My February 16 post explains why it is crucial for the US Environmental Protection Agency to repeal but not replace the Clean Power Plan (CPP) and instead reconsider and repeal the EPA GHG Endangerment Finding (EF) as part of its proposal to repeal the Obama Administration’s Clean Power Plan. On February 26 the Concerned Household Electricity Consumers Council (CHECC) submitted comments to the EPA explaining their reasons for this in response to the EPA’s request for comments on the Advance Notice of Proposed Rule Making (ANPRM) concerning possible replacements for the CPP. Their arguments include scientific, legal, and energy economic reasons. They have now prepared a press release summarizing their arguments as made to EPA on February 26:
PRESS RELEASE
- o CO2 is a Beneficial Gas, not a Pollutant. As a result, the Social Cost of Carbon is Negative since CO2 is so very critical to plant growth and therefore human life.
o The 2009 Endangerment Finding must be reconsidered and rescinded/vacated. Thus, the CPP would not be replaced.
o All future Federal, State and private sector decisions regarding the Nation’s electric power grid must focus solely on minimizing consumer electricity prices as well as maximizing Grid Reliability and Resilience. No consumer electricity price increases should be permitted by regulators that result from increased Renewables/Energy Storage Grid penetration.
o The Current Reconsideration of future vehicle MPG Standards must treat CO2 reduction as a cost, not a benefit, so that only consumer preferences matter, not climate change issues. Currently, with low gasoline price expectations, most consumers prefer trucks & SUVs.
March 20, 2018
The Concerned Household Electricity Consumers Council (CHECC) announces that on February 26, 2018 it filed a Comment in response to EPA’s Advanced Notice of Proposed Rule Making (ANPRM) Clean Power Plan (CPP) Replacement.
This Comment provided EPA and the Trump Administration with Legal, Climate Science and Energy Economic analysis findings, each robustly supporting the conclusion that EPA should Repeal and Not Replace the Clean Power Plan.
SUMMARY OF RECOMMENDATIONS
Based on the Legal Analysis: The CPP should not be replaced with anything at all until a lawful, scientifically robust, highly influential scientific assessment (HISA)-compliant positive endangerment finding has been made. The 2009 EF analysis process was fundamentally flawed requiring that it must be rescinded and reconsidered.
Based on the Climate Science Analysis: The scientific basis for the 2009 Endangerment Analysis has been invalidated – in fact, by two separate and distinct analyses. Hence, a GHG endangerment reconsideration is highly unlikely to yield a new endangerment finding. And, thus CPP replacement would have no legal basis and then should not be replaced.
Based on the Energy Economic Analysis: The current Federal, State and private sector policies that are now increasing the fraction of electricity generation from Intermittent Renewables must be stopped/reversed in order to avoid/mitigate very severe micro and macroeconomic impacts and National Security ramifications involving skyrocketing electricity prices as well as dramatically reduced power grid reliability and resilience. The climate science findings suggest that taking such action will have no impact on the climate.
Legal Findings
The legal analysis contained in the Comment is written to satisfy lawyers conversant in “Administrative Law,” but the bottom line is that the 2009 Endangerment Finding, upon which all current CO2 regulation is predicated, was rammed through EPA and the courts and shown in the Comment to have not been carried out consistent with statute law.
The 2009 Endangerment Finding did not comply with the requirements for highly influential scientific assessments (HISA), and Obama’s endangerment finding supporting the CPP is demonstrated to be grossly deficient. In short, the CO2 Endangerment Finding must be reconsidered because the 2009 finding was not made consistent with easy to understand statute law – a point made to EPA by its Inspector General but ignored by EPA and both the D.C. and Supreme Courts.
The only lawful way to regulate GHG emissions is to prepare a proper, HISA-compliant positive endangerment finding. Until that has been completed, and a lawfully conducted and scientifically robust positive finding returned, the CPP should not be replaced with any regulation at all.
