Climate 411

An outpouring of support for clean car standards, in the face of Pruitt’s attempted rollback

By Martha Roberts / Published: April 6, 2018

Cars on a dealer lot, waiting to be sold. Photo: Every Car Listed

(EDF Legal Fellow Erin Murphy co-authored this post)

EPA Administrator Scott Pruitt just announced his intention to rollback one of our country’s biggest climate success stories – clean car standards that reduce pollution and save Americans money at the pump.

In a closed-door ceremony, Pruitt kicked off a process to weaken these standards — placing at risk as much as two billion tons of climate pollution reductions and $460 billion in consumer savings.

His determination cited the auto industry dozens of times yet made no mention of people’s health or climate change, and cited zero EPA analyses justifying the rollback.

Even some auto industry leaders have raised concerns about this attack:

  • Honda: “We didn’t ask for that,” said Robert Bienenfeld, assistant vice president in charge of environment and energy strategy. “The position we outlined was sensible.”
  • Ford: “We support increasing clean car standards through 2025 and are not asking for a rollback.”
  • Adam Lee, chairman of Lee Auto Malls: “Trump has been saying these standards are crushing the auto industry. But we’ve had record years for the past four or five years, in terms of sales and profit. It almost makes you think he doesn’t have the facts.”
  • Automotive Technology Leadership Group: “It is in the nation’s best interest for the U.S. to continue leading in the development and manufacture of the cleanest and most efficient vehicles in the world. The innovation brought on by competition and our national performance standards has created hundreds of thousands of jobs in this country and significant market opportunities for U.S. companies abroad.”

Pruitt’s announcement has even generated a backlash in the most auto-industry-friendly place in America – Detroit.

In a strongly-worded editorial, the Detroit Free Press accused auto companies of reneging on their deal with the American taxpayer:

  • “[T]he auto bailout was more than a federally guaranteed loan; it was a multi-lateral agreement that your companies would henceforth go about the business of manufacturing cars and trucks more thoughtfully than they had in the past … [M]anufacturing more fuel-efficient vehicles that would cost less to operate and spew a dramatically smaller amount of greenhouse gases into the atmosphere was part of the bargain that saved your lives.” – Detroit Free Press editorial

The clean car standards have strong public support across the country. A recent American Lung Association poll showed that nearly seven in 10 voters want EPA to leave current fuel efficiency standards in place.

That support is reflected in the broad outpouring of support for clean cars expressed in the run up to, and aftermath of, Pruitt’s rollback announcement. A diverse group of leaders recognizes that weakening these protections will cost Americans money, hurt our health, and harm our national security:

  • “Thanks to emissions and efficiency standards, consumers have saved billions of dollars on fuel over the last 5 years. And if the standards were protected instead of undermined, consumers could expect to save a lot more over the next decade. It would be wasteful to discard those consumer savings, but EPA now appears poised to do just that.” – Shannon Baker-Branstetter, Consumers Union
  • “The American Lung Association strongly opposes EPA Administrator Scott Pruitt’s decision to revise the clean car standards … Transportation is the nation’s single largest contributor of carbon pollution, which drives climate change. Starting a process to weaken clean car standards marks yet another step backward from the fight to curb climate change. Climate change poses serious threats to millions of people, especially to some of the most vulnerable Americans, including children, older adults and those living with chronic diseases such as asthma.” – American Lung Association CEO Harold Wimmer
  • “Weakening CAFE and reducing future U.S. net oil exports will further diminish the future global energy leverage of the United States and leave the country and its allies on a more precarious footing.” – Council on Foreign Relations blog, 3/13/18

Political leaders across the country have voiced strong bipartisan support for the existing clean car standards:

