Standards of Performance for Greenhouse Gas Emissions from Existing Sources: Electric Utility Generating Units

December 1, 2014 • Public Comments

The science used by the U.S. Environmental Protection Agency (EPA) to support and justify its proposed rule “Standards of Performance for Greenhouse Gas Emissions from Existing Sources: Electric Utility Generating Units” generally fails to consider vital aspects of climate change and mankind’s role in it, including some of the most basic fundamentals, such as the sensitivity of the earth’s surface temperature to changes in carbon dioxide.

Absent an accurate accounting of the science, the EPA’s justification of its calculation of the social costs of carbon (SCC) and how that translates to “benefits” from the emissions reductions calculated to occur under this proposed rule is not only in error, but is grossly misleading. We show that a more plausible and justifiable determination of the SCC proves the costs to be near zero, with a good chance of being negative, meaning a net benefit.

The same applies to the health benefits presumed (and quantified) by the EPA. We demonstrate that the in the face of (or perhaps even as a result of) climate change, net human health and welfare are improving.

Further, basing its justification for action on assessment reports produced by the U.N.‘s Intergovernmental Panel on Climate Change and the U.S. Global Change Research Program raises serious doubts. Many concerns have been raised about robustness, thoroughness and degree of bias of these assessment efforts.

Perhaps most importantly, the EPA fails to quantify the projected climate impacts that expected to be mitigated by this proposed rule — a rule that was advanced for the expressed purpose of mitigating climate impacts. In these comments, we rectify that situation and perform the analysis that the EPA did not. In doing so, we demonstrate that the EPA’s proposed rule would result in no net benefits from avoided negative environmental effects as the environmental impacts of the proposed rule are negligible and scientifically undetectable.

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