells and whistles that users empirically incorporate their own mini user protocols, essentially defeating the purpose. I disagree that physicians are particularly computer literate and believe that cost and the fact the technology is still awkward and non-standardized is a barrier. Someone is going to need to underwrite or give physicians the technology, and it better not be the VA EMR which Medicare was at one time proposing to roll out. Of course, if the technology is provided, the giver will want to be able to puts its nose under the tent and gain information, consistent with HIPPA’s provisions.
Will EMR improve patient care and safety? No question it will but I suspect it will take 25 years. Will it generate information that may or may not result in physician disincentives, possibly? Very difficult for me to believe EMR will ultimately result in benefit as defined by current vendors. New generations of physician users, however, may believe there is benefit and be unaware of the coexistence of physician disincentives.”

Those developing EMRs should pay attention. No one has developed an easy to use and inexpensive EMR. No one has explained the multiple values of the EMR measurement. Only negative and costly experiences linger. The key questions not asked are who the real customers, and what do the customers really need. In the mind of most EMR vendors the hospital, government, insurance industry are the real customer. These are the stakeholders that have the money. Physicians and patients do not have the money to invest in an EMR.

I was told this 12 years ago by the head of the medical informatics division of a large corporation. I told him his focus in my opinion was dead wrong. I predicted and his EMR would fail. It has not succeeded although they have generated some very painful experiences for all the stakeholders.

The healthcare system needs the development of an EMR that will satisfy the needs of the physician and the patient. It must be user friendly and augment rather than hinder the physicians daily work flow. The EMR can not be punishing nor have a steep learning curve.

An ideal EMR would be one we did not buy. The needs of the physician and patient would be clearly defined. The EMR would be paid for by the click, just as you pay a credit card company for adjudicating a purchase. There is no reason the patients insurance claim could not be adjudicated immediately with a credit card. The physicians would not have to pay for endless upgrades and improved interfaces. The EMR vendors would pay for their mistakes, not us. There would be continuous quality improvement in the software system at no up front cost to the user. The system would be a heavily encrypted web based system for privacy. The patient would own their own data. It would be totally portable. The more the physician uses the EMR and its financial packages the more the physician pays for its use. The patients’ electronic medical record would have to be connected to the patients’ financial history in order to evaluate medical outcomes appropriately. EMR’s will not succeed until some creative vendor realizes this and can get over his own bureaucratic hierarchy. There should be no penalty to abandon an EMR that does not work well for the patient or the physician.

The second note is from another prominent leader in medicine. He is describing the core of the problem in the healthcare system. Until we abandon our legacy systems designed to protect facilitators stakeholders’ vested interests, we are not going to get anywhere in repairing the healthcare system. We will continue to generate million dollar plus salaries for insurance company CEOs and hospital administrators who add no value to the medical care system.

“Stan
My own opinion is that, until our government guarantees adequate health care access and cost/coverage to all Americans and requires transportability of medical records for all without casting the cost for this onto the physicians, we will continue to have the same mess we now have.”

I do not think Nancy Pelosi has a clue about what needs to be done. Remember, the government is not going to solve our problems. The primary stakeholders (the patients and physicians) must solve our problems.

The government’s job is to create the conditions for patients to be responsible purchasers of healthcare with their own money in a totally price transparent environment. Then, and only then will price and quality competition take place among physicians and hospitals as well. At that time, adoption of an EMR to increase efficiency, decrease expenses and increase quality will make sense to physicians and hospitals. The EMR will be driven by the patient demanding a lower cost vendor in a price transparent environment with improved quality of care. The ideal MSA would encourage the use of the ideal EMR.

Stanley Feld M.D.,FACP,MACE

Physicians have been slow to adopt Electronic Medical Records (EMR) even though most physicians are computer savvy. There are reasons for physicians to be slow adoptors.

They are told that the EMR will increase their quality of care. However, quality of care has not been adequately defined by those who proclaim EMRs’ virtue. Physicians have negative experiences with information technology. The insurance industry and government have used IT against physicians to decrease the fees. Physicians know much of the data collected by the insurance industry and government has been formatted to answer the wrong questions. The potential of the EMR simply stimulates more mistrust and suspicion on the part of the physician against these entities.

Those knowledgeable about EMRs would say “Dr. Feld you have it completely backward.” Perhaps I do. I do not think so. I have expressed the perception of many physicians. Perception translates to the reality of resistance by physicians.

I understand the advantages of a functioning and effective EMR. If done correctly the physicians would flock to adopt the system. However, most demonstrations of EMRs are a disaster. The implementation of EMRs by most EMR companies has been worse. The purchase of an EMR to many physicians has simply been money down the drain. A few practices have been lucky and very successful.

