Author Archives: Susanne Brooks

In Win for Environment, Court Recognizes Social Cost of Carbon

Co-authored with Martha Roberts

If someone was tallying up all the benefits of energy efficiency programs, you’d want them to include reducing climate pollution, right? That’s just common sense.

Thankfully, that’s what our government does when it designs energy efficiency programs—as well as other policies that impact greenhouse gas emissions. And just this month, this approach got an important seal of approval: For the first time, a federal court upheld using the social cost of carbon to inform vital protections against the harmful impacts of climate change.

So what is the social cost of carbon and why does it matter? It’s a crucial part of the development of climate safeguards and essential to our understanding of the full costs of climate pollution. We know that climate change is a clear and present danger now and for future generations—one that will result in enormous costs to our economy, human health and the environment. And yet, these “social” costs are not accounted for in our markets, and therefore in decision making. It is a classic Economics 101 market failure. Every ton of carbon dioxide pollution that is emitted when we burn fossil fuels to light our homes or drive our cars has a cost associated with it, a hidden one that is additional to what we pay on our utility bills or at the gas pump. These costs affect us all – and future generations – and are a result of the negative impacts of climate change. If we don’t recognize these hidden costs—we aren’t properly protecting ourselves against the dangers of climate pollution.

The social cost of carbon (or SCC) is an estimate of the total economic harm associated with emitting one additional ton of carbon dioxide pollution into the atmosphere. To reach the current estimate, several federal agencies came together to determine the range and central price point – roughly $40 per ton – through a transparent and rigorous interagency process that was based on the latest peer-reviewed science and economics available, and which allowed for repeated public comments.

It’s critical that we protect against the damages and costs caused by climate pollution. So it’s a no-brainer that when considering the costs and benefits of climate safeguards, we must take into account all benefits and costs – and that means including the social cost of carbon.

In their court opinion, the Federal Court of Appeals for the Seventh Circuit agreed wholeheartedly. Harvard Law Professor Cass Sunstein noted that their decision “upholds a foundation” of “countless” climate protections. In particular, their opinion made two important findings:

  • First, the court affirmed that the DOE was correct to include a value for the social cost of carbon in its analysis. The judges concluded that “[w]e have no doubt” that Congress intended for DOE to have authority to consider the social cost of carbon. Importantly, this conclusion reinforces the appropriateness of including the SCC in future carbon-related rule-makings.
  • Second, the court upheld key choices about how the SCC estimate was calculated. The court agreed that DOE properly considered all impacts of climate change, even those years from now, or outside our borders. These choices, the court concluded, were reasonable and appropriate given the nature of the climate crisis we face.

DOE itself acknowledged “limitations in the SCC estimates.” We couldn’t agree more. As new and better information about the impacts of climate change becomes available and as our ability to translate this science into economic impacts improves, regulators must update the current social cost of carbon estimate. There is still much we do not know about the full magnitude of climate impacts and much that cannot be quantified (as is true of all economic impact analysis) – which means that SCC estimates are likely far lower than the true impact of climate change. But as the Seventh Circuit recognized, their inclusion is a vital step in the right direction for sensible policy-making.

This decision already has positive implications more broadly—in particular, for the Clean Power Plan, our nation’s historic program to reduce carbon pollution from power plants. Just last week, EPA submitted a letter in the Clean Power Plan litigation noting that the Seventh Circuit’s decision further demonstrates the error of challenges to the treatment of costs and benefits in the Clean Power Plan rulemaking. It’s just another affirmation of the rock-solid legal and technical foundation for the Clean Power Plan.

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Capping Pollution from Coast to Coast

As the second auction in California’s landmark cap and trade program approaches, a coalition of states on the opposite side of the country – that have been cost-effectively reducing their carbon pollution while saving their consumers money – announced plans to strengthen their emission reduction goals.  Last week, the Regional Greenhouse Gas Initiative (RGGI) – the nation’s first cap and trade program which sets a cap on carbon dioxide pollution from the electric power sector in 9 Northeastern states (Connecticut, Delaware, Maine, Maryland, Massachusetts, New Hampshire, New York, Rhode Island, and Vermont) – released an updated Model Rule containing a number of improvements to the program, primarily a significantly lower (by 45%) overall cap, realigning it with current emissions levels.

Since the program took effect in 2009, emission reductions in the RGGI region have occurred faster and at lower cost than originally expected.  This has primarily been the result of increased electric generation from natural gas and renewables which have displaced more carbon-intensive sources like coal and oil, as well as investments in energy efficiency that lower overall electricity demand.  These reductions have been accompanied by lower electricity prices in the region (down 10% since the program began) and significant economic benefits:  a study from the Analysis Group estimated that electric consumers would save $1.1 billion on their bills over 10 years from the energy efficiency improvements funded by allowance revenue, and further, that these savings would generate over $1.6 billion in economic benefits for the region.