Climate Science Findings
New research findings now make it all but certain that CO2 is not a pollutant but rather a beneficial gas that should not be regulated. This is because at this point, there is no statistically valid proof that past increases in atmospheric CO2 concentrations have caused what have been officially reported as rising, or even record setting, temperatures.
Moreover, new research findings demonstrate that adjustments by government agencies to the Global Average Surface Temperature (GAST) data render that data totally inconsistent with many other published and credible temperature data sets and therefore totally useless for any policy analysis purpose.
Adjustments over time to previously reported official data that imparted an ever-steeper upward trend in the data by removing the natural cyclical temperature patterns previously present in the data. These adjustments have deprived the GAST data from NOAA, NASA and Hadley CRU of the credibility required for policymaking or climate modeling. This is particularly true when such data are relied on to drive trillions of dollars in expenditures.
Finally, it is therefore inescapable that: if the official GAST data from NOAA, NASA and Hadley CRU are invalid, then both the ‘basic physical understanding’ of climate and the associated climate models will also be invalid – resulting in tens of billions in wasted climate research funding.
The CHECC Comment also referenced two recent letters to the EPA Administrator from over 85 highly credentialed scientists. They stated as follows: “We the undersigned are individuals who have technical skills and knowledge relevant to climate science and the GHG Endangerment Finding. We each are convinced that the 2009 GHG Endangerment Finding is fundamentally flawed and that an honest, unbiased reconsideration is in order.”
The Comment’s science findings section also presents rebuttals of ten typical climate change alarmists’ claims. [See also here.] The authors of these rebuttals are all recognized experts in the relevant scientific fields. The rebuttals demonstrate the falsity of all ten of the claims merely by citing the most credible empirical data on the topic. The ten now rebutted alarmist claims are as follows:
- Heat Waves are increasing at an alarming rate and heat kills.
Global warming is causing more hurricanes and stronger hurricanes.
Global warming is causing more and stronger tornadoes.
Global warming is increasing the magnitude and frequency of droughts and floods.
Global Warming has increased U.S. Wildfires.
Global warming is causing snow to disappear.
Global warming is resulting in rising sea levels as seen in both tide gauge and satellite technology.
Arctic, Antarctic and Greenland ice loss is accelerating due to global warming.
Rising atmospheric CO2 concentrations are causing ocean acidification, which is catastrophically harming marine life.
Carbon pollution is a health hazard.
This parade of horrible calamities that the 2009 Endangerment Finding predicts and that a vast program of regulation seeks to prevent have been comprehensively and conclusively refuted by empirical data. The 2009 Endangerment Finding should be rescinded and the Clean Power Plan replaced with nothing at all.
Energy Economic Findings
The Energy Economic Argument for rescinding the 2009 Endangerment Finding is that the CPP should not be replaced with anything because increasing the Fraction of Electricity Generation from Intermittent Renewables causes Enormous Consumer Electricity Price Increases and Serious Negative Macroeconomic Impacts. Real world examples in the Comment demonstrate that jurisdictions that have succeeded in increasing the percent of electricity from renewables validate the proposition that the more their power grid relied on renewables, the higher the electricity price -with price increases accelerating as the percent of electricity from renewables gets higher than 20% or so.
These real world case studies are corroborated by a September 2017 study by IHS Markit, titled Ensuring Resilient and Efficient Electricity Generation: The Value of the Current Diverse U.S. Power Supply Portfolio which analyzed the economic effects of state and federal energy policies that are driving electric utilities away from coal, nuclear and hydroelectric and towards renewables and natural gas. Such policies are forecast by IHS Markit to lead to a tripling of the current roughly 7% reliance on wind, solar and other intermittent resources, with natural gas-fired resources supplying the majority of generation. (This assumption now appears optimistic for NG penetration; that is, current trends would favor higher renewable penetration.)