The investment the physician must make is at minimum $50,000 per physician. In an environment of decreasing insurance and Medicare payments, $50,000 is a huge investment. In addition there is usually an annual maintenance fee as well as yearly service fee. Many software companies produce EMRs. Choosing the correct EMR seems impossible to most. Many physicians have been stung by the software company going out of business within two years, making their investment worthless.

In the January 2007 issue of Health Data Management there appeared a Newsline article “Hawaii Blues to Docs: We’ll Help with EMRs.

“A $50 million program from the Hawaii Medical Service Association, under which the Blues plan, would give providers substantial financial help to purchase electronic medical records systems, could wire up most physicians in the state.”

Why would the physicians want to be wired up? What does wired up mean?

“Honolulu-based HSMA also thinks the program will foster the longer-term goal of establishing regional health information organizations.”We’re making this investment to move the community along to wider adoption of I.T. so we can be ready for RHIO activity,” says Cliff Cisco, senior vice president. “There’s a lot of RHIO talk, but we’re a ways off from implementing a network. We want to prepare for that and give motivation.”

One should note that a RHIO is a network of information of all the patients’ charts in a regional and anyone can get patient information and physician care activity instantaneously with proper authorization. This would be great if we lived in an environment of total trust. It could work if everyone would keep this information private and would not use the data gathered against the patient or physician. Remember the social contract in medical care is between the patient and the physician.

“Under the three-year HMSA Initiative for Innovation and Quality the plan has committed $20 million toward the purchase of EMRs for physician practices. It will contribute up to half the cost of an EMR, capped at $20,000 per physician, for about 1,000 physicians.’

The physician would still have to pay $30,000 for something he does not want and he does not perceive will increase the quality of his care. It is viewed as a tool that will be used to punish him.

Cisco believes a “significant” amount of funds under the hospital program will go toward I.T., but the overall goal is to reduce practice variances and improve safety. Details of the program remain under development. “We’ve made the commitment and now are talking to hospitals,” he adds.”

Please notice the implication is the system is going to tell the physician what he should do to practice “good” medicine as defined by the insurance companies and hospital administrators. This seems like a way to generate more mistrust between physicians and the insurance industry.

“The program to help pay for EMRs is open to any physician who doesn’t have EMR software. But the focus will be on small and rural practices where adoption rates are low. HMSA hopes it will get most of these practices to take up its offer, Cisco says. “This is an effort to bring on slower adopters of the technology.”

My response is good luck!

The EMRs also will have to be certified by the Certification Commission for Healthcare Information Technology. HMSA is expected to have a list of acceptable EMRs available by the end of 2006.

If this program was perceived by the physicians as a good idea it would have to be a single uniform software program with measurable data points available to the physician for his proving an improvement in his quality of care to the patient. Multiple software vendors will increase the costs and decrease the mobility of the data collected. I will devote more time to describing the ideal EMR in the ideal MSA system. The system would greatly benefit the patient and the physician. The benefit to the facilitator stakeholders would be secondary and not punitive to the patient or the physician.

“Heavy penetration of EMRs in Hawaii could support more comprehensive pay-for-performance programs. HMSA for five years has had a pay-for-performance program that gives physicians and hospitals “modest” payments for meeting certain quality standards, Cisco says. The new initiative is much larger than existing P4P programs, he notes. “Our board thought we’d ramp this up a bit, put out this $50 million commitment and see what it achieved.”

Does anyone out there know the potential punishing effects to the healthcare system that pay for performance will inflict. In my view pay for performance is not well thought through presently. Many physicians are totally opposed to the notion because the decisions of performance are going to be made by the same insurance company administrators that used incorrect data to produce the failed punitive report card system.

This ambitious program is going in the opposite direction of the concept of the ideal Medical Saving Account. It is not empowering to the patient or physician. P4P in the present form does not provide incentive to the patients or the physicians to improve their performance. It is an administrative mechanism devised to dictate physician behavior, undo patient privacy and reduce payment.
It is sure to fail at best and generate more distrust and waste at worst. The healthcare system does not have three years to waste on this folly. The endeavor is bizarre to me. It is a waste of $50 million. I predict the $50 million loss will be passed on to the patients in the form of increased premiums
The $50 million could go a long way to create the ideal EMR in an ideal insurance system (MSA). Some smart entrepreneurial company will figure it out some day. I hope sooner rather than later.

