Institute for Policy Integrity: Power Plant Pollution is Clearly Significant

Roger Caiazza

The Institute for Policy Integrity at New York University School of Law recently published The Scale of Significance: Power Plants: The U.S. Power Sector’s Annual Climate Pollution Causes Thousands of Deaths and Massive Economic Damage”.  The lede provoked an immediate negative reaction from this retired utility meteorologist.

Summary

The description of the report states that:

The Trump Administration is openly questioning the significance of U.S. contributions to climate change, playing down U.S. greenhouse gas emissions as contributing only “some mysterious amount above zero to climate change.” According to a leaked draft of a proposed regulatory repeal, Trump’s EPA will compare the U.S. power sector’s greenhouse gas emissions to worldwide totals and find, judged on that relative scale, the sector’s contribution to climate change is neither “significant” nor “meaningful.” That kind of skewed appraisal would produce the reductio ad absurdum under which no U.S. sector, sliced thinly enough, is ever a significant source of greenhouse gases—a clearly irrational outcome.

By any measure, emissions from major U.S. industries like the electric power sector contribute significantly to climate damages. The best available evidence shows that each year of greenhouse gas emissions from U.S. coal-fired and gas-fired power plants will contribute to climate damages responsible for thousands of U.S. deaths and hundreds of billions in economics harms.

The report was authored by Peter H. Howard and Jason A. Schwartz.  The document states that “Peter Howard is the Economics Director at the Institute for Policy Integrity, where Jason A. Schwartz is the Legal Director.” 

Arguments

The reductio ad absurdum remark refers to the relative scale of US power plant pollution.  It is based on the following graph. While US power plant emissions are likely still significant, using cumulative emissions from 1990 to 2022 is enormously misleading.  The start of that period was before the results of massive emission reduction programs kicked in.  Since then, the Acid Rain Program reduced SO2 emissions 93%, numerous nitrogen oxide emission reduction programs to reduce ozone pollution cut emissions 86%, and the fracking revolution made natural gas cheaper than coal and oil which reduced CO2 emissions 15%.  Using cumulative emissions ignores those reductions.  Moreover, changes to the rules impacts future emissions so the use of 30-year old data is misleading.

Figure 1: (https://policyintegrity.org/files/publications/Power_Sector_GHG_Contribution_Issue_Brief_vF.pdf)

The authors also argue that power plant emissions must be reduced because:

One useful way to confirm that a sector’s contributions to climate change merit regulation is to evaluate whether the benefits of reducing that sector’s emissions justify the costs. From that perspective, the U.S. power sector unquestionably makes a meaningful contribution to climate change that is worth regulating. EPA’s 2024 carbon pollution standards for fossil-fuel-fired ower plants, for example, entailed less than a billion dollars in costs per year and in return achieved $14 billion per year in climate benefits (not to mention an additional $6.3 billion per year in health benefits from reduction of co-pollutants)

The estimates are from the Fact Sheet for the Carbon Pollution Standards for Fossil Fuel-Fired Power Plants Final Rule, Standards And Regulatory Impact Analysis. This nonsense does not deserve a detailed rebuttal.  Climate benefits were calculated based on the Social Cost of Carbon (SCC).  Value judgements by biased analysts over-estimate societal benefit claims in the EPA Final Rule.  Furthermore, the Fact Sheet states: “The Regulatory Impact Assessment projects 1.38 billion metric tons total of CO2 avoided from 2028-2047 systemwide along with tens of thousands of tons of nitrogen oxides (NOx), sulfur dioxide (SO2), and fine particulate matter (PM2.5).  The use of avoided emissions increases the total, but SCC benefits are based on annual emission reductions.  That approach coupled with biased SCC results in massive numbers that are not realistic. 

The report also argues that US action will prompt other countries to cut their emissions in response to our reductions: “Regardless, most claims about leakage overlook how countries may be just as—or even more likely to—reciprocally reduce their own emissions in response to U.S. emissions-cutting policies and goals.  The report disparages the idea that foreign countries will increase their emissions in response and suggests that leakage is not an issue.  In the real world when an industry that depends on electrical energy cannot afford to stay in business in the US because the alternative to fossil-fueled electric production are so much more expensive, their product will be produced elsewhere.  It is very likely that the alternative location does not have the same pollution and efficiency standards so the emissions will go elsewhere and increase to boot.  Claiming otherwise is magical thinking.

There are other easily debunked claims that I do not have the time to address.  However, I cannot let the claim that “The U.S. power sector’s annual emissions will cause thousands of U.S.. mortalities” go without a response.  If their claims have merit, then the change in any of the claimed morbidity and mortality health effects should have improved from 1990 to the present proportional to the observed emission reductions.  I have never seen any analysis that made such a claim, so I say that their projections are hokum.  If any reader has found such an analysis, please let us all know.

Conclusion

The report concludes that “By any measure, emissions from major U.S. industries, like the electric power sector contribute significantly to climate damages.”  The measures described in the report are biased, based on selective choice of metrics, and ignore historical emissions improvements. 

Roger Caiazza blogs on New York energy and environmental issues at Pragmatic Environmentalist of New York.  This represents his opinion and not the opinion of any of his previous employers or any other company with which he has been associated.