A few years ago, cap-and-trade legislation to reduce greenhouse gas emissions failed to reach President Barack Obama’s desk because constituents gave their Members an earful that cap and trade would amount to a massive energy tax. When the bill died in Congress, President Obama said that there was more than “one way of skinning a cat,” and here it is.
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The Obama Administration has finalized its climate regulations known as the Clean Power Plan. There are plenty of details to uncover in the 1,560-page regulation,
[2] the 755-page federal implementation plan,
[3] and the 343-page regulatory impact analysis.
[4] To summarize, unelected bureaucrats at the Environmental Protection Agency (EPA) are poised to do what America’s elected representatives refused: impose higher energy costs on American families and businesses for meaningless climate benefits.
The following are four early observations that should cause Members of Congress, state politicians, and the general public concern.
1. Higher Energy Prices, Lost Jobs, Weaker Economy
When running for office in 2008, President Obama famously remarked, “Under my plan of a cap-and-trade system, electricity rates would necessarily skyrocket.”
[5] Although that plan ultimately failed to become law, the White House tasked the EPA with creating the regulatory equivalent, placing strict greenhouse gas emissions limits on new power plants and drastic cuts on existing plants. The plan includes greenhouse gas emission reduction targets for each state except for Vermont, Alaska, and Hawaii in hopes of reducing overall power plant emissions to 32 percent below 2005 levels by 2030.
The regulations will drastically shift the energy economy away from coal, which provides approximately 40 percent of America’s electricity.
[6] Restricting the use of that affordable, reliable energy supply will raise electricity rates, and those higher prices will reverberate through the economy. Businesses will pass higher costs onto consumers, but if a company must absorb the higher costs, it will invest less and expand less. The combination of reduced production and consumption will result in fewer jobs and a weaker economy.
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Despite candidate Barack Obama’s admission that cap and trade will raise prices, the Administration is attempting to spin the regulations as a win for the economy. Proponents of the Clean Power Plan argue that as energy prices increase, families and businesses will invest in more energy-efficient products and innovative technologies that will save them money in the long run. Arguing that increasing energy prices with regulations will save money by forcing energy-efficient product purchases is equivalent to cutting employees’ salaries and telling them that they will save money by shopping at Target. Just as the option to save money at Target existed before the pay cut, families and businesses already have an incentive to purchase energy-efficient products. When the government mandates efficiency, it removes that choice and makes consumers worse off.
2. No Climate Benefit, Exaggerated Environmental Benefits
The climate impact of the Clean Power Plan will be meaningless. According to climatologist Paul Knappenberger, “Even if we implement the Clean Power Plan to perfection, the amount of climate change averted over the course of this century amounts to about 0.02 C. This is so small as to be scientifically undetectable and environmentally insignificant.”
[8] Climatologist James Hansen, who wants the Administration to do much more to combat climate change, has stated that “the actions are practically worthless.”
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The monetized climate benefits the Administration is touting are equally worthless. The EPA says the rule will provide $34 billion to $54 billion in annual environmental benefits after 2030. Yet these numbers are misleading for two reasons.
Social Cost of Carbon. First, the Administration uses “the social cost of carbon” to calculate the climate benefit. The EPA is using three statistical models, known as integrated assessment models, to estimate the value of the social cost of carbon, which is defined as the economic damage that one ton of carbon dioxide emitted today will cause over the next 300 years. The EPA uses the average of the three models to estimate the social cost imposed by climate change—$40 in 2015 and $56 in 2030. However, the models arbitrarily derive a value for the social cost of carbon.
[10]Subjecting the models to reasonable inputs for climate sensitivity and discount rates dramatically lowers the figure for the social cost of carbon.
People generally prefer benefits earlier instead of later and costs later instead of earlier. Hence, it is necessary to normalize costs and benefits to a common time. For example, if a 7 percent discount rate makes people indifferent to a benefit now versus a benefit later (e.g., $100 today versus $107 a year from now), then 7 percent is the appropriate discount rate to use. The Administration’s own analysis shows how sensitive the social cost of carbon is to the discount rate.
[11] When changed from a 3 percent discount rate to a 5 percent discount rate, the EPA’s $20 billion in projected climate benefits decreases to $6.4 billion—less than the EPA’s egregiously low projection of $8.4 billion in compliance costs.
Co-benefits. The second problem is the EPA’s use of co-benefits in inflating the benefits. The EPA exaggerates the environmental benefits by including the estimated benefits from reducing particulates (co-benefits) that are already covered by existing regulations and federal health requirements. Of those benefits, $20 billion come from direct climate benefits, and $14 billion to $34 billion are air quality co-benefits. Co-benefits sound positive. Who would not want additional health and environmental benefits from regulations?
The problem is that these benefits are double-counted over and over again with each regulation the federal government imposes. In some instances the co-benefits have accounted for more than 99 percent of the EPA’s estimated environmental benefits. The agency even overestimates the co-benefits by using questionable assumptions about causality and simplistic methods to calculate the benefits.
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