Selected category: Health

EPA's Pruitt Tries to Open a Loophole to Allow Super-Polluting Trucks on Our Roads

Have you ever seen a truck belching black soot as you drive on the highway and wondered, “isn’t that level of pollution illegal?”

We see less and less of that these days, thanks to common sense standards from the Environmental Protection Agency (EPA) that protect us from this harmful, excessive pollution.

But that progress is now at risk. The current EPA Administrator, Scott Pruitt, is trying to reopen a loophole that would allow the sale of super-polluting trucks that lack modern pollution controls.

The trucks in question are called “glider trucks.” They look new – but their engines are old and polluting. Anyone who likes to breathe air should be concerned.

Loophole would risk as many as thousands of lives a year

Pruitt’s proposed loophole would allow the sale of glider trucks – new trucks with old engines installed in them – without any modern pollution controls.

These super-polluting trucks emit harmful soot and smog-causing pollutants – including oxides of nitrogen, particulate matter, and cancer-causing diesel particulate – at a rate as much as forty times that of new engines. By 2025, glider trucks would comprise just five percent of the nation’s truck fleet, but they would cause one third of the air pollution.

Data that Pruitt’s own agency has collected shows that reopening the loophole could result in as many as 6,400 premature deaths by 2021 from oxides of nitrogen and particulate matter pollution. That assessment is actually conservative, as it doesn’t account for the health harms from cancer-causing diesel particulate pollution or from smog formation caused by these super-polluting trucks.

Benefiting the worst polluters at the expense of responsible companies

Pruitt’s action to reopen this loophole goes against the stated wishes of other truck manufacturers and dealers, who responsibly invested in pollution control equipment and depend on a level playing field for the well-being of their businesses and the Americans they employ.

For example, truck dealership Nuss Trucks commented that:

The original intent of selling gilder [trucks] has moved from a rebuilding mechanism to now mainly evading diesel emissions EPA mandates.

Volvo, the manufacturer of MAC Trucks, noted that the availability of “glider trucks” is creating:

an unlevel playing field for manufacturers of new vehicles designed and certified to be compliant to all current emissions, fuel efficiency, and safety regulations.

So why is Pruitt giving the glider industry special treatment over responsible trucking companies — and over the health of American families?

As recently reported by the Washington Post, Pruitt granted a glider industry request to reconsider the standards after a meeting with a major glider manufacturer in May.

That same manufacturer prominently hosted an event for Donald Trump early in his presidential campaign.

Super-polluting trucks are designed to evade pollution controls

Historically, only a few hundred glider trucks were sold each year. They were typically produced by truck repair shops when a customer wanted to salvage the undamaged engine from a wrecked truck by installing it into a new frame.

But after pollution limits on heavy-duty freight engines were updated in 2010, a small handful of companies recognized a loophole – an opportunity to sell old, dirty engines in new frames, and thereby evade modern pollution standards. The result was mass production of super-polluting trucks that do not come close to meeting current emission standards.

Glider truck manufacturers created a market that didn’t exist before 2010. They made a business out of sourcing large numbers of old, high-polluting engines to sell in new trucks, with sales likely surpassing 10,000 a year in the last few years. The pre-2002 engines they mainly use have essentially no air pollution controls, and cause the classic puff of black diesel smoke you hated to be stuck behind in traffic. (And with good reason, as diesel particulate is known to cause lung cancer.)

EPA took action in 2016 to close the loophole and bring glider truck sales back to pre-2010 levels.

The agency took pains to cause as little disruption as possible while still meeting its responsibility under the Clean Air Act to protect public health and welfare. It phased in the glider truck standards over a period of several years, and never outright banned the sale of glider vehicles (since it recognized the benefit to truckers in being able to salvage the engine from a damaged truck).

Under EPA’s common sense actions to close the loophole, beginning in 2018, glider manufacturers must cap production of high-polluting vehicles at 300 annually beginning in 2018. They may continue to produce additional glider vehicles as long as those meet the modern air pollution controls that all other manufacturers already have to meet.

A decision with devastating consequences for our health  

Pruitt announced his intent to revisit the just-closed loophole in August of this year. He has now released a new proposal to repeal emission requirements for these super-polluting trucks, indicating that he is moving forward with his regressive plan to reopen this loophole and put thousands of lives at risk.