  • “Today’s EPA decision on vehicle emissions won’t prevent us from fulfilling what we believe is an obligation to protect Colorado’s air and the health of our citizens. Many of our auto manufacturers are making cars cleaner and more efficient. Indeed, many support the existing stricter standards. It doesn’t make sense that the EPA would take us backwards. Who is the EPA trying to protect?” – Colorado Governor John Hickenlooper:
  • “As U.S. attorneys general, mayors and county executives, we – not federal officials in Washington, D.C. – are primarily responsible for the transportation systems upon which our residents and our local and regional economies depend. A clean, efficient and high-performance vehicle fleet is an essential component of these systems. We strongly support the current federal standards for such a modern vehicle fleet agreed to in 2012 by the automotive industry, the federal government and the State of California.” – A Coalition of 12 State Attorneys General and Over Fifty Mayors
  • “Today’s announcement by EPA Administrator Pruitt to weaken vehicle emissions standards is in direct conflict with the agency’s mandate to reduce air pollution. This decision will increase air pollution and limit innovative technology advancements that bring cleaner, more efficient cars to market. We support the current federal standards agreed to in 2012 by the automotive industry, the federal government, and the State of California.  These standards are helping to drive the global transition to more efficient transportation technologies. They also protect the health of our communities and reduce the pollution that is changing our climate.” – 17 Governors of states across the country and Puerto Rico

Labor and investment experts have also recognized that the clean car standards are essential for long-term American auto sector innovation, vitality, and jobs:

  • “The current standards have helped bring back, secure, and create jobs nationwide; they have reduced pollution; saved consumers billions at the pump; and have been integral to growing and sustaining America’s manufacturing sector over the past decade. Weakening the rules — which is indicated to be the intent of today’s decision — could put American jobs at risk today and in coming years, and would threaten America’s competitiveness in manufacturing critical technology.” – BlueGreen Alliance Director of Advanced Vehicles and Transportation, Zoe Lipman
  • “Strong national fuel economy and emissions standards spur innovation and open the door to tremendous economic opportunities. They represent an investment in technological and economic leadership. Weakening them would be a bad deal for investors, workers, car owners, and businesses—and for the American economy itself.” -­ David Richardson, Impax Asset Management
Also posted in Cars and Pollution, Clean Air Act, Greenhouse Gas Emissions, Health, Jobs, News, Partners for Change, Policy, Pruitt, What Others are Saying / Comments are closed

Are there roadblocks ahead for America’s clean cars standards? Here are five things you need to know

By Martha Roberts / Published: March 29, 2018

Cars wait to be sold on a dealer’s lot. Photo: Every Car Listed

(EDF Legal Fellow Erin Murphy co-authored this post)

America’s clean cars standards are one of our biggest climate success stories.

We’ve made major strides in reducing greenhouse gas pollution since protective standards were put in place in 2012 – spurring fuel efficiency gains at the same time.

New innovations have made additional progress even more clearly achievable – and have set the stage for a future free from tailpipe pollution.

Yet, when it comes to cars, the Trump administration is stuck in reverse.

President Trump is reportedly considering a dramatic rollback of our existing clean cars standards. Right now, an EPA action to set this reversal in motion is under White House review.

Ford broke ranks earlier this week, publicly disavowing a rollback of these climate pollution protections.

Yet it’s rumored that EPA Administrator Scott Pruitt will issue a decision as early as Friday that would set in motion a potentially dramatic weakening of these safeguards. It’s time for policy-makers and automakers like GM, Chrysler, Honda and Toyota to take a stand and reject these baseless attacks.

Here’s what you need to know:

  1. Climate progress in the balance

Tremendous climate progress is at stake.

EPA estimated that the clean cars program would reduce climate pollution by six billion tons over its lifetime and cut other dangerous air pollutants as well. That’s how much climate pollution America emits in a year, from all sources and all sectors.

The American Lung Association and twelve other public health organizations have all underscored the importance of maintaining protective clean cars standards.

The transportation sector has become America’s largest contributor of climate pollution. It is also a significant source of harmful soot and smog-causing pollution.

Now is the time to accelerate reductions from this sector, not stall out. Yet leaked details suggest the Trump administration is moving to significantly weaken upcoming standards for cars in model years 2022 to 2025 – eroding the benefits of the standards by almost 60 percent.

