June 25th will mark the deadline for public comments on EPA's dreadful proposal meant to fulfill President Obama's campaign promise to "necessarily bankrupt" anyone foolish enough to build a new coal-fired power plant. EPA is properly braced for a very large volume of comments.
Sure, the economics favor gas today, as fracked natural gas floods the market, and it is in fact cheaper to build and run a gas-fired plant rather than one lit by coal. But that very abundance has now depressed the price of gas to the point that the major frackers, like Aubrey McClendon's troubled Chesapeake Energy, are cutting way back. There's no certainty about what the future price of gas will be, but it's surely possible that it will again rise above coal on a per-unit-electricity basis. In that eventuality, you still could not operate a new plant.
That's because EPA has proposed that no coal plant can be built unless it emits (per unit energy output) as little or less carbon dioxide than a comparable natural gas plant. Because producing a requisite amount of electricity from gas results in—estimate—about 50% of the carbon dioxide for the same coal-based electricity, the only way to meet the proposed standard is to capture the outgoing carbon dioxide, pipe it somewhere, and bury it. This raises the cost of power and also requires considerably more coal to be burned because it takes energy to capture and transport carbon dioxide. Hence, you go "necessarily bankrupt".
I'll be submitting my comments next Monday, and I'm going to go straight to the heart of the matter: EPA's "endangerment finding" from carbon dioxide and other greenhouse gases. Concerning U.S. climate, it is largely based upon a single document, produced by the U.S. Global Change Research Program (USGCRP), called "Global Climate Change Impacts in the United States".
My comments will include the first release of a late draft of an Addendum to that report, produced by the new Center for the Study of Public Science and Public Policy (PSPP) here at the Cato Institute. The Center is particularly interested in the policy consequences of making the government the sole funding provider for policy-related scientific research.
And so, on June 25th (or shortly thereafter), you will be able to access our Addendum, which pretty much matches—page for page, and subject for subject—the USGCRP document. The Government has 569 science citations, Cato has 932. Which is more complete?
Both are summarized in a set of ten "Key Findings" near the beginning of the documents. Here they are, side by side, USGCRP and Cato's CSPP. (Also included are two examples of the subsequent text explaining the findings).
1. Global warming is unequivocal and primarily human-induced.
2. Climate changes are underway in the United States and are projected to grow.
3. Widespread climate-related impacts are occurring now and are expected to increase.
(Text: Climate changes are already affecting water, energy, transportation, agriculture, ecosystems, and health. These impacts are different from region to region and will grow under projected climate change. (p.41-106, 105-152))
4. Climate change will stress water resources.
5. Crop and livestock production will be increasingly challenged.
6. Coastal areas are at increasing risk from sea-level rise and storm surge.
7. Risks to human health will increase.
(Text: Harmful health impacts of climate change are related to increasing heat stress, waterborne diseases, poor air quality, extreme weather events, and diseases transmitted by insects and rodents. Reduced cold stress provides some benefits. Robust public health infrastructure can reduce the potential for negative impacts. (p. 89))
8. Climate change will interact with many social and environmental stresses.
9. Thresholds will be caused, leading to large changes in climate and ecosystems.
10. Future climate change and its impacts depend on choices made today.
1.Climate change is unequivocal and human activity plays some part in it.
2.Climate change has occurred and will occur in the United States.
3. Impacts of observed climate change have little national significance.
(Text: There is no significant long-term change in U.S. economic output that can be attributed to climate change. The slow nature of climate progression results in de facto adaptation, as can be seen with sea level changes on the east coast. (pp.45-144))
4. Climate change will affect water resources.
5. Crop and livestock production are adapting to and will adapt to climate change.
6. Sea level rises caused by global warming will be easily adapted to in the U.S.
7. Life expectancy and wealth are likely to continue to increase.
(Text: There is little relationship between life expectancy, wealth and climate. Even under the most dire scenarios, people will be much wealthier and healthier than they are today in the year 2100. (pp. 99-111))
8. Climate change is a minor overlay on U.S. society.
9. Species and ecosystems will change with or without climate change.
10. Policies enacted by the developed world, including the U.S., will have little impact on global temperature.
We expect our Addendum is going to cause a little heartburn at the EPA, and it should, with hundreds of more citations and endnotes than are in the documents that serve as the scientific cover to "necessarily bankrupt" people.