Pruitt’s attempt to repeal these important safeguards reeks of political cronyism, and is being done at the expense of public health. Families and communities across America will be exposed to the dangerous pollution from thousands more of these dirty trucks on our highways. We all deserve better – especially from EPA, the agency with the core mission of protecting us from pollution.

Also posted in Cars and Pollution, Clean Air Act, News, Policy| Comments are closed

Why Honeycutt is such an alarming choice for EPA's science advisory panel

Michael Honeycutt – the man set to lead the U.S. Environmental Protection Agency’s prestigious Science Advisory Board – has spent most of his career as a credentialed counterpoint against almost anything the EPA has proposed to protect human health.

Fortunately, his lone voice for the Texas Commission on Environmental Quality rarely carried beyond the Lone Star State. Until now.

The EPA science advisory panel Honeycutt will chair is supposed to provide the agency with independent scientific expertise on a wide range of issues. In a highly unusual move, EPA Administrator Scott Pruitt picked the Texan for the job even though he has never been a member of the board.

More than Honeycutt’s inexperience, however, what worries me most is his faulty logic and what this means for science at the EPA.

Honeycutt downplays ozone dangers

A toxicologist by training, Honeycutt has criticized the EPA’s health-based standards for ozone because “most people spend more than 90 percent of their time indoors,” reducing their exposure to the ubiquitous pollutant.

Houston residents know differently. The city’s worst day for lung-damaging ozone this year happened while many people were outside for long hours of cleanup after Hurricane Harvey.

Honeycutt doubled-down on his position that ozone is not harmful to human health in a 2014 interview with the Texas Tribune.

“I haven’t seen the data that says lowering ozone will produce a health benefit,” he said. “In fact, I’ve seen data that shows it might have a negative health benefit.”

Honeycutt’s statement suggests he believes that more air pollution might actually be good for you.

…even though ozone can cause premature death

I am a toxicologist in Texas, too, and here is the truth about ozone: The pollutant can exacerbate asthma, lung disease and heart disease – and even lead to premature death.

The current acceptable limit, recommended during the George W. Bush administration and set under Obama’s in 2015, is 70 parts per billion, a standard that the public health community still believes is too high. The EPA’s own science advisors had recommended a limit as stringent as 60 ppb to protect human health.

Honeycutt spent millions to refute science

In his Texas role, Honeycutt responded to the recommendation by paying more than $2.6 million for research that says tighter ozone rules would cost the state billions of dollars annually with little or no impact on public health.

“Every part per billion that they don’t lower it is millions of dollars,” Honeycutt told the Houston Chronicle. “So we think that the return on investment in this is just phenomenal. Just phenomenal.”

And it’s not just ozone that seems to be a target for Honeycutt. He also has issues with protections against mercury, particulate matter and air toxics.

The reality is, however, that by failing to improve air quality, we’re paying more in health and social costs. This is real money lost on hospital visits, and on missed work and school days.

…and now he’ll steer EPA science

All this matters because Honeycutt, as the board’s chair, will help prioritize which issues the EPA decides to investigate and pick the scientists who review studies and reports before they come to the full board.

My worry is that he will continue down a path that is destructive to public health protections, a well-known pattern within the Trump administration.

We know that clean air and a strong economy go hand in hand – and that claims by industry doomsayers claims are unsubstantiated.

But none of that matters to an administration that scrubs qualified scientists from serving on advisory committees, that eradicates scientific data from websites that do not support the its agenda, and that does not want to be challenged.

Honeycutt’s appointment is yet another attack against science. With American health at stake, we can not stay silent about this latest EPA development.

This post originally appeared on our EDF Voices blog.

Image source: Source: Flickr/Science Democrats.

Also posted in Policy, Science| Comments are closed

Pruitt takes steps to remove science from decisions affecting the health of American families

Today EPA Administrator Scott Pruitt announced additions to the Agency’s Scientific Advisory Board (SAB) and the Clean Air Scientific Advisory Committee (CASAC). Taken in conjunction with the drastic policy shift also announced today, Pruitt is set to fundamentally undercut the role science in driving EPA decisions that directly affect the health and safety of American families and communities.

The new policy would exclude any scientist receiving an EPA grant from serving on any of the agency’s advisory panels. This creates a profound hypocrisy: under the policy scientists who take money from ExxonMobil or even Russia—since funding from other governments wouldn’t be disqualifying—Pruitt would regard as trusted to offer impartial advice. Meanwhile, those who have grants from the US environmental agency – whose research program was praised by the National Academy of Sciences in a report just this past summer – cannot.