  1. Savings every time you fuel up

Clean cars standards are a win-win – in addition to reducing pollution, they save consumers money at the gas pump.

This program gradually reduces climate pollution rates from cars and trucks – driving five percent reductions each year through flexible fleet-wide standards and spurring comparable year-by-year improvements in fuel efficiency.

Drivers are already benefiting from our existing standards. For example, each Ford F-150 truck bought in 2015 uses about 180 fewer gallons of gas a year than prior models. That saves its owner eight trips to the gas station and up to $700 per year, depending on the price of fuel.

The standards will bring even greater savings in the future. Families that purchase a new car or truck in 2025 will save an estimated $1,650 over the lifetime of that vehicle, compared to a car just three years older.

Over the lifetime of the clean cars program, the savings to American families and businesses will add up to more than a trillion dollars.

The 86 percent of Americans who finance their car with a five-year loan are expected to immediately realize the cost savings from cleaner, more efficient vehicles. This is true even with lower gas prices.

  1. We have the know-how to exceed these standards

The improvements under the existing clean cars standards are technically feasible and affordable.

Automakers and suppliers are developing and deploying innovative technologies faster than anticipated when the standards were finalized.

EPA, the Department of Transportation, and the California Air Resources Board conducted an exhaustive technical review of the auto industry’s ability to meet the 2022 to 2025 model year standards. They found extensive evidence that the automotive industry can meet those standards at lower costs than predicted when the standards were initially finalized in 2012.

Since the clean cars program began in 2012, there has been roughly a doubling in the number of SUVs that achieve 25 miles per gallon or more, the number of cars that achieve 30 miles per gallon or more, and the number of cars that achieve 40 miles per gallon or more.

Today there are already more than 100 car, SUV, and pickup models on the market that meet standards set for 2020 and beyond.

If any changes are made, the standards should be strengthened.

  1. Supporting American jobs and innovation now and into the future

Well-designed federal standards foster the deployment of fuel saving solutions.

We have seen this cycle play out over the past several years, as automakers have brought more efficient cars and trucks to market with record sales and strong profitability.

Today, the auto industry directly employs millions of Americans and employment at auto dealerships is at its highest level ever.

Automakers have recognized this strong financial performance in recent annual reports:

  •  “[Fiat Chrysler] posted another record performance in 2017, achieving ambitious financial targets … We have now reached or exceeded all key financial goals for the first four years of the current five-year plan.”  Fiat Chrysler 2017 Annual Report, Chairman’s Letter
  • “2016 was the best year in its history of more than 130 years.” Daimler 2016 Annual Report, Chairman’s Letter
  • “2016 was a very strong year for General Motors, one that included the launch of dozens of award-winning products around the world, record sales and earnings, substantial return of capital to shareholders and remarkable progress in our drive to define and lead the future of personal mobility. In North America, we achieved record earnings last year and exceeded our 10-percent-margin goal for the second consecutive year.” General Motors 2016 Annual Report, Chairman’s Letter

In a 2016 letter supporting EPA’s proposal to reaffirm the clean cars standards, the United Automobile Workers (UAW) noted:

  • “UAW members know firsthand that Corporate Average Fuel Economy (CAFE) and greenhouse gas (GHG) standards have spurred investments in new products that employ tens of thousands of our members.”

Other countries – including China, the world’s largest new vehicle market — are pushing toward a zero-emissions future. U.S. automakers can’t afford to fall behind.

Protective clean car standards spur investment that will preserve and increase automakers’ global competitiveness.

  1. State leadership at risk

Over the last half century, state leadership has played a key role in spurring the development and deployment of clean car solutions like smog-fighting catalytic converters.

Administrator Pruitt recently made aggressive public statements smearing this success story and suggesting that the Trump administration’s coming attack may even seek to stifle these state-led programs.

