ByNatural Resources Defense Council
In our last post, we covered how EPA Administrator Scott Pruitt fiddled with the accounts to inflate the costs of the Clean Power Plan, when in reality the rule is achievable at even lower cost than the EPA originally projected.
In this post, we’ll focus on how Pruitt has tried to cook the books on science and economics to hide the Clean Power Plan’s enormous climate and public health benefits.
Pruitt undermines the best available science and economics, twice
When it issued the Clean Power Plan, EPA concluded that the Plan would produce tremendous climate and public health benefits that far outweigh its costs. In 2030, the climate protection and health benefits run to the tune of $34 to $54 billion. Subtracting the costs of meeting the CPP goals, the net benefits range from $26 to $45 billion.
These climate and health benefits are very likely incomplete. The climate benefit estimates relied on the best available science and economics—which have gone through an extensive peer review process—but leave out many impacts that scientists foresee but do not yet know how to fully quantify. EPA’s standard practice has been to estimate climate benefits based on reductions in carbon dioxide pollution that drives climate change, and public health benefits based on reductions in air pollutants, including sulfur dioxide (SO2), nitrogen oxides (NOx) and particulate matter (PM2.5 or soot) that cause respiratory illness and premature death. In 2014, the Intergovernmental Panel on Climate Change—a group made up of the world’s foremost experts on climate science and economics—noted that estimates of climate damages leave out many impacts that are difficult to value but would certainly increase the costs of carbon pollution.
EPA’s methodology for quantifying health impacts resulting from power plants’ sulfur dioxide and nitrogen oxides emissions has similarly been subjected to thorough and robust scientific review, including by the Agency’s Science Advisory Board. EPA’s methodology focused on the best-documented harms of fine particles (soot) and ozone (smog), but again scientists have not fully valued all the harms these pollutants cause.
Instead of trying to improve these estimates by considering all of the undervalued harms, Scott Pruitt’s EPA goes in the opposite direction: it radically distorts the science and economics of assessing the harms of these dangerous pollutants and the benefits of curbing them, and it does so without any review or input from the scientific community.
Pruitt continues his climate denial
In its 2015 analysis, the EPA found that the Clean Power Plan would drive $20 billion in benefits in 2030 as a result of avoided climate damages.
To assess the climate benefits of the rule, EPA used an estimate of the impacts of each ton of carbon dioxide known as the “Social Cost of Carbon”. The Social Cost of Carbon was developed based on extensive scientific and economic analysis from across several agencies of the government, and with a public review and comment period. That figure has two important characteristics. First, since carbon pollution does not stop at our borders, it accounts for the damage our emissions cause in other countries. And second, since these pollutants last in the atmosphere for centuries, it gives weight to damages that our emissions will cause to future generations. In 2030, the costs of each ton of carbon pollution are estimated to be $48/ton; this value still leaves many climate damages out, but at least it is a start at a full accounting.
Scott Pruitt effectively engages in outright climate denial by deflating the benefits of climate action, using two methods: (1) ignoring the global impacts of climate change, choosing instead to only account for the impacts in the U.S, and (2) by discounting the well-being of future generations. After his comments earlier this year denying man-made climate change, it should come as no surprise that Pruitt has instructed his Agency to hide the costs of climate change from the public.
Pruitt’s attempt to sweep under the rug the harm our pollution causes the rest of the world is wrong for numerous reasons. It’s inconsistent with our values. Just as we don’t tolerate pollution from one state harming people in another, we know it’s wrong for pollution from one country to cause harm in another.
By only examining domestic costs Pruitt also pretends that climate impacts in the rest of the world will have no secondary effect on the United States. This ignores the warnings of the Department of Defense, which calls climate change a “threat multiplier.”
Finally, it’s wrong because if we want other countries to account for the damage that their pollution causes us, we must do the same. Climate change is a global problem, and it requires a global response. Pruitt’s calculation rests on two faulty premises.
First, it pretends that reducing carbon emissions under U.S. policy has no impact on climate change beyond our borders. Second, it misjudges the role of U.S. policy in global climate diplomacy. The Clean Power Plan was, in fact, the centerpiece of U.S. pledges under the Paris Accord, a groundbreaking agreement in which 195 countries have committed to reduce their emissions, and U.S. leadership played a significant role in influencing the decisions of other countries to join the Accord. As top scientists and economists concluded during a review of the SCC by the National Academy of Sciences:
“Thorough estimates of U.S.-specific damages would need to consider how climate change and CO2 reductions in other parts of the world could also impact the United States—for example, through increased migration because of economic or political destabilization, and through reciprocal actions by other countries in response to U.S. emission reductions.”
Lastly, Pruitt’s EPA also uses a higher discount rate, which means that the costs that future generations face as climate impacts worsen are considered significantly less important than the costs we might face today to avoid climate change. Using such high discount rates is completely unjustified for a problem like climate change.