In Pruitt’s Alice-in-Wonderland world, the EPA advisory panels intended to ensure the agency is making use of the best and latest science should be populated overwhelmingly by industry-affiliated scientists, at the expense of independent academic scientists.

Along with the policy, Pruitt’s new appointments to the SAB and CASAC (see a selection of the reported additions below) include longtime fossil fuel and chemical industry advocates, who have consistently played down or outright dismissed concerns about the risks of pollution or toxic chemical exposures based on discredited and outrageous scientific claims. Although the SAB is supposed to “provide independent advice and peer review on the scientific and technical aspects of environmental issues to the EPA's Administrator,” these additions cannot be relied upon to faithfully uphold the Board’s mission.

Meanwhile, Pruitt is also reportedly taking the unprecedented step of not renewing any appointments for members whose terms expire this year. This allows Pruitt to reshape the panel in his own image more quickly.

All told, the goal is as clear as it is concerning: to create a rubber-stamp set of scientific advisers that can distort the science while still lending an aura of credibility to Pruitt’s destructive actions at the Agency.

The real losers are not the researchers, but rather American families who depend on having an agency that actually works to protect their health.

Meet some of Mr. Pruitt’s new science advisers

Texas official with a long record of downplaying health concerns about pollutants and toxic chemicals ranging from ozone to benzene. Honeycutt argued against stronger ozone standards by noting most people spend their days indoors. He also claimed that “some studies even suggest that PM [particulate matter] makes you live longer.”

Denver-based consultant with long track record of conducting research that disputes the public health benefits of reducing air pollution. Cox has stated that there is “no evidence that reductions in air pollution levels have caused any reductions in mortality rates.”

Record of disputing the benefits of clean air and air pollution limits; said that “Modern air … is a little too clean for optimum health.”

Professor at NC State affiliated with the climate-denying Heartland Institute, who claims that the “evidence is overwhelming” that if temperatures do increase, it will be “better for humans.”

Former Secretary of North Carolina Department of Environmental Quality (NCDEQ), who questions the well-established scientific consensus of climate change and, had a controversial tenure at the agency, notably over health advisories to well owners whose water might have been contaminated by coal ash.

Smith is a Managing Director of NERA Economic Consulting and co-head of its environmental practice. In work funded by the fossil fuel industry trade group the American Petroleum Institute, Smith argued that EPA data on lung response to ozone is imprecise, roundly debunked by policy experts and independent fact-checkers.

Also posted in Basic Science of Global Warming, Science, Setting the Facts Straight| Comments are closed

EPA refuses to act on smog pollution. Here’s what’s at stake.

The Environmental Protection Agency (EPA) is refusing to move forward with the implementation of health-based standards that protect Americans from dangerous ground-level ozone pollution — more commonly known as smog.

That’s why Environmental Defense Fund, along with a broad coalition of public health and environmental groups, sent a letter to EPA Administrator Scott Pruitt informing him that we will take legal action if he does not carry out his mandatory duty to begin implementing our nation’s 2015 health-based smog standard.

Smog is a caustic pollutant that irritates the lungs, exacerbates lung conditions like asthma, and is linked to a wide-array of serious heart and lung diseases.

It is particularly harmful for children, seniors, people with lung impairments like asthma, and anyone active outdoors.

Under the Clean Air Act, October 1, 2017 was the deadline for identifying the communities that meet our nation’s health-based smog standard, and for identifying those that are violating the standard. Administrator Pruitt missed this mandatory deadline to begin implementing the smog safeguards.

The Clean Air Act’s statutory deadlines are not merely suggestions – they are of critical importance to achieving better air quality. When EPA shirks mandatory deadlines, the Clean Air Act’s mechanisms to improve air quality fail to engage and American families suffer the harmful effects of breathing polluted air for longer.

Administrator Pruitt unlawfully attempted to extend this same deadline, by one year, earlier this summer. However, he was forced to withdraw this extension and reinstate the October 1, 2017 deadline in response to legal challenges filed by EDF and our public health partners, and by a coalition of 16 state Attorneys General.

Now Pruitt has failed to meet the deadline – adding to his concerning pattern of delay, and undermining these important public health safeguards.

Here’s more on the consequences of ignoring our national health-based smog standards:

By delaying implementation of the standards, EPA is allowing vulnerable communities to suffer the consequences of polluted air while Administrator Pruitt stalls.