Under long-standing provisions in the Clean Air Act, California is authorized to set its own vehicle pollution standards, and all other states have authority to adopt and enforce these standards. Today a third of U.S. new car sales are covered by the coalition of states that have committed to protective clean car standards.

In Ford’s public comments this week, the company recognized this history and committed to working together with California to build a path forward. Yet Administrator Pruitt’s irresponsible comments suggest he is reviewing an existing waiver that allows for implementation of this state success story — and may be considering revoking this waiver, even though such a step has never been taken and has no basis in law.

Pruitt’s comments show a clear disregard for his professed concern for states’ rights.

The takeaway? We need to move forward, not shift into reverse

Unfortunately, it’s no surprise that the Trump administration is set to roll back these protections — just as they’ve relentlessly attacked so many other common sense pollution standards.

EDF will defend the progress we’ve made cleaning up pollution from our cars, and we’ll push for even more progress. We hope all Americans will join us in defense of these crucial safeguards.

  • Policymakers at all levels need to stand against these rollbacks and advance clean cars through the myriad of avenues available to them.
  • Automakers need to make clear that they stand for common sense standards that spur continued progress on clean vehicles today and continued movement towards a future without tailpipe pollution.
  • Individual citizens need to push back against these reckless cuts.

The climate and health protections contained in the clean car standards are critical, well-founded, and eminently achievable. We will be fighting to keep them whole.

Also posted in Cars and Pollution, Greenhouse Gas Emissions, Jobs, News, Policy / Comments are closed

Still cheaper than coal – a report on the economics of solar power in Colorado

By Rama Zakaria / Published: March 26, 2018

Workers install solar panels on a building in Superior, Colorado. Photo: SolarDave.com

(EDF’s Graham McCahan co-authored this post)

A newly-updated report is shedding light on what President Trump’s solar trade tariffs may mean for one state – and underscoring a tremendous opportunity to move forward toward clean energy, with all the benefits it can bring.

Xcel Energy filed its 30-day bid report update with the Colorado Public Utilities Commission on March 1. The update follows Xcel’s filing at the end of last year, in response to an “all-source solicitation,” as part of its Electric Resource Plan and its proposed Colorado Energy Plan.

Xcel’s plan would shut down two units at the Comanche coal plant in Pueblo, Colorado, and replace the capacity with a mix of lower carbon resources. Earlier results were unprecedented, with more than 80 percent of the bids coming from renewable energy and storage at incredibly cheap prices.

Xcel then provided bidders an opportunity to refresh their bids following President Trump’s final decision in the Suniva/SolarWorld trade case in January, which imposed tariffs on imported solar equipment.

The refreshed bids in Xcel’s updated report show minimal change relative to last year’s results and confirm that new wind and solar power in Colorado continues to be cheaper than existing coal plants – despite the trade tariffs.

According to the report, Xcel “received bid affirmation and refresh responses from all but one of the 400 plus bids.”

Of these responses:

“58% of the bids affirmed no change in pricing, 16% increased pricing, and 26% decreased pricing.”

The solar photovoltaic (PV) median bid price increased by only $1.5 per megawatt hour, and the median bid for solar PV with battery storage increased by $2.3 per megawatt hour – still the cheapest solar plus storage bids in the U.S. to date.

Based on analysis by Carbon Tracker, this means that the median bid price for solar is lower than the operating cost of all existing coal units in Colorado, while the median solar plus storage bid is lower than roughly 70 percent of operating coal capacity.

Federal renewable energy tax credits are likely buffering some of the solar trade tariff effects. While recent analyses show significant cost declines for renewable energy, with wind and solar becoming increasingly competitive with conventional generation even on an unsubsidized basis, the renewable tax credits are still a significant factor contributing to favorable wind and solar economics in the short-term and in the face of the Trump solar tariffs. That said, it’s important to recognize that coal generation has enjoyed state and federal incentives for a century, and continues to do so.

The tax credits are being phased down in the next few years, with the production tax credit for wind phasing out in 2019 and the investment tax credit for solar in 2021. So it will be critical to act now to take advantage of those credits to deploy clean energy at lowest cost and secure the associated economic and public health benefits.