Stanley Feld M.D.,FACP,MACE

I have been talking about the effects of “Dirty Coal Plants” production of pollutants that precipitate the onset of diseases such as asthma, chronic obstructive pulmonary disease, autism, learning disorders, and attention deficit syndrome to name a few. At the present level of pollution in America, it is estimated that diseases related to Dirty Coal Plants costs the healthcare system $34 billion. With the new Dirty Coal Plants proposed in Texas and the nation, the avoidable cost to the healthcare system could triple.

Everyone is talking about a “broken healthcare system” with out of control costs. Few are trying to do anything to fix it. However, one giant step in the right direction would be to decrease the pollution in the nation and avoid diseases and the costs to the healthcare system precipitated by the resulting pollution.
There are two potential solutions. One is to produce clean coal plants using proven IGCC technology. Utility companies in general and TXU in particular do not want to use this technology because it is cheaper to build and more profitable “Dirty Coal Plants”.

Market forces drive the motivation. However, government should set parameters that are in the best interest of the people and then market forces should drive the motivation.

Thomas Freidman in his October 20, 2006 column “ Make History Arnold” states; “The reason that Mr. Bush’s call a year ago to end our oil addiction has been a total flop has to do with a struggle in his administration between foolish market worshipers led by Dick Cheney—who insist markets will take care of everything—and wiser, nuanced policy makers who understand that government’s job is to set broad goals and standards, and then let the market reach them.”

In my opinion, I think Mr. Cheney’s heart is in the right place. However, I do not believe he sees the whole issue. Adam Smith was correct to a point. With appropriate government rules market forces can be more powerful than complete government control.

The government should have something to say about these “Dirty Coal Plants” for the health and welfare of its citizens. No one has said anything yet. It looks like our political system is also “broken”.
The second solution is embodied in a comment I received for my blog “Review. What I Have Said Recently” from Jay Draiman Director of US Gas & Telecom. It is a wonderful comment. Essentially, it says we need to redirect our thinking.

Americans are a very smart and innovative people. We all understand we need to decrease our dependence on foreign oil. We also understand the oil industry is not very interested in the concept of change. There are other industries linked to the oil industry. The automobile industry has a huge investment in oil dependent cars. All the automobile support industries might not be interested in reducing our dependence on oil because they could also be destroyed by a change in focus away from oil.

We have to decrease our dependence on fossil fuel because of what it does to our environment and subsequently our health. One could think that the healthcare system would be adversely affected by a reduction in disease burden if we decreased pollution. However the physicians mission to preserving the health of our citizens. We are all for decreasing unnecessary healthcare costs by decreasing pollution.
Therefore it is to the advantage all of these vested interests and many others to either keep silent or at least be passive in demanding a change leading to the elimination of our dependence on fossil fuel.
All of us have been exposed to the potential of the kinetic energy that surrounds us. I will define kinetic energy as potential sources of energy we have available to us that have not been harnessed and will not pollute the environment. These energies include wind, sun, water and biodegradable regenerating substances. Technologies are available that make this kinetic energy easy to harness. I suspect we have been very slow at its adoption because the vested interests of the powerful groups have legacy domains threatened by a paradigm change.

It would be interesting if some bright and innovative person like a Steve Jobs or Bill Gates figured out how to generate a paradigm shift to change the conversation. I do not believe it will be done by the present powers driving fossil fuel use unless our government wakes up and does its job.

Eight year old children do not know what a typewriter or a 78 record is. CD’s will soon vanish from the universe.

I think it is about time producing electricity with fossil fuel became the dinosaur it is. The paradigm shift will create a very different world just asl PC and IPOD have.

Repairing the Healthcare System should not be far behind. I believe the stimulus to these paradigm shifts will be the virtual communities of the blogosphere. People like you and me networking and demanding change from our politicians.

I do not think it will be done by our politicians unless we stimulate them to do the right thing.

Jay Draiman’s comment deals with these energies and deserves the spot light and not simply appear in the comment section.

Dr. Feld

Jay Draiman
Northridge, CA. 91325
12-26-2006

Wake up America!!

President Bush did when he was Governor of Texas.

Time for another news quiz: Which American state produces more wind-generated electricity than any other? Answer: Texas. Next question — this one you’ll never get: Which politician launched the Texas wind industry? Answer: Former Gov., now President, George W. Bush.
Yes, there are many things that baffle me about President Bush, but none more than how the same man who initiated one of the most effective renewable energy programs in America, has presided over an administration that for six years has dragged its feet on alternative energy.

He fell asleep when he became President.

Stanley Feld M.D.,FACP,MACE

I have been distracted from my main theme, the ideal Medical Saving Account as the vehicle needed to repair the healthcare system. I have been building the case for this system of self responsibility as the mechanism to repair the best medical care system in the world. The theme is patients’ must control their healthcare dollar to repair the healthcare system.

