Category Archives: Clean Air Act

Uncovering the Real Cost of Carbon

(This post was co-authored by Thomas Sterner and appeared first on EDF Voices.)

Last week, the Obama administration released new energy efficiency standards for microwaves, along with an update to the government’s official Social Cost of Carbon (SCC) figure. What do those two things have to do with each other? Well, the efficiency standards will help the planet by cutting the energy needs of microwaves, which will in turn save consumers money. And the new SCC numbers show just how expensive our addiction to fossil fuels has become.

The SCC is used to estimate the damages from carbon emissions (and the benefits from reducing those emissions) for the purposes of regulatory benefit-cost analyses. The central estimate for the SCC is now around $35 per ton of carbon dioxide pollution emitted today.

That’s the administration’s estimate of the damage—to human health, ecosystems, and the economy—caused by every ton of carbon dioxide emitted into the atmosphere. The average American emits about 20 tons each year.

The new cost of carbon figure is a welcome step forward, reflecting the latest versions of the underlying models. The bad news is that the increased number also shows that our lack of a comprehensive climate policy is becoming ever more costly.

Moreover, this updated SCC number underestimates the true costs of carbon emissions. For example, the current SCC quickly rises to $55 per ton under a lower discount rate (that is, an estimate that doesn’t “discount” harms to the wealth and health of future generations by quite as much as the administration did in reaching its $35 per ton figure).

The value of one ton of carbon dioxide would rise higher still with a declining discount rate, something that, in line with the general consensus among economists, would more closely reflect the true costs of climate change. And none of that includes the cost of extreme climate events.

Basing Policy on Science

The good news: the administration’s latest numbers show exactly how policy analysis should be done—rigorously and consistent with the latest advances in science and economics. For example, instead of using older versions of three main SCC models to calculate its official number, the administration now uses the most recent peer-reviewed versions of each. That simple but important step helps to bring the new official SCC more in line with the latest academic literature.

In short, the administration’s economics are slowly and carefully catching up with what we all can see outside our windows. While atmospheric carbon dioxide levels have just passed the 400 parts per million threshold for the first time in over 3 million years, the real costs of climate change keep piling on.

What the country really needs, of course, is for Congress to pass a comprehensive climate policy. Only then will Americans stop living in a world where their personal behavior leads to socialized costs of at least $35 for each of the 20 tons of carbon dioxide we emit every year. Until then, the Obama administration is right to at least include these costs in its own regulatory impact assessments.

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Benefits of Clean Air and Water Dwarf Costs 10 to 1

(This post was first published on EDF Voices.)

The Office of Management and Budget is nerd heaven: a bunch of people getting their professional kicks from analyzing federal regulation. This bean counting may sound painfully lacking in glamour, but it’s incredibly important. OMB’s annual report to Congress on the benefits and costs of all major rules adopted by most federal agencies over the past 10 years shows how efficiently, or inefficiently, those agencies are functioning.  And the conclusion is clear: the Environmental Protection Agency comes out on top.

 

Source: OMB’s “Draft 2013 Report to Congress on the Benefits and Costs of Federal Regulations"

These numbers are based on the 2013 draft report, so they could still change. But the pattern is the same as in any of theirreports from the past few years, including the final 2012 report that came out last week.

None of this is to diminish the contributions of the other government agencies, but if you are a do-gooder trying to achieve the greatest good for the greatest number of people, EPA is the place to be.

One of the driving forces behind this rule is the Mercury and Air Toxics Standards, an extraordinary achievement for clean air and public health. Because of these standards, all coal fired power plants will for the first time be required to control their emissions of toxic air pollutants — including mercury, arsenic and acid gases. Forty years after the Clean Air Act signed by Richard Nixon, twenty after the landmark Amendments signed by George H.W. Bush, we are finally getting around to regulating mercury from burning coal.

The analysis of the benefits of reducing mercury pollution demonstrates just how much we underestimate the benefits of environmental protections. For example, when it comes to reducing mercury pollution, the benefits are based on EPA’s estimates of increased wages of (higher IQ) children born to families that catch freshwater fish for their own consumption.