The new lower cap allows RGGI to secure the reductions already achieved, and push forward towards more ambitious pollution reduction goals.  The changes to the program are the result of a transparent and comprehensive program review process set in motion through RGGI’s original Memorandum of Understanding – a mechanism that is successfully fulfilling its original intention by allowing the states to evaluate results and make critical improvements.

While the changes will go a long way to fortify the program, there is room in the future for the RGGI states to look to California’s strong program design for additional enhancements.  For example, RGGI’s updated Model Rule creates a Cost Containment Reserve (CCR) – a fixed quantity of allowances which are made available for sale if allowance prices exceed predefined “trigger prices”.  A CCR is a smart design feature which provides additional flexibility and cost containment – however, RGGI’s CCR allowances are designed to be additional to the cap, rather than carved out from underneath it as in CA’s program (ensuring the overall emission reduction goals will be met).  California’s program has displayed enormous success already, with a strong showing in their first auction.

In the meantime, the RGGI states should be commended for their success thus far, and for their renewed leadership as they take important steps to strengthen the program.  These states have achieved significant reductions in emissions of heat-trapping pollutants at lower costs than originally projected, all while saving their citizens money and stimulating their economies, transitioning their power sector towards cleaner, safer generation sources, and laying a strong foundation for compliance with the Carbon Pollution Standards for power plants being developed under the Clean Air Act.  Such impressive achievements provide a powerful, concrete example of how to tackle harmful carbon pollution and capture the important co-benefits of doing so.

The bottom line is that cap and trade is alive and well on both coasts as the states continue to lead the charge on tackling climate change in the U.S. while delivering clear economic benefits.

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More Evidence That the Benefits of EPA Rules Vastly Outweigh the Costs

This blog was originally posted on EDF's Climate 411 blog.

Yet another study is confirming what we’ve known for quite some time — the benefits of EPA’s clean air rules vastly outweigh the costs.

An analysis from the Economic Policy Institute (EPI) reinforces what other studies have told us time and time again: clean air is a great economic investment.

Unfortunately, that fact is often lost in the unfounded attacks on EPA that have gotten so much attention lately, in the media and even in Congress.

EPI’s analysis examines the combined effect of EPA rules that have already been finalized under the Obama Administration, as well as those currently in the proposal stage. It finds that:

The dollar value of the benefits of the major rules finalized or proposed by the EPA so far during the Obama administration exceeds the rules’ costs by an exceptionally wide margin. Health benefits in terms of lives saved and illnesses avoided will be enormous.

Of course, the most important benefits of clean air are those related to human health. Just three of these rules (Cross-State Air Pollution (CSAPR), Mercury and Air Toxics, and Boiler MACT) are estimated to save up to 57,500 lives a year.

Those lives saved, plus illnesses avoided and other environmental improvements translate to enormous economic benefits:

  • Setting aside CSAPR, the combined annual benefits from all final major rules exceed their costs by $10 billion to $95 billion a year. The estimated benefit-to-cost ratios for those final rules range from 2-to-1 to 20-to-1.
  • The net benefits from CSAPR range from $112 billion to $289 billion a year.
  • The combined annual benefits from three major proposed rules exceed their costs by $62 billion to $188 billion a year. The estimated benefit-to-cost ratios for those proposed rules range from 6-to-1 to 15-to-1

The results are even more striking in chart form:

(For more details on EPI’s analysis, see our new fact sheet.)

EPI has also shown, in a previous analysis, that EPA clean air rules can also have a positive impact on overall employment – including 28,000 to 158,000 jobs from the Mercury and Air Toxics rule for power plants alone.

In fact, Josh Bivens of EPI recently testified before the U.S. House of Representatives on the Mercury and Air Toxics rule for power plants. He said:

Calls to delay implementation of the rule based on vague appeals to wider economic weakness have the case entirely backward – there is no better time than now, from a job-creation perspective, to move forward with these rules.

It’s time for everyone – and especially Congress — to recognize that EPA rules are not only good for our health, but also our economy.

For more on how cleaner air can save lives, improve health, and help our economy, see the following previous EDF blog posts:  “Thank You, EPA,” “The Clean Air Act Amendments: Good for Our Health AND Our Economy,” and “Newsflash: Clean Air Act saves lives, boosts GDP.”

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It Makes Dollars & “Sense” To Capture Air Emissions

This blog was originally posted on EDF's Energy Exchange blog.

Oil and gas exploration and production is rapidly expanding across the U.S. due to technological developments that have made extraction of previously untapped unconventional resources such as shale gas feasible.

In fact, shale gas production “has gone from a negligible amount just a few years ago to being almost 30% of total U.S. natural gas production.”

