Guest essay by Stephen Heins, Energy Consultant, Business Writer and Practical Environmentalist
While many of us have actively tried to follow the broad-based scientific discussions about climate change including those at the Paris Meetings, most of us are stuck between to the “alarmist” and the “denier” narratives. The “luke warmers,” as we are called, suspect that the climate change discussion is far from over.
Most troubling to some observers of the current Washington DC bureaucracies, the FCC and the EPA, is that they fit the classic mold of federal agencies furiously trying to regulate industries while they themselves are many years behind the investment, technology and innovation of the industries they regulate.
Suffice it to say, the world’s 7.4 billion people of global economy and planetary environment are far too important to be left to silo thinking or national and global politics. This is especially true with the skyrocketing need for big data, huge wireless broadband and ongoing technological innovation, particularly in the under-developed and under-represented parts of the world.
With that in mind, here are several flaws in the final version of the Clean Power Plan (CPP) of 2015:
• The use of several studies (e.g. Harvard’s study of indirect health benefits) are likely examples of “study-bias;”
• Medical computations of indirect health benefits from the reduction of PM 2.5 (or fine particulate matter) have never been well demonstrated;
• The CPP places complete faith in the advancement of technology responding to political dictates instead of the marketplace;
• The CPP lacks a full accounting of the costs of stranding electrical assets and the large investment in new infrastructure, which essentially just replicate old distribution assets;
• The Clean Power Plan has never been properly vetted by the states, and there never was a state or national political mandate calling for its formulation;
• Currently, a clear cut democratic majority, 28 states, have officially challenged the legality of the Clean Power Plan;
• With the U.S. Court of Appeals for the District of Columbia just beginning its En Banc proceedings, President Obama and Secretary McCarthy are likely to be in the rear view mirror by the time it is fully litigated;
• Indistinguishable from any political campaign, the robust public relations campaign conducted by the EPA and the White House, and a large number of related texts and emails, are shrouded in the lack of proper disclosure not unlike the Colorado Toxic Spills;
• Actual greenhouse gas reductions from the Clean Power Plan are miniscule, and, according to Scientific America and the Energy Information Administration (EIA), by 2015, 47 states had already achieved sharp decreases in emission from 2007 levels, with more than billion tons of reductions;
• The US is already on a glide path whereby America has reduced more Green House Gas (GHG) than any other country in the world, a fact which even the Sierra Club acknowledges;
• The EPA has never provided a real cost benefit analysis of the Clean Power throughout all versions of the regulations;
• The CPP gives the EPA and state environmental agencies first class status, making all other state and federal agencies (like the Department of Energy, Federal Energy Regulatory Committee, and State Utility Regulators) virtual second class citizens, with second class powers;
• With “cross state” and regional emission differences, the CPP makes states and regions compete against each other in energy markets previously regulated by states, and is de facto helping to create a national emissions market, which has already been defeated legislatively;
• The Clean Power Plan is fraught with backward looking and silo thinking, with no heed paid to the rapidly expanding convergence of energy, technology and wireless telecommunications. In the case of the above convergence, there is no consideration for the rapidly expanding need for electricity, big data and wireless broadband to allow significantly more energy efficiency, better environmentalism and economic development in all 50 states;
• The CPP has a serious lack of transparency, whereby much of the information remains undisclosed. Much of the grant money provided by the EPA for health and emissions studies (Harvard, Syracuse, George Mason et al) is essentially undeclared;
• The significant input provided by large environmental groups like the Sierra Club and the NRDC is largely buried in the footnotes or hidden in private emails;
• Finally, as Professor Laurence Tribe of Harvard and the Wall Street Journal point out, the constitutionality of Clean Power Plan and its new found powers violate the separation of powers and the long standing principle of cooperative federalism between the states and the federal government.