Colorado is an example of this tremendous opportunity to move forward now to lock in incredibly low-cost resources, with no fuel costs and therefore no medium- to long-term volatility or risk to consumers. The Xcel bids show that there is a lower-cost clean energy alternative to keeping the polluting Comanche units online in Pueblo, and it no longer makes sense to continue to operate and maintain these units at the expense of Colorado customers and Colorado air quality.

There is even the potential for low-cost utility-scale on-site solar to be used by Evraz Rocky Mountain Steel – a steel mill and the single largest manufacturer in Pueblo and largest producer of premium rail in North America – to help cut costs and keep manufacturing jobs in Pueblo.

Evraz is Xcel’s largest retail customer in Colorado, and the 175-200 megawatt Evraz solar project that the company is considering would provide a cost-effective option to meet Evraz’s growing needs, help guarantee Evraz low and stable electricity rates in the future, and therefore help keep Evraz in Colorado.

We are already witnessing some of the impacts of Trump’s solar tariffs on jobs in some areas of the U.S., and the potential for these tariffs to stall American competitiveness and innovation – for instance, American solar company SunPower recently announced that it will lay off hundreds of workers, largely from its research and development and marketing positions.

But the Xcel refresh bids in Colorado – a state blessed with high solar and wind potential – provides an important first look at what the solar tariffs mean for the competitiveness of clean energy in a state where clean energy conditions are favorable.

In Colorado, it is clear that the advantages of clean energy for consumers and the local economy remain compelling. Despite the tariffs – and in the presence of renewable tax credits, rapid technological advances, and plummeting costs of solar and storage technologies – solar still outcompetes fossil fuels. It also helps lower costs to consumers, and protects local manufacturing jobs.

The state should act now to lock in those benefits for the people of Colorado.

Also posted in Energy, Policy / Comments are closed

Leadership: The auto industry’s missing ingredient

By Jason Mathers / Published: January 16, 2018

The automotive industry’s capacity for innovation and marketing are on full display this month. Between the Consumer Electronic Show and the North American International Auto Show, every day brings a new story about the rapid development of vehicle technology. The industry possesses the know-how and ability to deliver on the zero-emissions future if it wants to.

A Ford at an electric car charging station in Buffalo, NY. Photo by Fortunate4now

Behind the headlines of engineering feats and product plans, though, is a disturbing fact. The industry is undermining its own innovation. It’s doing this through a campaign to dramatically weaken the central tool we have to move cleaner technology into the fleet – protective greenhouse gas reduction and fuel efficiency standards for new cars and passenger trucks.

Well-designed federal standards foster the deployment of fuel saving solutions. With the certainty of long-term standards in place, manufacturers are able to make the necessary investments to scale these solutions into the fleet. Scaled production further drives down costs, enhancing automaker profitability and consumer payback.

This cycle has been in full view over the past several years as automakers have brought to market ever more efficient vehicles with record sales and strong profitability. An exhaustive technical analysis completed by the U.S. Environmental Protection Agency, National Highway Traffic Safety Administration and California Air Resources Board found that automakers were well positioned to deliver even more fuel efficiency and emissions progress in the years ahead.

With this robust technical underpinning, the U.S. Environmental Protection Agency (EPA) issued a determination to maintain the existing 2022 to 2025 standards. Back in 2012, EPA finalized these standards with the broad support of the automotive industry. But fast forward to today, and the automotive industry is pushing for the Trump Administration to reconsider this determination.