For instance, delaying the standards will mean that residents of the Uintah Basin in Northeastern Utah will potentially be faced with more and longer exposure to pollution levels that at times can rival smoggy Los Angeles.

This is truly unacceptable when there are clear solutions for reducing smog and protecting public health, such as reducing the pollution emitted from the thousands of oil and gas wells that dot the basin – common sense solutions that would be helped along if the 2015 health-based smog standard was properly and timely implemented.

Administrator Pruitt’s failure to identify which communities have air quality that violates the health standard obscures Americans’ basic right to know whether the very air we breathe meets the level that EPA has determined to be healthy.

The health-based national air quality standard for deadly air pollutants like smog form the foundation of the Clean Air Act — a bedrock public health statute that has provided for extraordinary, bipartisan progress in protecting Americans’ health and the environment for more than 40 years.

These consensus-backed health standards save lives and protect American families. By EPA’s own estimate, compliance with the 2015 smog standard will save hundreds of lives, prevent 230,000 asthma attacks in children, and prevent 160,000 missed school days for children each year.

Failure to carry out his responsibilities under our nation’s clean air laws also demonstrates Administrator Pruitt’s disregard for the recommendations of EPA’s own public health experts and scientists.

The 2015 health-based standard for smog was developed through a rigorous and extensive rulemaking process over the course of several years, and the science on smog’s health impacts is well-established.

EPA finalized a revised, strengthened standard of 70 parts per billion after engaging in a transparent, public process and relying on well-established scientific information and the recommendations of an independent committee of scientific advisors.

Administrator Pruitt has a legal duty to carry out the health standard to ensure healthier, longer lives for millions of Americans afflicted by dangerous smog pollution. That’s why EDF joined so many others in telling him we’ll go to court if he doesn’t.

Those joining us on the notice of intent to sue are the American Lung Association, American Public Health Association, American Thoracic Society, Appalachian Mountain Club, Earthjustice, Environmental Law & Policy Center, National Parks Conservation Association, Natural Resources Defense Council, Sierra Club and West Harlem Environmental Action.

The Attorneys General of New York, California, Connecticut, Delaware, Illinois, Iowa, Maine, Massachusetts, Minnesota, New Mexico, Oregon, Pennsylvania, Rhode Island, Vermont, Washington, and Washington D.C. sent a similar letter.

We urges Administrator Pruitt to “expeditiously” carry out his responsibility under our nation’s clean air law to protect the health of our families and communities. There is no time to waste.

Also posted in Clean Air Act, Partners for Change, Policy| Comments are closed

Yes, Administrator Pruitt, EPA does have the obligation to protect America from climate pollution

(This post was co-authored by EDF’s Ben Levitan)

The head of the Environmental Protection Agency (EPA) is once again misleading the American people in an effort to avoid doing his job.

EPA Administrator Scott Pruitt was interviewed on Fox News this week, and questioned his legal authority and responsibility to protect the public from the pollution that causes climate change.

During that interview, Pruitt asked:

[W]hat authority has Congress given the EPA to engage in rulemaking to reduce [carbon dioxide]?

Pruitt made similar remarks at the Heritage Foundation earlier this week – peddling the discredited notion that the “Clean Air Act was set up to address local and regional air pollutants, not the global phenomena of [climate pollution].”

We’ve written about this extensively at EDF. We’re happy to go over it one more time to help Administrator Pruitt, since he seems to be having trouble understanding it.

  • That authority is in the Clean Air Act, which is a law that was passed by Congress.
  • We know that authority is in the Clean Air Act because the Supreme Court told us so.
  • The Supreme Court then said so again – and again after that.

So to sum up, we’ve been told by the High Court three times that the authority is indeed in the law that was passed by Congress.

Pruitt’s remarks come just over a week after he signed a proposed rule to abolish the Clean Power Plan — America’s only nationwide limit on climate pollution from fossil fuel power plants.

EPA is legally obligated to protect Americans from harmful climate pollution, but Pruitt’s destructive proposal would leave American communities exposed to greater climate risks, and cost thousands of American lives by increasing dangerous air pollution.

Pruitt’s words on Fox News, and even more so his actions, are appalling. The official who is charged with administering our nation’s clean air laws for the benefit of the American people – laws that the Supreme Court has now held on three separate occasions clearly apply to pollutants that are driving destructive climate change – should not be questioning his basic job description.