We must develop a system of incentives where provider prices are transparent and providers compete for the patient’s healthcare dollar. We must create a system where providers (hospitals, physicians, and other healthcare providers) are forced to become efficient to compete for the patient’s healthcare dollar on quality of care and cost of care. The result will be that healthcare costs will decrease and the quality of care will increase. This is the meaning of consumer driven healthcare.

The last few weeks have been spent on the “Dirty Coal Plants” TXU is proposing for Texas. These “Dirty Coal Plants” are being proposed all over the country because of the abundance of cheap dirty strip mined coal. Presently $34 billion dollars are wasted healthcare costs to treat illnesses resulting from the present levels of pollution. The healthcare costs resulting from the proposed “Dirty Coal Plants” in Texas and around the country could easily double and perhaps triple.

The point is that Dirty Coal Plants polluting the environment result in large avoidable costs to the healthcare system. These costs can not be controlled by the patient exercising patient responsibility.

Patients will be afflicted with unavoidable environmentally caused diseases once these Dirty Coal Plants are built and operational. The Dirty Coal Plants will be operational for the next fifty years. The illnesses and costs of medical care for these illnesses could be avoided if we do not pollute our environment.

One could look at building these Dirty Coal Plants as “man’s inhumanity to man in pursuit of the mighty dollar.” I have been amazed by how many people believe that the EPA standards are the state of the art, that the present EPA rules will protect us from pollution. If the levels were a concern the EPA would change the rules. Therefore, we do not have to become pollution experts. The EPA’s mission is to protect us from any environmental toxin that might be dangerous. We have delegated the EPA as our surrogate to protect us from pollutants that could harm us.

Unfortunately, this has proven not to be true. Two court judgments have gone against the EPA rules in recent months. The EPA has for some reason loosened standards of pollution since 2000. One should question why. Our advances in technology have given us the ability to decrease coal burning pollution markedly by building IGCC Coal Plants. Our advances in understanding the medical effects of pollution have demanded that we decrease our exposure to these pollutants.

I understand our need to reduce our dependence on foreign oil as an energy source. If the new Dirty Coal Plants result in an additional $68 billion burden to our healthcare system by avoidable disease healthcare costs, shouldn’t a prudent government be investing in creating incentives for renewable sources of clean energy such as wind and solar energy? At the same time shouldn’t we be investing in creating incentives for energy conservation? We could use the extra $68 billion saved to promote these efforts.

TXU claims there are other sources of pollution such as our automobiles. Shouldn’t we create incentives for automobile companies to decrease the pollution and increase conservation of fuel for our automobiles more than they have? Look at the impact of the Toyota Prius, without incentives. Toyota is not even an American company. Toyota has created a competitive advantage for their product. Other companies have been slow to follow with as efficient a product. In fact it seems they are trying to undermine the efficiency of the product.

America is a brilliantly creative marketing country. America has created many “hypes” in my lifetime. My first recollection was promoting cigarette sales even though the cigarette companies knew they were not good for us. I could not wait to be old enough to smoke a cigarette. Recently, it is flat screen high definition television. Congress has even taken time out from their busy work to set a deadline for digital HDTV.

Why can’t Congress create incentives for us to stop harming ourselves with environmental pollution? Perhaps there is not enough lobbying money in the effort.

Why can’t Congress get smart and use its creative energy to promote the health of our citizens, rather than bending to the vested interest pursuit of the almighty dollar resulting in more pollution and more medical costs to society.

It can only be done if the politicians, the government officials, and the government agencies are challenged by the citizens they are supposed to be serving. It is clear to me the evolution of the rules in our legal system and the institution of lobbying has removed citizen input for demanding what is in the citizens best interest.

The time has come to express ourselves. The citizens of Texas are trying to do that right now. However, we have a very refractory Governor Rick Perry and a very powerful corporation in TXU. TXU has not demonstrated any corporate community responsibility to date. I hope our legislative officials in Austin will be able to respond to the cries of the citizens and force this folly to stop!!

Stanley Feld M.D.,FACP,MACE

I could not understand why some intelligent people do not oppose the proposed building of 17 Dirty Coal Plants in Texas. They are not impressed with any of the information I provided in the last 5 blog posts.

Finally, it dawned on me. The issue is complex. We have been told Texas needs energy to grow and be economically progressive. Coal is abundant since we are strip mining the Powder Basin in Wyoming. The pulverized coal is the dirtiest coal available with high sulfur and mercury content. This is to say nothing about the controversy regarding strip mining and the effect that it has on the topography of the land.