President Trump’s March Executive Order told agencies to stop using the Obama administration’s estimate of the social cost of carbon, and instead to follow guidance from the Office of Management and Budget issued in 2003 under the George W. Bush Administration. But that very guidance tells agencies they need to use lower discount rates when considering intergenerational impacts. A rate of 3 percent might not show enough concern for future generations, the guidance says, and lower rates should be examined as well:
“Special ethical considerations arise when comparing benefits and costs across generations. Although most people demonstrate time preference in their own consumption behavior, it may not be appropriate for society to demonstrate a similar preference when deciding between the well-being of current and future generations.”
In 2015, EPA heeded this guidance using discount rates between 2.5 percent and 5 percent to address the impacts on future generations. Pruitt’s EPA has gone in exactly the opposite direction, focusing on an estimate that uses a 7 percent discount rate. In so doing, this Administration is saying, we don’t care how our activities will harm our children, grandchildren, and beyond. This shows total disregard for our moral responsibility to protect future generations from the worst impacts of climate change.
The Administration continues its war on science
The EPA also found in its 2015 analysis that the Clean Power Plan would result in $14 to $34 billion in health benefits in 2030 as a result of reduced exposure to dangerous air pollution.
The CPP projected significant public health benefits because as the power sector cuts carbon pollution, emissions of other harmful pollutants decrease as well. Power plant emissions such as sulfur dioxide and nitrogen oxides lead to the formation of soot and smog, which have dangerous human health consequences. Specifically, EPA found that slashing these harmful air emissions would prevent up to 3,600 premature deaths, 90,000 asthma attacks, and 300,000 missed work and school days, resulting in $14 to $34 billion in public health benefits.
In a radical revision that undermines a thoroughly peer-reviewed methodology based on the best available science, EPA puts out several different considerations in an apparent attempt to sow confusion about the benefits of reducing air pollution. The reality remains clear: the Clean Power Plan would cut emissions, protect public health, and result in significant benefits for the American people.
EPA first proposes that the cost-benefit analysis should only consider the “targeted pollutant”; in other words, EPA could count only the climate benefits and would ignore the massive health benefits of the rule. This runs counter to basic principles of cost-benefit analysis. Again, in the same guidance issued under the George W. Bush Administration, the Office of Management and Budget explains that EPA consider all of the costs and benefits of a rule:
“…analysis should look beyond the direct benefits and direct costs of your rulemaking and consider any important ancillary benefits and countervailing risks. An ancillary benefit is a favorable impact of the rule that is typically unrelated or secondary to the statutory purpose of the rulemaking (e.g., reduced refinery emissions due to more stringent fuel economy standards for light trucks)…”
To ignore the health benefits of a climate rule would be nonsensical and goes against decades of EPA practice of examining all the costs and benefits of a rule, a practice that has been followed by both Democratic and Republican Administrations.
Pruitt also leans on the thoroughly debunked idea that the health benefits of reducing dangerous soot (called particulate matter or PM) no longer exist below a certain threshold. This goes against the consensus of the entire scientific community, which has long held that particulate matter is a “no-threshold” pollutant—in other words, health experts have concluded that there are no levels of particulate matter that do not have dangerous impacts on human health. As my colleague John Walke has described in detail, EPA scientists have studied the health effects of particulate matter pollution extensively in the past and previously rebutted the same arguments that Pruitt makes now.
In a letter responding to Congressman Upton’s attacks on the same science, EPA responded that “The best scientific evidence, confirmed by independent, Congressionally-mandated expert panels, is that there is no threshold level of fine particle pollution below which health risk reductions are not achieved by reduced exposure.” This “no threshold” conclusion was independently reviewed and confirmed by EPA’s official Clean Air Science Advisory Committee, the Advisory Council on Clean Air Compliance Analysis (and separately, the Health Effects Subcommittee of this Council), EPA’s Science Advisory Board and the National Academy of Sciences. The World Health Organization separately concluded that “Small particle pollution has health impacts even at very low concentrations – indeed no threshold has been identified below which no damage to health is observed.”
Despite the overwhelming consensus of health experts, Pruitt insists on presenting results that attack the scientific evidence in order to misrepresent and underestimate the health benefits of the CPP.
The Trump Administration’s analysis of the impacts of rolling back the Clean Power Plan relies on misleading accounting, attacks the overwhelming consensus of health experts, and engages in climate denial. The reality is that the goals of the Clean Power Plan are readily achievable, at even lower cost than EPA initially projected when it finalized the rule. Despite its best efforts, the EPA cannot escape the conclusion that the CPP has significant climate and public health benefits that far outweigh the modest costs and the rule should not be repealed.