Communities and families across the country are already feeling the impacts of climate change through stronger hurricanes, increased flooding, more damaging wildfires, rising sea levels, worsened air quality, and more intense heat waves. Americans overwhelmingly want swift action to address this clear and urgent threat – not Pruitt’s distortions and delay.

Here’s more detail about Pruitt’s legal responsibilities:

Contrary to Pruitt’s claims, the Supreme Court has repeatedly and unequivocally affirmed that Congress gave EPA authority to regulate climate pollution:

  • In Massachusetts v. EPA (549 U.S. 497, 2007), the Supreme Court found “without a doubt” that climate pollution falls within the broad definition of “air pollutants” covered by the Clean Air Act. The Court ordered EPA to make a science-based determination as to whether those pollutants endanger public health and welfare. EPA finalized its determination 2009. The U.S. Court of Appeals for the D.C. Circuit categorically rejected a barrage of legal challenges to the determination, including one brought by Scott Pruitt when he was attorney general of Oklahoma.
  • In American Electric Power v. Connecticut (564 U.S. 410, 2011), the Supreme Court unanimously held that the Clean Air Act “speaks directly” to the problem of climate pollution from power plants – a point that even opponents of the Clean Power Plan conceded at oral argument in the case.
  • In Utility Air Regulatory Group v. EPA (134 S. Ct. 2427, 2014), the Supreme Court held that the Clean Air Act obligated EPA to ensure that new and modified industrial facilities apply the best available control technology to reduce their emissions of carbon dioxide.

Scott Pruitt’s latest statement questioning EPA’s authority not only contradicts the rulings of the Supreme Court, it departs from the views of former EPA Administrators who have served in administrations of both political parties.

As Christine Todd Whitman, EPA Administrator under George W. Bush, put it:

I think, as a matter of law, that carbon is a pollutant has been settled.

Pruitt’s comments to Fox News also contradict his own previous statements to Congress. During his confirmation hearing to become EPA Administrator, Pruitt told United States Senators that the Supreme Court rulings were the “law of the land” and needed to be “enforced and respected.”

In the Fox News interview, Pruitt also took aim at the Clean Power Plan, repeating his false claim that the Supreme Court held the plan to be unlawful.

In fact, the Supreme Court never issued an opinion on the merits of the Clean Power Plan. It never even heard the case.

The Supreme Court simply put the Clean Power Plan on hold until legal challenges played out in the courts. And since then, Pruitt’s EPA has gone to extraordinary lengths to prevent any court from ruling on the legal merits of the Clean Power Plan.

Just as Pruitt glosses over Supreme Court precedent he doesn’t like, he also seems to have invented a Supreme Court ruling that he desires.

Pruitt’s continued claims that the Clean Power Plan is unlawful are also at odds with the views of leading legal experts – including the Attorneys General of eighteen states, former Republican Administrators of EPA under Presidents Nixon, Reagan, and Bush, and leading drafters of the Clean Air Act. They have all stood up in federal court to defend the fundamental legality of this vital climate and health safeguard.

Pruitt also took a moment in his interview with Fox News to question the health benefits associated with the Clean Power Plan – which include as many as 3,600 avoided deaths each year and thousands of avoided heart attacks and asthma attacks.

As many experts have documented, Pruitt’s EPA has deployed deceptive gimmicks to hide the consequences to human health of repealing the Clean Power Plan. Those gimmicks include assuming, contrary to the conclusions of the American Heart Association, the World Health Organization, the National Research Council, and EPA’s own scientific advisors, that there are zero benefits to reducing air pollution beyond certain levels.

Pruitt made those claims even though EPA acknowledged in its proposed repeal that the Clean Power Plan would achieve pollution reductions that would protect the health of our children.

This isn’t the first time Scott Pruitt has distorted the law and science in order to dismantle key climate and public health protections. Along with the Clean Power Plan, Pruitt has attacked pollution standards for oil and natural gas facilities, climate pollution standards for cars, and standards for heavy-duty trucks.

Americans should be outraged at Scott Pruitt’s repeated misleading statements on settled questions of law and science.

Also posted in Clean Air Act, Clean Power Plan, EPA litgation, News, Policy, Setting the Facts Straight| Comments are closed

Underhanded maneuvers to repeal the Clean Power Plan put Americans’ lives and health at risk

(EDF’s Ben Levitan co-authored this post)

Environmental Protection Agency (EPA) Administrator Scott Pruitt says he will sign a proposal tomorrow to repeal the Clean Power Plan – America’s only nationwide limits on carbon pollution from fossil fuel power plants.

