New carbon rule is entirely at odds with Trump Administration’s earlier rhetoric on the Clean Power Plan.
Pay no attention to the premature deaths behind the curtain.
That is the upshot of the analysis supporting the Environmental Protection Agency’s (EPA) so-called Affordable Clean Energy (ACE) rule, which public health groups are challenging in a lawsuit filed earlier this month.
The Trump EPA’s policy is a toothless replacement for the Clean Power Plan (CPP), a signature climate initiative of the Obama Administration that sought to substantially reduce reliance on aging coal plants and boost the use of non-emitting alternatives like wind farms and solar arrays. ACE, by contrast, requires at most modest efficiency gains at coal plants—a strategy that perversely runs the risk of raising emissions from such plants by increasing their cost-competitiveness and, in turn, the frequency with which they are dispatched.
The health groups filing suit rightly contend that ACE will put lives at risk. But in the analysis accompanying the rule, EPA attempts to paint its change of policy as no big deal, environmentally or economically. It is a surprising—and transparently cynical—turnabout for an administration that has long characterized repealing the Clean Power Plan as an essential component of its plan to “save the coal industry.”
When the Trump Administration first proposed ACE last summer, many pointed out that the agency’s own analysis showed grave consequences from scrapping the Clean Power Plan, to the tune of 1,400 pollution-related deaths a year and tens of billions of dollars in net harms to the American people.
Those inconvenient statistics are nowhere to be found in the final version of the rule. Instead, EPA insists that “there is likely to be no difference between a world where the CPP is implemented and one where it is not.”
In making this claim, EPA manages to depart dramatically from the Trump Administration’s previous rhetoric around this repeal effort without getting any closer to the truth.
For years, Trump and his EPA have consistently painted the Clean Power Plan as a draconian threat to both the coal industry and the larger economy. In a September 2016 campaign speech, Trump claimed the policy would “shut down most, if not all, coal-powered electricity plants in America.” When he officially instructed EPA to consider repealing the rule in a March 2017 executive order, Trump contended that “no single regulation threatens our miners, energy workers, and companies more than this crushing attack on American industry.” The following October, when the President’s first, scandal-plagued EPA Administrator, Scott Pruitt, released an initial proposal to repeal the rule, Pruitt claimed doing so would save the power sector up to $33 billion in 2030 alone. And even Pruitt’s more cautious successor, Andrew Wheeler, announced less than a year ago that the replacing the Clean Power Plan with ACE would avoid up to $400 million a year in spending on pollution reductions.
Now, still under Wheeler’s leadership, the agency says that “the most likely result of implementation of the CPP would be no change in emissions and therefore no cost or changes in health benefits.” In other words, the Trump Administration is telling us that a policy it previously characterized as a “crushing attack on American industry” would in fact impose no costs at all.
Why the dramatic reversal? Because last summer’s scrutiny of ACE’s severe health impacts proved embarrassing to the Administration and could have derailed the rule in court. The bad news for EPA is that its new ploy is unlikely to fare any better. The agency has not actually eliminated ACE’s death toll; it has just obscured it.
It is true, to be sure, that the Clean Power Plan was never the economic albatross that the Trump Administration made it out to be. As we explained two years ago, Pruitt’s claim that the rule would impose $33 billion in compliance costs was pure puffery, the product of an elaborate accounting gimmick. In reality, the policy was going to be even cheaper to implement than the Obama Administration had originally predicted, due to lower than expected prices for natural gas and renewable energy technologies.
It is also true that those favorable market conditions have prompted a faster-than-expected decarbonization of the power sector, meaning that some of the reductions originally expected to occur as a result of the Clean Power Plan have already been achieved, without a regulatory push. But contrary to EPA’s current claims, this good economic luck has not rendered the Clean Power Plan meaningless: the agency’s latest modeling projects that, as of 2030, 18 states will fall short of Clean Power Plan emission targets as a result of the plan’s repeal.
EPA attempts to assume away these shortfalls (and their attendant harms to public health), claiming that, if the Clean Power Plan were to remain in place, states not already on track to meet the rule’s 2030 targets would comply not by reducing their own emissions but by engaging in emissions trading with states like California and New York, which, as a result of ambitious state-level climate policies, are already expected to cut emissions by significantly more than the Clean Power Plan requires. If underachieving states simply paid to take credit for excess reductions in overachieving states, then everyone could achieve compliance without any change in business-as-usual emissions.
But universal trading is a heroic assumption, one that EPA has made in no previous analysis of the Clean Power Plan, including those conducted under the Trump Administration. The rule certainly did not require states to engage in such trading, and California, one of the states with the highest volume of “spare” emissions reductions, made clear in 2016 that it would trade with others only under very limited circumstances.
That the Obama Administration did not assume universal trading in its 2015 analysis for the Clean Power Plan is notable, given that such trading would have made compliance with the rule look significantly cheaper. In other words, the Obama EPA declined to resort to methodological chicanery to put its preferred policy in a more favorable light. The Trump EPA clearly feels no such compunction, notwithstanding recent reports that Administrator Wheeler has decided to start “playing by the rules” of policymaking in hopes of boosting his agency’s dismal record in the federal courts.
In the end, the Trump Administration’s effort to paint the Clean Power Plan as insignificant is just as dishonest as its past claims that the plan would bring down the U.S. economy. The Obama policy was neither a silver bullet nor a nothingburger. It would not have solved the problem of greenhouse gas emissions from the power sector but, as EPA’s own analysis shows, it was likely to achieve substantially more pollution reductions than market forces alone—and save many lives in the process.
The Trump Administration’s plan, by contrast, is a near-complete abdication of responsibility to address the climate crisis. And despite EPA’s claims to the contrary, that decision will carry consequences—for all of us.