Natural gas has gone up in price. We want to decrease our dependence on foreign oil. Coal is cheap. We have done little to support and subsidize renewable energy such as solar and wind. Why not? These are clean energy sources that we have in abundance. I believe an intensive effort by our country could go far to harness these potential energy source. Solar and wind could provide cheap electricity while stimulating the growth of the economy.

I had an epiphany as I sat and listened to the arguments in support of The proposed Dirty Coal Plants. There is an obvious disconnect between what seems logical to me and what I have heard.

The decisions for building these Dirty Coal Plants are in the hands of businessmen, lawyers, and politicians. Lawyers, politicians and businessmen should not make medical decisions. They readily admit they do not understand medicine. However when the EPA makes a rule that is the “law” and the lawyers’ and politicians’ job is to interpret and enforce the law even if the law is wrong or inadequate.

I am for free enterprise and a market driven economy. Texas is a bell weather state that has grown and been energized by free enterprise and the free market. I am proud of it.

However, the free market should not disregard the health of our citizens, our water supply, and our food chain. This is the corporate community responsibility that we as a state and as a nation must demand.

TXU considered that they received a mandate from Governor Perry to provide increased electricity to the state for its expected growth in demand and the growth of the state in the future.

TXU set out to answer that demand and applied for 9 coal plants in rural Texas. The plants were designed to comply with EPA rules. These Dirty Coal Plants supposedly comply with EPA rules.

One should ask two important questions. Are the EPA rules stringent enough for what we know about the pollutants emitted by the Dirty Coal Plants? Is TXU building the cleanest possible coal plants for the state of Texas?

I understand the arguments of TXU and the proponents of the Dirty Coal Plants. TXU’s goal is to provide the cheapest electricity to Texas at the lowest price. In order to do this they have to build Dirty Coal Plants because natural gas is expensive, and strip mined coal from the Powder Basin in Wyoming is cheap. The old technology of these Dirty Coal Plants makes them easy to build and will provide a good return on TXU’s investment. TXU claims to be a good neighbors and would not hurt us.

TXU claims that the EPA and the TCEQ (Texas Commission on Environmental Quality) are the scientists and make the rules. They are protecting us from TXU harming us. TXU is simply complying with the rules that the experts made. These rules are the law. The state and local government have to comply with the law. The statement eliminates a lot of thinking on the part of the citizens of the state. In short it says “just trust us”.

We have seen our administration, our government officials and government agencies make mistakes recently. These mistakes were made even though information was available to avoid the mistakes. The information was either not communicated or ignored.

We have been informed that the FBI and CIA have not communicated with one another in the past. Both agencies had the composite information about 9/11. The 9/11 terrorist attack could have been stopped if these two agency were communicating effectively. The lack of communication spans the watch of at least two federal administrations.

CIA intelligence about Iraq was either incorrect or defective. The new CIA had no agents on the ground. Why did we not find Weapons of Mass Destruction? If Iraq had them, where did they send them? We absolutely know they had weapons of mass destructions during the Gulf War. We bombed a munitions depot without knowing it. The result was we poisoned 100,000 of our own soldiers and countless Iraqis and Kuwaitis’ without knowing it until the Gulf War Syndrome was described by Dr. Robert Haley of University of Texas Southwestern Medical School a few years ago.

Why did our agencies not understand the geopolitical nature of post war Iraq to predict the recent chaotic events? I submit we did know but they were not communicated to the decision makers or the decision makers did not listen. How could our military make so many mistakes and our diplomats be so inefficient?

The Katrina disaster is another example of lack of communication or inefficiencies of our government agencies. Why was the Corp of Engineers was not listened to when they told the Federal Government how badly the levies needed repair or rebuilding? Why was FEMA not able manage and administer the orderly repair of the flood’s damage and the resettlement of displaced people. Some of those people still do not have adequate temporary housing.

How can one say the EPA rules are correct when on close reading they not only are contradictory but they continually delay the reduction in coal plant emissions with each subsequent set of rules since 2000? These changes in rules result in less stringent air quality controls. Are the emissions getting better for our health? They reduction in control of emission is occurring despite their own commissioned outsourced reports declaring the dangers of present control levels.