But national clean air standards covering these activities have not been updated since 1985 in one case and 1999 in another. They are limited, inadequate, and out of date, particularly given recent technological advances in this area.

This poses a serious problem, since exploration and production activities emit numerous hazardous air pollutants and other airborne contaminants that threaten human health and the environment. Communities across the country are paying the price, suffering from air pollution in the absence of protective, comprehensive standards.

In July, the Environmental Protection Agency (EPA) proposed new nationwide safeguards to reduce air pollution from upstream oil and gas production activities. Recently, the public was given a chance to express their opinions on the issue at three hearings held in Pittsburgh, Pennsylvania, Denver, Colorado, and Arlington, Texas. EDF testified at all three. (Public written comments will be accepted through November 30th and EPA is required to issue a final rule by February 2012. You can submit comments online, via fax or through the mail. In your correspondence, please be sure to reference Docket Number EPA–HQ–OAR–2010–0505; FRL–9456–2.)

I testified at the EPA hearing in Pittsburgh where compelling concerns were raised by many in the communities hard hit by air pollution impacts. People in communities across Pennsylvania expressed concern that adequate protection from dangerous pollution in their home state is simply not in place. Some pleaded with the EPA to finalize new standards, others expressed anger that EPA has not done so already, and many fear that the new standards won’t be tough enough to keep their families safe.

The individual who testified before me declared that when it comes to our health and that of our children, the costs of cleaning up harmful pollution should not factor into EPA’s decision-making. He got a standing ovation.

Of course, the hearing also featured industry representatives, some of whom echoed the position of the American Petroleum Institute (API) calling for more time to comment on the proposed standards and to delay their implementation.

Yet, the truth is that the proposed EPA rules will standardize many practices and technologies already being used in states such as Colorado and Wyoming, and elsewhere by natural gas companies. Further, these practices and technologies reduce gas losses, which results in greater recovery and sale of natural gas, and thus increased economic gains. The return on the initial investment for many of these practices is sometimes as short as a few months and almost always less than two years. In these tough economic times, it would seem wise to eliminate waste, save money, and reduce environmental impact.

Based on EPA estimates of natural gas losses, industry lost more than $1 billion in profits in 2009 due to venting, flaring and fugitive emissions. The U.S. Government Accountability Office (GAO), with supporting data from EPA, estimates that around 40% of natural gas estimated to be vented and flared on onshore federal leases could be economically captured with currently available control technologies. Recouping these losses could increase federal royalty payments by $23 million annually, at a time when revenue is desperately needed.

The industry can demonstrate their commitment to bringing natural gas to market in an environmentally sound way by using best practices, acknowledging the benefits of these safeguards, and being proactive in helping them get adopted.

And, while EPA’s proposed rules are a great start, there is room for improvement (for more details, see EDF’s preliminary analysis of the regulations). Bottom line: it is critical that stronger clean air standards move forward. They are vitally important to protect human health and the environment.

At the EPA hearing in Pittsburgh, the public demanded that EPA require industry to be more vigilant about health and safety, and reduce their environmental impact. Considering the potential increased revenue of capturing more gas, advocating for strong clean air rules makes both dollars and “sense.”

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Thank You, EPA

Given that EPA is in the midst of finalizing some of the most critical regulation protecting American human health from poisonous air pollution, one might think that a simple “thank you” might be in order.

Instead, EPA is facing unfounded attacks from several angles – one of the most egregious from Steve Milloy in a recent Washington Times op-ed in which he asked the agency to “show him the bodies” of victims of air pollution.

The evidence linking air pollution to adverse human health impacts including mortality is substantial.  Recently, Michael Livermore, executive director of the Institute for Policy Integrity at New York University School of Law, released an excellent response that easily rips Milloy’s arguments to shreds:

“Questioning these health concerns means countering a substantial body of empirical health studies, conducted both by federal agencies and by independent researchers. These studies, which have been subjected to the scrutiny of the peer review process, have come to a set of well-supported conclusions about the relationship between particulate matter and mortality …”

Livermore points to specific research, including that of the National Research Council (reviewed by a range of independent bodies) and other peer-reviewed studies that back up the EPA’s analysis.

Lynn Goldman, Dean and Professor at the George Washington University School of Public Health and Health Services and a member of EDF's Board of Trustees, also responded to Milloy’s baseless assertions in a recent Letter to the Editor in the Washington Times:

“As a research scientist, I know that volumes of medical science document the harm air pollution does to the human body, and that the scientific community has concluded air pollution causes disease and death …”

She refers to the family members who can actually point to the bodies of loved ones who “dropped dead from a heart attack after breathing too much air on a Code Red day” and to the children she has treated as a pediatrician suffering from asthma attacks. And the problem of air pollution is widespread — according to the American Lung Association, about half of all Americans live in areas with unhealthy levels of ozone or particulate matter.

