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Category — CO2 Power Plant Rule

EPA Overlook: Improved Health & Welfare from Greenhouse Gas Emissions

“The [EPA] Proposal ignores the obvious association between increased GHG emissions and positive health and welfare benefits. GHG emissions and improving quality of life are associated because the economy runs on energy, and that energy is principally derived from fossil fuels.”

Several detailed and extensive comments were submitted to the U.S. Environmental Protection Agency (EPA) regarding their proposed Standards of Performance for Greenhouse Gas Emissions for New Stationary Sources: Electric Utility Generating Units documenting new and influential science that the EPA did not assess when issuing the proposed standards. Instead, EPA simply deferred to their Endangerment Finding that they issued in December 2009.

As yesterday’s post pointed out, a lot is new in the rapidly evolving field of climate (change) science, and thus the EPA Endangerment Finding is getting a bit stale—or should I say becoming “endangered.” A reassessment is sorely in order. After all, how long can you base new regulations on old science?

Here, I examine another aspect of the issue that was largely overlooked by the EPA—the benefits (not only costs) of manmade greenhouse gas (GHG) emissions. Several commentors point to the good to the public health and welfare that came about as a result of human greenhouse gas emissions—or more specifically, the energy whose production gave rise to the GHG emissions.

One such commentor was Peabody Energy Company, the world’s largest private-sector coal company and a “leader in sustainable mining and clean coal solutions.” Peabody wanted to make darn sure that the EPA recognized not only that access to fossil-fuel produced energy that improved peoples’ lives, but also that limiting access to it, as proposed by the EPA, would result in negative consequences to public health and welfare—the very thing that the EPA’s regulations were crafted to avoid.

Here I excerpt the section from Peabody Energy Company’s rather extensive comment to the EPA in which they lay out the basics for how GHG emissions are associated with public health benefits rather than impairment as concluded by the EPA. Couple these with other positive externalities from carbon dioxide and modest GHG-induced climate change, and it isn’t hard to see why the EPA’s 2009 Endangerment Finding is out of date and out of touch. [Read more →]

July 13, 2012   5 Comments

New Science Endangers EPA’s “Endangerment Finding”

“If the EPA were to have done that with the regulations being proposed here … it is quite likely that their original Endangerment Finding would have to be revised and potentially overturned.”

The public comment period for the U.S. Environmental Protection Agency’s (EPA) proposed Standards of Performance for Greenhouse Gas Emissions for New Stationary Sources: Electric Utility Generating Units closed on June 25, 2012. A number of extensive comments were submitted arguing that the basis of the Endangerment Finding—that human greenhouse gas emissions (GHGs) “threaten the public health and welfare of current and future generations”—has become so outdated as to require a thorough re-assessment.

Strong cases were made that the EPA failed to completely consider new and influential scientific results which have a direct relevance to the impact that climate change as a result of human greenhouse gas emissions may have on the public health and welfare. Overwhelmingly, the “missing” science from the EPA’s support documents included evidence that either lessened the certainty that human GHG emissions were behind the observed changes in the climate, or provided examples of positive impacts resulting from climate change on human health and welfare.

It is a recipe for pure waste and unintented consequences if EPA continues to propose regulations based upon static, even outdated, science in a field where the scientific knowledge-base is rapidly evolving. In his public comment to the EPA, the Cato Institute’s Dr. Patrick Michaels neatly described this situation: [Read more →]

July 12, 2012   5 Comments

Pandora’s NAAQS: CEI Comments on U.S. EPA’s ‘Carbon Pollution Standard’

“Some good may yet come of this. A policy crisis over NAAQS regulation of  man-made greenhouse gas would finally make clear that Massachusetts v. EPA created a constitutional crisis by authorizing the EPA to enact policies that the people’s representatives have not approved and would reject if proposed in legislation and put to a vote.”

Yesterday, June 25, 2012, I submitted the following comment on the U.S. Environmental Protection Agency’s Standards of Performance for Greenhouse Gas Emissions for New Stationary Sources: Electric Utility Generating Units, what EPA ideologically describes as the Carbon Pollution Rule. [1]

On behalf of the Competitive Enterprise Institute (CEI), a non-profit public policy group specializing in regulatory issues, I ask that EPA withdraw the Proposed Rule on the following four grounds:

1. The EPA’s proposal would effectively ban construction of new coal-fired power plants, a policy Congress has not approved and would reject if proposed in legislation and put to a vote.

2. The proposal is an underhanded ‘bait-and-fuel-switch.’ The EPA assured stakeholders in March 2011 that it would not redefine source categories to require fuel-switching from coal to natural gas. Had the EPA come clean about its agenda in 2010 and 2011, Senators Murkowski and Inhofe would likely have garnered more support for their efforts to overturn the agency’s greenhouse gas regulations.

3. The proposal relies on weird contortions – a consequence of the EPA’s attempt to use the Clean Air Act as a framework for regulating greenhouse gases, a purpose for which the Act was neither designed nor intended. For example, the EPA pretends that natural gas combined cycle – a type of power plant – is a “control option” and “system of emission reduction” that has been “adequately demonstrated” for coal-fired power plants.

4. The proposal will provide another precedent for establishing National Ambient Air Quality Standards for greenhouse gases, taking America one step closer to policy disaster.

I. Introduction

The proposed rule requires new fossil-fuel electric generating units (EGUs) to emit no more than 1,000 lbs of carbon dioxide (CO2) per megawatt hour (MWh). About 95% of all natural gas combined cycle power plants already meet the standard, according to the EPA.[2] No existing coal power plants come close; even the most efficient, on average, emit 1,800 lbs CO2/MWh.[3] [Read more →]

June 26, 2012   6 Comments

EPA’s Proposed CO2 Rule for New Power Plants: Coal First, Then …

While campaigning in San Francisco in early 2008 during the Democratic primaries, Barack Obama got a little too candid.  “So if somebody wants to build a coal-powered plant, they can,” he opined to the San Francisco Chronicle editorial board. “It’s just that it will bankrupt them because they’re going to be charged a huge sum for all that greenhouse gas that’s being emitted.”

Waxman-Markey: Never Forget

Elected, President Obama tried to keep his promise by way of the American Clean Energy and Security Act of 2009 (aka Waxman-Markey, H.R. 2454), which narrowly passed the House in June 2009 by a vote of 219 to 212.

Among the many features in the 1,437-page bill, cap-and-trade of carbon dioxide (CO2) emissions was designed to price (cap-and-tax, to critics) and thus reduce such emissions down to 17 percent of the 2005 level by 2050.

Per capita CO2 emissions were last at this level around the end of the U.S. Civil War.

There was considerable outcry against the Waxman-Markey Bill when the House recessed that August, and leaders of the Senate decided not to consider the bill. After November 2010 election losses, Democrat Senate leaders told President Obama cap-and-trade was dead. President Obama responded by saying that “cap-and-trade was just one way of skinning the cat.” [Read more →]

April 10, 2012   9 Comments