The Trump-Wheeler Polluting Power Plan: Five Key Takeaways

(Ben Levitan and Rama Zakaria co-authored this post)

The Trump Administration just released another proposal with a title that would floor George Orwell himself.

Less than a month after releasing the Safer and More Affordable Fuel Efficient Vehicles Rule to make our cars less safe and less fuel efficient, Trump and Acting EPA Administrator Andrew Wheeler unveiled the Affordable Clean Energy proposal – a plan that is neither clean nor affordable.

This new Trump-Wheeler proposal, ostensibly a replacement for the Clean Power Plan, is actually a major retreat from securing clean and affordable energy for Americans. It would subject our nation to more soot and smog and would vastly increase climate pollution – harming our health in the near term and exacerbating climate damage for generations to come.

Here are five things you should know:

1. The Trump-Wheeler plan would increase pollution and cost American lives.

EPA’s own numbers show the Trump-Wheeler proposal could lead to more than 1,000 annual premature deaths in 2030, compared to leaving the Clean Power Plan in place.

EPA map showing concentrations of additional premature deaths from soot and smog, compared to America under the Clean Power Plan. The areas in red will suffer most. See the Regulatory Impact Analysis, page 4-39.

It could also cause tens of thousands of childhood asthma attacks and more than 100,000 missed school and work days annually.

In 2030, the annual increase in health-harming pollution from the Trump-Wheeler proposal (compared to the Clean Power Plan) would be:

• Up to 72,000 tons of sulfur dioxide, which contributes to dangerous soot pollution
• Up to 53,000 tons of nitrogen oxides, which play a major role in smog formation

The Trump-Wheeler proposal sows confusion by presenting multiple estimates of deaths from harmful particulate matter, including several that are based on the assumption that particulate matter has no health impacts below certain levels. This assumption flies in the face of a vast body of scientific evidence showing that there is no level below which particulate matter is known to be safe. EPA’s misleading figures would disregard hundreds of American deaths per year.

2. The Trump-Wheeler plan senselessly excludes the most cost-effective pollution-reduction techniques.

The Clean Power Plan recognized the wide range of highly cost-effective clean energy measures that power companies are already using to reduce pollution.

Clean, affordable energy options like wind and solar energy are already spurring a dramatic transformation in the power sector, employing millions of Americans nationwide and creating jobs at a faster rate than any other industrial sector. In public comments submitted in February 2018, a major power company — drawing on its experiences in Iowa, Nevada, and elsewhere — expressly asked EPA to consider opportunities to utilize cleaner generation when setting pollution limits for a Clean Power Plan replacement.

• The Trump-Wheeler proposal irrationally ignores those widely available measures. Instead, the proposal requires that states consider setting standards based on a narrow set of tweaks to the operating efficiency of coal-fired power plants, called “heat rate improvement” measures. In the Clean Power Plan, EPA recognized that these measures would achieve minimal pollution reduction on their own and might perversely incentivize coal plants to increase their operations – leading to more climate and health-harming pollution.
• The Trump-Wheeler proposal relies on a rigid new interpretation of the Clean Air Act, which it claims would prevent EPA from considering time-tested, cost-effective pollution reduction measures like shifting generation to cleaner sources and switching to cleaner fuels. The proposal purports to be “returning” to a traditional interpretation – but is actually proposing a dangerous new interpretation that would imperil human lives, children’s health, and climate security.

3. The “Affordable Clean Energy” rule clearly isn’t clean. It’s also not affordable.

EPA’s own estimates show that, compared to the Clean Power Plan, the Trump-Wheeler plan would impose up to $10.8 billion in annual net costs on Americans in 2030, when accounting for compliance costs and the loss of the Clean Power Plan’s benefits for climate and public health.

By contrast, the Clean Power Plan was designed to save consumers hard-earned money on electric bills.

By pairing more protective pollution targets with incentives for energy efficiency, the Clean Power Plan would have saved the average ratepayer around $85 per year by 2030 — and provided greater climate and health protections for American families. The Trump-Wheeler plan would have none of these benefits.

4. The Trump-Wheeler plan sets no quantitative limits on climate pollution.

The Trump-Wheeler proposal contains no quantitative limits on climate pollution, and is not designed to achieve any particular level of pollution reduction by any particular date.

• The proposal merely lists a set of heat rate improvement measures that would modestly improve the operating efficiency of coal-fired power plants.
• The proposal would leave it to the states to determine which — if any — of those tweaks apply to specific power plants, and set source-specific pollution rates accordingly.
• EPA’s own analysis of the proposal shows that, compared to the Clean Power Plan, the Trump-Wheeler plan would increase carbon pollution by up to 103 million short tons annually by 2030.
• The proposal’s minimal requirements apply only to coal-fired power plants, and provide no framework whatsoever for limiting climate pollution from natural gas-fired power plants.

5. The Trump-Wheeler plan willfully ignores most of the harms of climate pollution.

The Trump-Wheeler proposal drastically undercounts the real costs of climate pollution for all Americans.

• Climate pollution has worldwide impacts, but the proposal counts only those impacts that are expected to occur within U.S. borders.
• If every country acknowledged only the harm that its climate pollution inflicted within its own borders, then no country would reduce pollution in an amount sufficient to avoid catastrophic climate change.
• EPA’s blinkered approach also ignores the ways in which the adverse and potentially destabilizing impacts of climate change around the world can imperil America’s own national security and economic prosperity. Any proposal to address climate pollution should fully account for these impacts.