It unfortunate that the EPA rules contradict themselves. In 2000, the National Academy of Science was commissioned by the EPA to figure out the minimum toxic dosage of mercury. Their answer was .1 microgram /Kg per day. Therefore a 22 lb child with a growing brain exposed to 1 microgram per day would be receiving a toxic dose of mercury. An average fetus weighs zero to eight lbs. The placenta concentrates mercury from the mother and transports large doses to the fetus. Population studies estimate that 7% of our new borns are affect with abnormal brain development resulting in autism, attention deficit syndrome and degrees of mental retardation. The incidence is highest in mercury polluted areas. Seventy percent (70)%) of our mercury contamination comes from our presently operating Dirty Coal Plants. The human effects of mercury contamination are clearly dose response related. Some individuals are more sensitive to lower doses than others. There should be little to no mercury in the environment.

TXU claims these Dirty Coal Plants reduce mercury output from an average of 800 lbs per year for the existing Coal Plants to 160 lbs per year per coal plant for the new coal plant. TXU is very proud of this 80% reduction and so it seems is the Texas Commission for Environment Quality. TCEQ has granted TXU provisional permit pending the result of the fast tracked public hearings.

There are two problems. The first problem is 160 lbs of mercury converts to 72,480,000,000 micrograms of mercury emitted per new Dirty Coal Plant per Year. The 2000 report said you only need .1 microgram per kg per day of mercury for it to be toxic. The second problem is mercury does not go away. Therefore, year after year this dose is additive.

I also discovered reading the EPA’s literature that one of the by products of burning Powder Basin Coal is Uranium 238. The Uranium 238 is a great source for enriching nuclear fuel. The amount of Uranium by product is more than the minimum amount allowed for a nuclear reactor by the EPA. Yet the EPA does not require measurement of uranium as a by product by these new Dirty Coal Plants. What we do not know will not hurt us. Is that correct? I would think TXU is certain not to measure uranium in the sludge if it is not required to.

There are lots of defects in the EPA rules. Is it possible the rules are inadequate? I think it is likely. In order to clear all this up before disaster strikes again we need to slow the fast track permitting process. If we absolutely need to burn coal for energy, gasification plants are need. Coal Gasification Plants are not experimental as TXU claims. Coal gasification plants can reduce mercury emission by 94% of what the present proposed plants can.

I have not even discussed the toxic effects of sulfur, nitrogen, dioxin. The EPA has not even regulated CO2 emissions. The EPA’s inadequate regulations are going to be accepted by the judges, lawyers, businessmen and bureaucrats as the law despite the deficiencies in the regulations and grant permits to build Dirty Coal Burning Plants. Coal Plants we will bestuck with for 50 years.

The evidence to me is overwhelming. We need to change the law before we allow these plants built.

The EPA is our scientific surrogate. Yet it seems to be ignoring the scientific evidence that states the present regulation are going to harm the health of our society. Do you think the EPA is immune from making a mistake? This administration and other government agencies have made mistakes in the recent past.

It is pretty clear to me that we must speak up for our sake, our children’s sake and our grandchildren’s sake.

Stanley Feld M.D.,FACP,MACE

It seems as if it is very hard for the people’s voice to be heard in Texas. Contacting the Governor is harder than paying the water bill in Franz Kafka’s book “The Castle”. Even if we were listened to, we would not be heard by our governor. He still believes building the Dirty Coal Plants and polluting the state and cities in Texas is good for the growth of Texas even if the majority of the people disagree. Presently, Texas is in the top six for pollution. I bet these coal plants will propel us to “Number 1”. Governor Perry’s office called the opposition of the Dirty Coal Power Plants a liberal Democratic plot. I call it a refusal to understand the issue on the part of the governor.

The following quotes appeared in the Herald Democrat December 8, 2006

“Dozens of David’s lined up here (Bonham,Texas) Thursday (December 7,2006) to see if State Administrative Law Judge Kerry Sullivan would give them a rock to use in the battle against Goliath TXU.”

“Ranchers and those who have built wetlands and wildlife sanctuaries fear devastation of their land, ponds and trees from acid rain caused by sulfur dioxide (emission from the Dirty Coal Plant proposed in Savoy Texas.)”

In addition to sulfur, people in Fannin and Grayson County are going to be exposed to 72,480,000,000 billion micrograms of Mercury a year (160 lbs). All of this Mercury is additive each year. Mercury affects fetal and infant brain development with resultant increase in Autism, attention deficit syndrome and loss of memory in adults. Maybe the increase in Alzheimer’s disease is secondary to the increase in pollution in the country.

“TXU said the plant will emit 3,787 tons(7,574,000 lbs.) of sulfur dioxide each year, less than current coal-fired plants and within the U.S. Environmental Protection Agency’s limits.”