This has set up a year of incongruity where the industry’s position that the standards need to be re-examined are consistently contradicted by its product announcements. In just this past year, automakers have made the following announcements:

  • Daimler AG announced a billion dollar investment to build electric vehicles in the U.S. with production starting in the early 2020’s.
  • BMW reached 100,000 in global electric vehicle sales while promising a dozen models of electric vehicles by 2025.
  • Toyota committed to having at least 10 models of all-electric vehicles by the early 2020’s.
  • Mazda promoted an engine breakthrough that could improve efficiency by up to 30 percent, and is planning to deploy the new engine in 2019.
  • GM laid out a bold vision for a “zero crashes, zero emissions, and zero congestion” future, announced plans for 20 new electric vehicles by 2023 – including two by 2019, and rolled out the acclaimed Chevy Bolt across the U.S.
  • Ford publicized its intention to have an electric vehicle with a range of 300 miles on the market by 2020.

These are not public announcements most automakers make lightly. They make them with high confidence in their ability to meet them.

As amazing as these announcements are, none of them are even necessary to meet the vehicle greenhouse gas standards that EPA finalized in 2012 and affirmed last year. The industry is already poised to meet these standards with broader adoption of more conventional technologies.

The impressive innovation in advanced engine design and electrification – which the industry clearly believes will start to scale over the next few years – will make the standards even more attainable.

Yet, despite the remarkable recent record of innovation and the significant investments made in developing a new generation of clean vehicle solutions, the automotive industry – through its trade associations – has chosen a path to weaken our existing emissions standards and has stayed silent as EPA Administrator Scott Pruitt has threatened California’s own protective vehicle emission standards.

The industry’s actions are contradictory and concerning. Yet, there is still time for automakers to choose a different path – one that looks to the future and seeks to build a new round of protective standards that rewards the industry’s innovation, lowers costs for families and protects human health and the environment.

As the announcements are made over the coming days, we should also be listening to hear if any automakers are willing to match their record on innovation with what the industry most needs now – leadership.

Also posted in Cars and Pollution, Greenhouse Gas Emissions, News, Policy / Read 1 Response

Trump Administration misleads Americans about the cost of climate pollution

By Susanne Brooks / Published: October 25, 2017

The Trump Administration is attempting to justify the rollback of crucial environmental and health protections by vastly undervaluing the costs of climate change.

The latest safeguards under attack are the Clean Power Plan, the nation’s first-ever limits on carbon pollution from existing power plants, and the Bureau of Land Management’s vital standards to reduce wasted natural gas from oil and gas facilities on public and tribal lands. They would have health, environmental, and economic benefits worth an estimated billions of dollars annually. But you wouldn’t know it from reading the Administration’s recently revised documents – because of a series of deceptive accounting tricks, including efforts aimed at obscuring the benefits of reducing carbon pollution.

The Trump Administration has used discredited methods to eviscerate the social cost of carbon — an estimate of the costs that carbon pollution inflicts on the public, represented as the dollar value of the total damages from emitting one ton of carbon dioxide into the earth’s atmosphere.

The social cost of carbon is a tool that helps ensure that policymakers consider the health, environmental and economic benefits of avoiding extreme weather, rising temperatures and intensifying smog when they make decisions that affect climate pollution.

Climate change harms businesses, families, governments and taxpayers through rising health care costs, destruction of property, increased food prices and more — so it’s common sense that we should properly account for the value of avoiding these harmful outcomes. But the Trump Administration has systematically undermined and attacked the well-established science of climate change – including the social cost of carbon, which has had a target on its back for a while now.

The most up-to-date estimates of the social costs of carbon were developed by an Interagency Working Group (IWG) of experts from a dozen federal agencies. They were developed through a transparent and rigorous process based on the latest peer-reviewed science and economics, and with input from the public and the National Academy of Sciences.

But in March, President Trump cast aside the results of this thorough and consultative process. He issued an executive order aimed at discrediting the IWG estimates, withdrawing them as government policy, and directing federal agencies to pick their own metric.

The executive order leaves federal agencies to fend for themselves without specific guidance, opens the door to extensive legal challenges, and effectively sets up agencies to cook the books to serve the Administration’s goals.

That’s exactly what EPA Administrator Scott Pruitt and Department of the Interior Secretary Ryan Zinke just did – releasing benefit-cost analyses that massively undervalue the costs of carbon pollution, radically reducing the estimates by up to 97 percent.