If the proposal matches what we’ve already seen in a leaked draft, it would be one of the most deeply harmful and reckless actions an EPA Administrator has ever taken. It would cost thousands of American lives, harm public health in myriad other ways, and lead to years of costly delays in combating the urgent threat of climate change.

Administrator Pruitt would have to go to great lengths to obscure and ignore these harmful consequences. When EPA issued the Clean Power Plan in 2015, it estimated that the plan would create up to $54 billion in annual benefits, including:

  • The prevention of up to 3,600 premature deaths every year
  • The prevention of 90,000 childhood asthma attacks every year
  • The prevention of 300,000 missed school and work days every year.

By comparison, EPA concluded that the annual costs would be much lower. And in the two years since the Clean Power Plan was issued, new analyses – including this one from New York University’s Institute for Policy Integrity – have concluded that compliance with the Clean Power Plan has become dramatically cheaper as a result of the plummeting costs of clean energy.

Yet the draft proposal for repealing the Clean Power Plan seems to rely on a significantly higher costs estimate, and much lower benefits. How is that possible?

A careful look at the numbers shows that the Administrator Pruitt’s EPA cooked the books for this proposal. They used discredited methodologies to artificially inflate costs, and to mask the consequences for our climate and obscure the thousands of lives that could be lost as a result of their repeal of the Clean Power Plan.

Here are four tactics that Administrator Pruitt has employed in the leaked proposal to inflate the costs and hide the benefits of the Clean Power Plan:

1. Disregarding lives saved by the Clean Power Plan

EPA’s original analysis of the Clean Power Plan found that it would avoid thousands of premature deaths each year by reducing particulate matter pollution – yielding up to $34 billion in annual health benefits in 2030.

According to the American Lung Association, particulate matter pollution causes permanent damage to lung development in children, aggravates asthma and other respiratory problems, increases hospitalizations, and increases deaths from heart and lung diseases including lung cancer.

The Clean Power Plan would reduce exposure to this pollution across the country – avoiding these health harms and premature deaths.

Administrator Pruitt’s draft proposal assumes away those benefits by asserting – contrary to established medical research – that there is zero health impact from reducing particulate matter pollution below certain “threshold” levels. The proposal also suggests that EPA can count only the climate benefits associated with carbon pollution, with no consideration to any health benefits at all.

This claim that there is a “threshold” level of particulate pollution below which it does not harm human health is directly contradicted by the American Heart Association and was completely discredited many years ago by an expert panel convened by EPA under the George W. Bush Administration. It also runs contrary to EPA’s long-standing practice.

As EPA itself recently explained in a court brief:

The best scientific evidence, confirmed by independent, Congressionally-mandated expert panels, is that there is no threshold level of fine particulate pollution below which health reductions are not achieved by reducing exposure.

Ignoring the deaths and harm to Americans’ health that would result from repealing the Clean Power Plan is unconscionable. The plain truth is that undoing the Clean Power Plan would deprive Americans of billions of dollars in health benefits and put then at increased risk for premature death.

2. Artificially inflating the costs of the Clean Power Plan

EPA originally anticipated that parties would comply with the Clean Power Plan in part through investments in demand-side energy efficiency, “a highly cost-effective means” for reducing carbon pollution from the power sector.

Demand-side energy efficiency measures help consumers save electricity, resulting in lower electric bills for hard-working Americans, less pollution, and a more reliable electric grid. Investments in energy efficiency are largely offset by the electricity savings that result.

Yet the upside-down accounting in the draft proposal adds those energy efficiency investments to the costs of the Clean Power Plan without deducting the electricity savings those investments yield. This makes it look like the power sector is paying for both energy efficiency and the electricity that it no longer needs to produce. Therefore, this upside-down accounting includes billions of dollars of imaginary electricity costs – for electricity that will never be generated or purchased.

The draft proposal adds the cost of this imaginary electricity to its estimate of Clean Power Plan benefits — to represent the “benefit” of not having to purchase electricity that was never produced in the first place. When comparing costs and benefits, this imaginary electricity is a net wash ­– but it enables EPA to inflate its estimate of the plan’s costs by up to $19.3 billion in 2030.

The draft proposal also uses a higher discount rate of 7 percent for energy efficiency investments – providing no meaningful justification for a choice that further inflates costs by $6.2 billion.