The lowering of these toxic levels of Sulfur and the resulting conversion to sulfuric acid when reacting to the air have be stalled by the Bush Administration. The administration does not believe in the existence of acid rain or the global warming resulting from excess production of carbon dioxide. This belief is held in spite of the abundance evidence for it effect. Nitrogen effluent will produce 1894 tons per year (3,788,000 lbs.) resulting in increased production of ozone. The particulate matter from the Savoy Texas Dirty Coal Plants will be 1515 tons( 3,030,000 lbs) per year. How many of us think this is healthy for the kids of North Central Texans in general and Grayson and Fannin County residents in particular.

However we, the people of Texas, will be stuck with the high levels for the next 50 years long after this administration is gone. I thought people were wrong when they said these groups of government officials were not compassionate. They are not compassionate and they do not listen to the will of the people.

“When the judge found there were more than 40 people who live within 10 miles of the plant at the hearing asking for status as individuals, he said, “I am required by law to hold this hearing in a way to have an organized process for the development of the evidence that will focus on issues and that can be cross examined effectively. And there is simply no way we can have this many active participants prepare for this hearing and then formally participate in it.”

“With all due respect to everyone, you are working within the parameters you have to work in,” Feld said. “I can see that clearly. What has happened is there is something wrong with the system of parameters when local people didn’t know anything about it (the proposed coal plants) and haven’t been able to express their opinion. With the rules that have been set up, Texas Electric (the former name of part of TXU) has said ‘OK, let’s batch everyone together and make it quicker.’”

This was a very good move on TXU’s part. TXU would love to shut as many people up as they can. What is magical about 10 miles? What is so wrong with educating your neighbor about the risk we will permit in our neighborhood? Presently we get 70% of our electricity from Dirty Coal burning plants and right now we are the most polluted in the country with mercury.

Large area lakes in East Texas are already shut down already to fishing because of contamination with Mercury. We do not want Lake Texoma to be contaminated. TXU’s response is “Who said the contamination came from the Mercury produced by the Coal Plant.” Where does the Mercury come from?

“Sullivan reversed strategy and reconvened the hearing. He let all those interested in joining as individuals plead their cases.”

Maybe someone will get the point that the people want to be heard and we want the coal plant project stopped! Governor Perry seems not to be able to visualize that if we live in a polluted state no one will want to live here. TXU will not have a problem because they will sell the excess electricity on the national grid.

We the residents of Texas will suffer and the government will say it made a mistake. We have heard that before, haven’t we?

Stanley Feld M.D.,FACP,MACE

Thank you, Brad Feld for encouraging me to start this blog a year ago. I had no idea RSS was so powerful.

While at Columbia College C’59, we were required to take a course called Contemporary Civilizations. A big take home point was that we as citizens have an obligation to contemporary society and future generations.

We have an obligation to our health and the health of future generations. This is the reason it is so important everyone of us step up and protest TXU’s 18 Proposed Dirty Coal Plants for us presently, our children, and our children’s children.

About a week ago, Harry Jaeger, editor of Gas Turbine World, posted a comment on my blog.

Two days ago, I heard the TXU representative present to the People and the City Council of Savoy, Texas (ground zero for the Dirty Coal Plant) the same, as well as additional half truths, about how clean the Proposed Plant will be. He reported on how experimental and impractical IGCC plants are. I researched the half truths recited at the Bells City Council meeting and reported only on the Mercury issue at 160 lbs per year in a previous posting.

I wrote to Harry Jaeger asking about TXU’s assertions about gasification plants. Harry Jaeger’s answer is specific and is published below.

Harry Jaeger’s comment should help the Texas Cities Coalition for Clean Air get standing at the permit hearings on Thursday December 14. Twenty eight cities throughout Texas have banned together to slow the process down and get clean air for all Texans. They have been denied standing in the hearing to this point on a questionable technicality brought up by TXU.

His comments might help some of the city and county officials near ground zero understand the issue of IGCC plants a little better. Hopefully it will encourage them join the Coalition to get a seat at the table to protect their citizens health and healthcare cost. They also have an obligation to protect our recreation areas and Lake Texoma.

Dallas Business leaders just formed their own coalition against the permit process and the Dirty Coal Plants.

The Dallas Morning News asked for a moratorium on the permit process yesterday.

All that is required is Governor Rick Perry call off the fast track. He should learn about the issue of Dirty Coal Plants and their implications to the health of Texans. He should see how it contradicts his promise to the people of Texas.

I know he would be opposed to these Dirty Coal Plants and their threat to the health of Texans’ if he really understood the implications to health and the cost to the healthcare system.

Harry Jaegers comment is published in the preceeding post. “What is IGCC? Are They Practical?” Thank you Harry!

