CPP repeal wrong on costs and benefits, say Dems
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November 06, 2017
CPP repeal wrong on costs and benefits, say Dems

Democratic lawmakers are in an uproar over the cost-benefits analysis underlying EPA’s proposed repeal of the 2015 Clean Power Plan (CPP; October 16, 2017, FR). In a letter to EPA Administrator Scott Pruitt, 19 Senate Democrats assert that the proposed repeal “relies heavily on skewed scientific and mathematical data to justify repealing the CPP.”

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“Our review of the 2017 repeal proposal reveals significant deficiencies associated with the cost-benefit analysis used to support the 2015 rule’s repeal,” the Senators write. “At seemingly every turn, the 2017 repeal proposal uses mathematical sleights of hand to overstate the costs of industry compliance with the 2015 rule and understate the benefits that will be lost if the 2017 repeal is finalized.”

Repeal corrects unauthorized rule

The repeal proposal is mainly based in the current EPA’s belief that the CPP strays from authority provided in the Clean Air Act because it requires actions that must be taken across the electric power grid rather than actions taken at and applied to individual power plant units.

Furthermore, the proposal asserts that the CPP imposed “massive costs on the power sector and consumers; invaded traditional areas of state regulation over the mix of energy generation within their borders; departed radically from prior regulatory practice and longstanding reading of the statute; and did not adequately ensure the national interest in affordable, reliable electricity, including from coal generation.” The repeal proposal also states that there are considerable uncertainties in the benefits the Agency had previously attached to the CPP.

Fivefold increase in costs

Alluding to Pruitt’s “well-known rejection of the scientific consensus that greenhouse gas pollution causes global warming,” the Democrat’s letter notes the following:

  • Although the World Health Organization has stated 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,” the 2017 repeal proposal asserts that there may be no health effects associated with exposure to soot particles below certain thresholds. “This dramatic departure from the use of the best-available, peer-reviewed science has the effect of lowering the health cobenefits of the 2015 rule from $14–$34 billion by 2030 and 3,600 avoided deaths, to the 2017 repeal’s estimate of $1.3–$4.5 billion and 120–420 avoided deaths,” the senators state.
  • Although the 2015 rule projected compliance costs of the CPP to be between $5.1 and $8.4 billion by 2030, the 2017 repeal lists these costs to be as high as $33.3 billion by 2030, an almost fourfold increase. “This appears to be because the cost-savings associated with energy-efficiency improvements in homes and businesses are no longer counted in the ‘costs column,’ a deceptive accounting move seemingly designed to artificially inflate the costs of compliance with the 2015 Rule,” the senators state. 
  • The 2015 rule was projected to yield $20 billion in climate benefits by 2030, whereas the 2017 repeal projects only $0.5–$2.7 billion. “This is because in the 2017 repeal proposal, EPA chose to depart from a methodology that took years of discussion and review to develop and confined its analysis to climate damages predicted to occur only within the United States,” the senators state. “EPA also low-balled the costs associated with the damages caused by climate change, reducing these costs by as much as 97 percent from the costs included in the 2015 rule.”
  • The 2017 repeal’s cost-benefit analysis fails to incorporate available studies and data demonstrating that the electricity sector has made significant progress in complying with the 2015 rule and that the costs of doing so have declined considerably since the 2015 rule was finalized, even though some of these studies are cited in the 2017 repeal proposal. 

No response to April letter

“So that we can better understand the basis for the 2017 Repeal, we request that you provide us with all documents (including but not limited to e-mails, memos, meeting notes, and correspondence) sent or received by EPA that are related to EPA’s cost-benefit analysis for its 2017 Repeal of the Clean Power Plan,” the letter states. 

The senators also note that they are still waiting for Pruitt’s response to an April 7, 2017, letter requesting more details about the administrator’s views on the causes of climate change.

The Democrat’s letter is here.

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