All Cost No Benefit: EPA Proposes Carbon Dioxide Regulation for Power Plants
Today, the EPA has proposed a carbon dioxide standard for new power plants. The EPA blames carbon dioxide and other human emitted greenhouse gases for an increase in global temperature during the past 100 years. Unfortunately, this action is yet another EPA regulation that is essentially all cost and no benefit.
First, the EPA’s incessant use of the words “pollutant” and “pollution” in reference to carbon dioxide is deceptive. In the press release announcing this regulation, the agency mentioned the words “carbon pollution” eight times. Yet, as you learn in middle school science, carbon dioxide plays a vital role in the environment and has no direct negative human health effects. It is unlike particulate matter, sulfur dioxide, ozone or a volatile organic compound (substances explicitly regulated by the Clean Air Act); it is an essential part of photosynthesis, an important component of our atmosphere and a byproduct of the human respiratory system. Thus any discussion referring to this regulation as making power plants “cleaner” is downright misleading.
In 2009, the EPA concluded greenhouse gases do endanger human health. This “endangerment finding” was outside of the legal context provided by the Clean Air Act, since the Act requires a reasonable approach that considers a real benefit to regulation of a “pollutant,” not merely negligible decreases in global temperature. Ironically, the EPA has not quantified any health benefits for the regulation of greenhouse gases whatsoever.
Good public policy and sensible environmental regulation weighs the cost and benefits of regulatory action. The costs of greenhouse gas regulation are well documented by both the EPA and independent research studies. They vary, yet all show significant costs. Meanwhile, the benefit of this specific regulation, which aims to reduce carbon dioxide, has not been calculated at all. Why? Because the EPA justifies the regulation with a decrease in global temperature decades in the future that, even according to EPA’s flawed science, will be negligible. Even if one accepts the scientific claims of climate change proponents, EPA’s own analysis shows that the regulations will have no substantive effect on reducing global temperatures. It is hard to calculate human health benefits when the EPA itself isn’t sure they exist.
To make the endangerment finding, EPA wove together three highly uncertain lines of evidence — temperature records, climate models, and understanding of large-scale physical phenomena — to create the false sense that it could be 90 percent certain of human caused global warming. Even more disconcerting is that the EPA ignored its own established process by refusing to submit its work for independent scrutiny by its Science Advisory Board (SAB) as required by the Clean Air Act. The SAB is a panel of top scientists from universities, research institutions and other highly regarded organizations, empowered by federal law to review any new “criteria document, standard, limitation, or regulation” that the EPA proposes to issue under the Clean Air Act. The EPA is legally required to have the SAB review its work on greenhouse gases, and the Agency broke the law by ignoring this obligation.
Despite any calculation of health benefits and any peer review of its endangerment finding, the EPA concludes that it is taking “common-sense steps” to limit carbon dioxide and ensure “a cleaner, safer and more modern power sector.” Obviously the EPA has learned the Washington game all too well; EPA wants you to follow the rules when it comes to big government regulations while they willfully ignore the rules themselves.