Comment:

Dr. Feld,

TXU is using the same arguments against considering the cleaner IGCC technology that have been used by all utilities who are hell-bent on getting their conventional coal plants built before they have to face up to tightening air quality regulations that may include limits on CO2 emissions.

The main claims are that IGCC is not reliable and that it costs much more than coventional coal.

We find that the boiler manufacturers, who are enjoying a heyday these days, are providing a lot of the fodder that feeds such arguments. This is quite understandable, as IGCC would cut into their market just when the world is turning back to coal, and large coal-fired steam power plants to meet the growing need for energy.

Regarding the reliability issue, I find it a travesty that those who reject IGCC as unproven and unreliable still refuse to look beyond the US borders for their data. There are several commercial IGCC projects operating in Europe that are exhibiting plant availability levels well above the US national average for conventional coal plants.

Granted, some of these plants are using refinery wastes, such as asphalt, but the difference between using coal and these feedstocks is not that significant from a reliability standpoint. After all, proponents of PC plants will tell you that coal preparation systems are very reliable.

Also, if one looks into the data, including that from the US plants, one will see that most of the past problems with IGCC plants were due to the turbine equipment and not with the gasification system.

Both US plants (Tampa and Wabash) used early versions of the same model gas turbine that had many reliabiiity issues all over the world – not just in the two IGCC plants.

In Europe, an IGCC plant in Spain used another advanced-design gas turbine that also was the cause of most of the plant outage time.

Meanwhile, there are three or four plants in Italy, and one in the Netherlands, that used a more proven gas turbine design and were able to reach very acceptable availability levels within two or three years of operation.

A new IGCC plant in Japan has apparently gotten over its initial “teething problems” in only one year, and is operating quite satisfactorily.

With this experience behind them, there are European and Japanese suppliers, as well as ones in the US, who would supply an IGCC plant, and who would apply lessons learned from these earlier plants to make new ones even better.

In addition, the construction schedule for an IGCC plant should not be any longer than that for a modern PC plant. So it is not clear that IGCC technolgy would have a problem with meeting the real rate of load growth being experienced on the TXU system.

If an IGCC plant can enjoy the same “fast track” permiting process as being allowed for the proposed PC plants, there is no reason why the first plant couldn’t be online in 2011.

As for the other principal argument used against IGCC, that is, its higher cost, the issue today is that costs of large construction projects are escalating so steeply that it seems to be anyone’s guess what these plants will really cost. In other words, if someone claims that IGCC will cost, say, 20% more than PC plants, that is well within the uncertainty seen in current construction estimating.

Besides, we have been seeing some estimates for new PC plants coming in higher than most IGCC plant cost estimates, and they continue to climb.

In this regards, there was a study completed recently by the Electric Power Research Institute (EPRI) that was sponsored by CPS of San Antonio. That study did find IGCC plants to result in higher cost of electricity, but when one looks into its details, we found some questionable underlying design assumptions, as specified by CPS, that were the cause of most of the cost difference.

If EPRI were to do the same study over again, restating these assumptions to put IGCC on a more level playing field, we think that the results would be quite different.

Unfortunately, in the case of TXU, there was no parallel plant cost study performed in order to obtain a fair comparison of the two technologies. In the case of CPS, the study was done post facto, so quite naturally it could be expected to support the decision that was already made to go with conventional coal burning technology.

I’d fear that any similar study done by TXU, perhaps as might be ordered by the courts now looking into their plans for a new fleet of PC plants, would suffer from the same problem.

Apparently there is a third problem with IGCC that is raised by TXU, that being the claim that there are no suppliers who would guarantee an IGCC plant using low rank coals.

I’ve attended several conferences where the gasifier suppliers all say that they have the ability to use such coals in their gasification process – perhaps at some loss of efficiency and economy – as is the case of a PC plant as well. Granted that the case for IGCC is hurt somewhat with the use of poorer coals, but it is not so much for technical reasons as for economic ones.

TXU should be reminded that the demonstration plant that operated for a number of years during the late ’80s and early ’90s at the Dow Chemical facility in Plaqumemine LA operated on a wide range of coals, and mostly on sub-bituminous. The same gasification process is now operating commercially at the Wabash plant in Indiana and is being offered by ConocoPhillips (Houston) who purchased the technology a few years ago.

At the Wabash plant, the gasifier is co-firing coal with petroleum coke, which enhances the performance of the process and greatly improves the economics.

I hope that this information is helpful to you and to those who are urging the use of IGCC instead of perpetuating the use of PC technology which, as you have shown, promises to leave a long legacy of much higher impact on the air quality of central Texas, and on the health of your citizens.

Harry Jaeger
Gasification Editor
Gas Turbine World Magazine