Similar to Milloy, Texas Republican Rep. Joe Barton has also questioned the science behind EPA’s analyses, but additionally questioned their economic assessment of the value of the benefits resulting from EPA’s regulation.  Referring to the monetized value of avoiding premature death from air pollution, Barton said that he doesn’t trust EPA’s assumptions and wants someone to check them.

In fact, EPA’s assumption about the value of avoiding premature death (known as the Value of a Statistical Life, or VSL) represents the most credible, scientifically sound, and peer-reviewed figure available.  The VSL measures how much people are willing to pay for small reductions in the risk of mortality, and is often estimated by looking at how much you have to pay someone to take a more dangerous job.  The EPA uses an average value across 26 studies estimating the VSL published between 1974 and 1991 – a value of $6.3 million (in 2000 dollars) that has been vetted and endorsed by the Science Advisory Board (SAB).

Although the idea of placing a value on human life can be controversial, the main thing to remember is that regulations reducing harmful air pollution will save lives, and it is crucial that these benefits are captured when undertaking economic analyses – EPA’s methodology for doing so is based on years of careful, peer-reviewed study, and its credibility is widely acknowledged.

As New York University researcher, Scott Holladay, pointed out in a recent blog post, “what the EPA is able to value, it does in the most rigorous, academically defensible manner.”

The conclusion is that cleaner air will save lives, improve the health of Americans across the country, and is a great investment for our economy – thank you, EPA.

For more on how cleaner air can save lives, improve health, and help our economy, see the Moms Clean Air Force website and a previous EDF blog post on the overwhelming benefits of the Clean Air Act Amendments.

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The Clean Air Act Amendments: Good for Our Health AND Our Economy

The Clean Air Act and its amendments prevent millions of premature deaths, significantly reduce illnesses, and save trillions of dollars for American families. But those in Congress who are working to stall EPA actions still claim that Clean Air Act regulations are too costly. Fortunately there's some new and conclusive evidence to show that they're wrong.

The EPA's just-released cost-benefit analysis of the 1990 Clean Air Act Amendments leaves no room for argument:  we simply cannot afford a world without regulations on the harmful pollution that the Clean Air Act is designed to fight.

This comes as no surprise. The Clean Air Act has been saving lives, improving the health of American children, and saving us trillions of dollars for years now. But this report is a new and definitive confirmation of just how critical this law is to the health of the American people — and to our economy.

EPA sets the gold standard in economic modeling with this report. It provides an excellent, no-nonsense analysis of both the costs of complying with the Clean Air Act Amendments and the benefits. Benefits are the clear winner. From 1990 to 2020, they manifest in the form of avoided premature deaths, reduction in illnesses and associated health care costs, and improved ecological and welfare impacts (like increased agricultural yields and better visibility conditions).

The report finds that, at the central estimate, and after taking costs into account, the net benefits of the Clean Air Act Amendments are $12 trillion in present value. Yes, that's TRILLION.

The report also finds that the benefits of the Clean Air Act outweigh the costs by a factor of more than 30 to one. Let me say that again: 30 to one. And that's a more modest estimate; the report's high benefits estimate exceeds costs by 90 times.

These estimates don’t even account for some benefits that are more difficult to monetize, such as health effects from air toxics, and chronic respiratory diseases other than chronic bronchitis. They also don't include the pain and suffering associated with illnesses, so the benefits estimate should be seen as conservative.

Let’s look at one of the most important results: health impacts. Last year alone, the Clean Air Act Amendments saved more than 160,000 lives, prevented more than 85,000 emergency room visits, prevented millions of cases of respiratory problems (including bronchitis and asthma), enhanced productivity by preventing 13 million lost workdays, and prevented 3.2 million lost school days (just to name a few of the benefits).

In the year 2020, the Clean Air Act Amendments are projected to prevent more than 230,000 early deaths and provide benefits reaching approximately $2 trillion. All of which makes it mind-boggling that opponents in Congress continue to push back against this successful law.

The enormous benefits of the Clean Air Act are nothing new. EPA’s earlier cost-benefit analysis of the law, from the years 1970 to 1990, showed that the net benefits in present value over the period were nearly $22 trillion, and that the benefits outweighed the costs by 40 to one.

Here's more good news:  protecting children from neurotoxins now will give us workers with higher IQs later — and that's something that also turns out to come with real economic benefits. The latest study by Harvard's Dale Jorgenson and his co-authors shows that the Clean Air Act has boosted productivity and growth: Gross Domestic Product in 2010 is up to 1.5% higher than it would have been without the Clean Air Act.

The bottom line is that the Clean Air Act and its Amendments have left Americans enormously better off – in terms of health, productivity, and economic growth. Why stop now?

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