The cumulative effects of adding the cost of imaginary electricity and using a higher discount rate increases costs by up to $25.5 billion in 2030.

3. Shortchanging the benefits of reducing carbon pollution

Administrator Pruitt’s proposal aggressively undercuts the social cost of carbon. That's the estimate of damages that climate pollution causes for our families and communities – from more intense hurricanes and heat waves, more wildfires, and the many other threats of climate change.

By using an unrealistically low figure, the proposal severely undervalues the benefits of the Clean Power Plan’s carbon reductions.

The original Clean Power Plan utilized an estimate of the social cost of carbon developed over many years by experts from a dozen federal agencies who used the best available science and repeatedly considered public input.

The draft proposal for repealing the Clean Power Plan has new, misleading values that use unsound methods rejected by independent experts to yield a lower estimate of the Plan’s benefits.

The draft proposal simply ignores important categories of carbon reduction benefits

The new proposal claims to count only the domestic U.S. impacts of carbon pollution, even though this pollution causes worldwide harm. A recent report by the National Academy of Sciences affirmed the importance of counting global benefits, explaining that the benefits of reducing carbon pollution would be dangerously undervalued if every country used a domestic-only social cost of carbon.

The draft proposal’s “domestic-only” cost estimate also ignores significant harms to the U.S. that arise from climate change impacts in other countries – including “global migration, economic destabilization, and political destabilization,” and “[l]ower economic growth in other regions [that] could reduce demand for U.S. exports, and lower productivity [that] could increase the prices of U.S. imports.”

For these reasons, the National Academy of Sciences concluded earlier this year that:

Climate damages to the United States cannot be accurately characterized without accounting for consequences outside U.S. borders.

Administrator Pruitt’s approach flies in the face of that expert advice.

The draft proposal short-changes our children by discounting pollution reduction benefits for future generations

The new proposal also uses a sharply lower value for the benefits that today’s carbon reductions provide to future generations.

The original Clean Power Plan “discounted” the future benefits of carbon reductions at a rate of three percent per year, based upon the findings of the inter-agency working group.

But the new proposal uses discount rates as high as seven percent, without any justification – a value that is much higher than recommended by the National Academy of Sciences or the economics literature.

The cumulative effects of ignoring global impacts and increasing the discount rate are dramatic. In the original Clean Power Plan, EPA estimated climate benefits of $20 billion in 2030 (using a three percent discount rate). The draft proposal to repeal the Clean Power Plan estimates climate benefits of just $0.5 billion in 2030.

Click to enlarge

 

4. Ignoring how low-cost clean energy means the Clean Power Plan will be even more affordable

In the two years since EPA finalized the Clean Power Plan, the plan’s goals have become even more achievable and low-cost than originally projected – thanks to electricity sector developments including the sharply declining costs of renewable energy.

But the new draft proposal has made no attempt to update its economic analysis, and does not appear to acknowledge that recent studies of the Clean Power Plan have found compliance costs are now much lower than EPA originally estimated.

Instead, Administrator Pruitt is proposing to repeal this life-saving, economically beneficial public health protection before even bothering to properly consider the latest data.

The recent report from the Institute for Policy Integrity highlights the falling costs of complying with the Clean Power Plan and points to several power sector developments that explain this trend.

The report presents several recent economic analyses conducted by independent, non-governmental entities that estimate substantially lower compliance costs than EPA projected in 2015. For instance, a June 2016 analysis by M.J. Bradley & Associates, using the same electric sector model as EPA but updating several inputs, finds that compliance would cost up to 84 percent less than EPA originally estimated.

EPA recognized and evaluated many of these precise studies as part of its Clean Power Plan deliberations. Yet for the sake of repealing the Clean Power Plan, Administrator Pruitt has decided to ignore these studies.

America deserves better

The Clean Power Plan is the most significant step the U.S. has ever taken to address the crisis of climate change. Once fully implemented, it will provide enormous public health benefits – making Americans safer, healthier, and more productive.

If Administrator Pruitt is intent on rolling back a life-saving protection for human health and the environment, the American people at least deserve an honest evaluation based on the best available data.

Unfortunately, it looks like he’s using underhanded maneuvers and deceptive accounting gimmicks to justify rescinding the Clean Power Plan instead – and the consequences for the health and safety of Americans will be all too real for decades to come.

Also posted in Clean Power Plan, Economics, Energy, News| Comments are closed
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