Think about that one for a second. Mercury is a potent neurotoxin in all its forms, but the EPA estimates do not include mercury that is inhaled or that enters our bodies through other means. And there is nothing in the estimates about the fact that mercury harms the brains of our kids, regardless of whether it influences their future earning potential.

In a sense, this analysis is the moral equivalent of arguing that we should have child labor laws because keeping kids in school makes for more productive workers later on. This kind of reasoning, alas, is  why economists are often called names unfit for a family-friendly blog. It’s the most reductionist argument you can find in favor of reducing mercury. (In fact, the bulk of the benefits that were quantified by EPA are due to inextricably connected benefits in reducing deleterious particulate pollution.)

Costs, by the way, are relatively well estimated, since businesses are all-too willing to share them. So yes, there are costs—but they are small relative to benefits. And costs, as opposed to benefits, are typically overestimates. They are largely based on current available control technologies. They don’t consider that industry may invent an entirely new and unexpected way of complying with regulations at lower cost. This happens over and over again, and it comes with a name: entrepreneurial ingenuity. Works every time.

These omissions and shortcomings on either side of the equation only stand to bolster the most important claim: benefits outweigh costs more than 10 to 1 for all major EPA regulations adopted in the past decade.

For every dollar invested, Americans get $10 worth of benefits. I’ll take that ratio any day.

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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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Nature: The rebound effect is overplayed

Trying to put the rebound effect for energy efficiency in its rightful place is like playing a game of wack-a-mole. Predictably every couple of years, someone new discovers the counter-intuitive appeal of showing how more efficient energy policies may lead to more energy use. Wham! Told you there's something wrong with those clean-car standards. Well, not so fast.

Yes, the rebound effect is real. But it's also small. And what's there is actually positive! Why shouldn't people who can now afford to due to more efficient energy technologies be able to improve their lives?

Together with three co-authors (Ken Gillingham at Yale, Dave Rapson at University of California, Davis, and Matt Kotchen, currently on leave from Yale to serve as Deputy Assistant Secretary for Environment and Energy at the U.S. Treasury), I surveyed a bajillion+1 energy efficiency rebound studies. Nature then made us cut down those references to 6. We settled at 9.

We couldn't find a single study that has the rebound be above 100% or anything close to it, what's necessary to nix energy efficiency savings. The maximum number you can get is 60%, and that's already quite a stretch. Think 30% as the upper bound for actual behavioral responses. Yes, we are more efficient today than we were a hundred years ago, and we also use more energy today. But that's far from talking about the rebound effect. It's simply economic growth.

Establishing a causal link between efficiency and energy use isn't quite as simple. In the end, the rebound effect comes in four forms. Buy a more fuel-efficient car, and driving that next mile just became cheaper. The result: a bit more driving, to the tune of 5 to a maximum of 30%, although most likely much closer to 5-10% of the initial fuel savings. Then there's the indirect effect: Drivers may now use some of the savings to buy other products that consume energy.

You can already see that we can't just add these two effects. If you spend some of the gas money on driving more, you have less to spend on that plane ticket, and vice versa.

Then there are two macroeconomic effects: one via the price and one via technological advances. They are the trickiest to pin down and could, in theory, be the largest. But theory lends a helping hand in getting an upper bound: the basic demand-and-supply relationship tells us that the macroeconomic price effect can't be more than 100%.

And once again, all these effects aren't anywhere near that threshold. 60% is as high as it gets for the combined effect, and only in rare circumstances. For the most part, it's much closer to 5 to perhaps 30%.

So where does that leave us?

When designing energy efficiency policies like clean-car standards, consider the rebound effect, much like the government already does. The Department of Energy's model uses a highly appropriate 10% rebound figure for the car standards. And that's about it. Not much else to see here.

If you did want to take it a step further — full disclosure: a step I couldn't convince my three co-authors to take in the Nature piece itself — everything else equal, the existence of the rebound effect may prompt us to use even stricter energy efficiency standards. If you have an overall target in mind, and the rebound effect shaves off a bit, you ought to consider using a slightly stricter target to get back to where you wanted to be.

For more, check out the full Nature piece. Well worth the $32 to put the rebound effect in its rightful place once and for all.

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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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