The Trump Administration would have us believe that the costs of carbon pollution are near zero. The Administration’s new estimates are only a couple dollars per ton of carbon dioxide – about as much as a cup of coffee or a bus ticket.

Sadly, communities around the country are already seeing just how wrong that is. From longer wildfire seasons to more intense hurricanes, the American public is already bearing the enormous costs of climate change.

Even the IWG estimates – roughly $50 per ton of carbon dioxide based on year 2020 emissions – are almost certainly a conservative lower bound since they do not yet reflect many different types of climate impacts.

A closer look at the Administration’s deceptive math 

There are two major flaws in the Administration’s drastically reduced estimates, both of which fly in the face of established science and economic principles in service of obscuring the very real benefits of climate action.

First, the reduced estimates ignore that carbon emissions are a global pollutant, so they omit important categories of climate change impacts on the United States.

Second, they shortchange the harm to our children and future generations from climate change.

The so-called “domestic-only” estimate

Since the impacts of carbon pollution are felt globally regardless of where the emissions come from, leading researchers and the IWG have appropriately focused on accounting for that full global impact.

In contrast, the Administration’s revised estimates claim to consider “domestic-only” impacts to the United States. But that title is a misnomer – the Administration’s flawed approach ignores important categories of impacts that affect the American public. Climate impacts beyond our borders have costly repercussions for U.S. citizens in the form of changing global migration patterns, economic and political destabilization, and other “spillover” effects.

The National Academy of Sciences specifically rejected the approach the Administration is taking in a report released earlier this year, concluding that:

[C]limate damages to the United States cannot be accurately characterized without accounting for consequences outside U.S. borders.

Economist Richard Newell – president of the think tank Resources for the Future, which is leading an effort to implement the Nation Academy of Sciences’ recommendations to update the social cost of carbon estimates – has criticized the Administration’s approach, saying that considering only direct domestic impacts is:

[U]nnecessarily constrained and unwise for addressing inherently global pollutants like greenhouse gases.

The use of a “domestic-only” number also harms Americans because it undervalues the cost of climate pollution and encourages other countries to similarly undervalue – and over-emit – this pollution.

More than half a dozen leading experts argue:

[The] United States benefits tremendously if other countries set policy based on global rather than local effects.

They also point out that the use of a global estimate can encourage reciprocal climate action elsewhere. For instance, the Canadian government incorporated the U.S. IWG value in its own policy analysis.

Undervaluing the impacts on children and future generations

The Administration’s estimates also use a sharply lower value for the benefits that today’s carbon reductions provide to children and future generations. Again, this is in direct conflict with the weight of expert opinion that supports valuing these impacts even more than we did before the Trump Administration.

The Administration’s estimates “discount” future impacts at 7 percent – a rate significantly higher than the 3 percent central rate of the IWG, and one that is wholly unsupported by the economics literature when it comes to the long-lived intergenerational effects of carbon pollution.

A growing consensus among leading economists supports lower or declining discount rates, as does the Council of Economic Advisors.

As Richard Newell of Resources for the Future points out:

Practically speaking, the use of such a high discount rate means that the effects of our actions on future generations are largely unaccounted for in the new analysis.

In other words, the Administration’s estimates reveal just how little they value protecting American children and generations to come.

The social cost of carbon has profound influence on our policy process and embodies the very real costs of climate change that communities around the country are already feeling.

The Administration’s distortion of these values is illustrative of a frequent strategy of theirs – twisting the facts to validate their desired outcome, and in the process sowing doubt around the overwhelming scientific consensus on climate change.

Unfortunately, while the math the Administration is using is warped, the costs of climate change are still very real – and the American public is footing the bill.

Also posted in Clean Power Plan, Greenhouse Gas Emissions, Policy, Setting the Facts Straight / Comments are closed

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

By Rama Zakaria / Published: October 9, 2017

(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.

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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.

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