An op-ed in yesterday’s Investor’s Business Daily uses a new study to make unsubstantiated claims about the economic impacts of the proposed Clean Power Plan on vulnerable communities. Since the op-ed didn’t provide a link to the actual analysis, we hunted it down and took a look behind the headlines. And when we did, we found that the foundations of this new “analysis” are shaky indeed.
A house built on sand
The new study, conducted by Management Information Services, Inc. (MISI) on behalf of the National Black Chamber of Commerce (NBCC), purports to look at a range of EPA regulations, but focuses on the Clean Power Plan (CPP).
But here’s the first of the study’s fatal flaws: it depends, as it explicitly says (p. 21), on the findings of seven other studies, which it lists. But those seven include:
- Three studies that came out before the EPA published the draft CPP, meaning they don’t actually study the CPP as proposed—even though that’s the supposed focus of the NBCC/MISI analysis
- One that was just (self-described) “preliminary analysis” from the United Mine Workers of America, a group you’d be hard-pressed to characterize as an unbiased voice in this debate
- Three other studies funded by other fossil fuel interests who oppose the Clean Power Plan
One of those, done by IHS on behalf of the U.S. Chamber of Commerce, is the report most cited in this new work, even though it was one of those that came out before the draft CPP, and even though there was, as the Chamber itself admitted, “a big difference” between what they’d modeled and what EPA put forth (which the new study doesn’t acknowledge).
The flaws in the study by Energy Ventures Analysis (EVA) for Peabody Energy (the largest U.S. coal company) are also clear. The Center for Climate and Energy Solutions has pointed out that, unlike other studies, EVA’s didn’t even show a business-as-usual case, meaning that any CPP results were floating in a vacuum, without reference to a base case of shifting energy costs and other economic factors.
Ignoring the bedrock
Equally telling are the studies that didn’t make NBCC/MISI’s literature review:
- The EPA’s own cost-benefit analysis, which showed investments in energy efficiency under the Clean Power Plan will ultimately generate savings on electricity bills nationally
- Studies from academic sources, which show the CPP delivering widespread health co-benefits by reducing harmful air pollution from power plants
- One by the NAACP that has documented the costly and disproportionate impacts of power plant pollution on “low-income communities and communities of color”
- Another recent analysis by researchers at the University of Maryland suggesting the CPP will lead to a net increase in jobs.
But you wouldn’t glean any of that from the new NBCC/MISI report. No, it follows in the footsteps of previous misleading studies by exaggerating the costs and ignoring the benefits of climate action.
The elephant in the neighborhood
And that brings up another of the study’s fatal flaws: it forgets about climate change. In the op-ed, the only mention of “mitigation” is about avoiding the supposed impacts of the regulation. And even in the study itself, nary a word.
Hard to believe, I realize. But somehow the author makes it through the entire study without mentioning global warming. This, a purported study of a regulation, but it doesn’t even acknowledge the incredible amount of science behind the need for just such a regulation. All it’s got is one mention of “warmer climates” and the importance of air-conditioning… which, it turns out, we’ll need more of as the climate warms.
And who is going to be disproportionately affected by that warming climate and other impacts? In many cases, the same vulnerable populations that the new study is supposedly defending.
On the other hand, that grievous omission isn’t entirely surprising, since the author of the study has claimed—despite the wealth of information very much to the contrary—that more carbon dioxide is actually a good thing. Not so much.
Poor science, bad policy
It all adds up to a study that Juan Declet-Barreto of the Natural Resource Defense Council calls:
“…a cynical attempt at co-opting the Latino and African American communities into rejecting the most significant controls to power sector air pollutants and toxics affecting their health and communities.”
The Clean Power Plan is about the fundamental need to address climate change, including on behalf of those who are least equipped to deal with its impacts. A study of the CPP that forgets that isn’t worth the electrons it’s printed on.
Poor science may make for good headlines, but it definitely makes for bad policy.