The Study’s Findings are that current policy driven market distortions will lead to the: U.S. power grid becoming less cost-effective, less reliable and less resilient (see here at pp. 4 and 5; emphasis added). The study forecasts that these policies will cause a 27% increase in the retail price of electricity.
The following economic impacts of these policies were forecast:
- The 27% retail power price increase associated with the less efficient diversity case causes a decline of real US GDP of 0.8%, equal to $158 billion (2016 chain-weighted dollars).
Labor market impacts of the less efficient diversity case involve a reduction of 1 million jobs.
A less efficient diversity case reduces real disposable income per household by about $845 (2016 dollars) annually, equal to 0.76% of the 2016 average household disposable income.”
It should be noted that the Study’s projected 27% increase in average retail power prices is predicated on the wind and solar renewables share rising by three-fold from 7% to “only” about 21%. The case studies discussed in the Comment make very clear the enormous increases in power prices that would result as policy makers attempt to move the renewables grid penetration higher than that. Moreover, the study found that policies that promote increased use of wind and solar would likely result in little to no reduction in the level of electric sector CO2 emissions.
Based on these Energy Economic findings, the CPP should not be replaced with anything because increasing the fraction of electricity generation from Intermittent Renewables will cause (1) enormous consumer electricity price increases, (2) the Grid to become even less reliable and less resilient, and (3) even more serious negative micro and macroeconomic impacts – but would have zero impact on the climate. Based on the Comment’s reported science findings, this would be true whether or not the CPP Replacement managed to significantly reduce U.S. CO2 emissions from any and all sources.
One camp is transnational or international. On climate it is Orwellian and cargo cult. Big Brother does not want to convene debates. The people must accept whatever is announced by the Fake News/CIC. Facts are conveniently invented to support narratives, like the phony Russian Dossier funded by Crooked Hillary.
A competing camp examines the science. it favors reason, realism, debates, competition among ideas, elections, private sector innovation and energy.
It is healthy for any society to debate ideas and to criticize their weaknesses. All the more so if a purported problem is globally important, as alleged.
Distracted by terrorism, the dubya bush administration was too accepting of climate alarmism. Romney disparaged coal. Being weak on climate alarmism helps it fester.
This gives leftists a cause to support. More importantly Since it fails the scientific method, their cause ill serves society in diverse ways.
To bolster respect for real science, it is apt of CHECC to petition for rigorous reconsideration of the CO2 Endangerment Finding. The solution for bad science is countervailing better science.
This may help explain Doc Carlin. if the extremely low levels of carbon dioxide in the atmosphere, in reality essential to life on this planet, are perversely deemed endangering, then this is intrinsically absurd and profoundly anti scientific, plus anti environmental, all wrapped up in one.
CO2 is made up of one carbon atom and two oxygen atoms. Does Al Gore think there should be a social cost charged to Oxygen emissions owing to growing crops? He probably polled this idea and found the public would not believe it. Al loves taxes, so if he could justify taxing people for planting fruits, veggies, and flowers, he would. To save the earth from toxic oxygen, tax greenery.
The two most common elements used to make a human are oxygen and carbon. photosynthesis is central to life on this planet, giving us food and oxygen by which to breathe. We exhale CO2 to recycle it to enable more photosynthesis. This is only a positive.
Greatly Enjoyed this post, Doctor Carlin.
Loved mention the social cost of carbon is negative. I knew this intuitively or sumliminally, but had not considered the matter more consciously, not having cause to.
It reminds me of when you wrote that alarmism fails the scientific method. I had not thought of the topic in this basic and apt frame of reference. i had simplified it to BS or political lies. It is more formal to opine that alarmism falls short of satisfying the scientific method.
Nicer manners too!!!
Photosynthesis is understood in considerable depth. I expect photosynthetic reactions can be examined carefully, within well controlled small scale experiments. These establish and confirm reliable knowledge. Thus the benefits of plant growth from cO2 emissions should be reasonably and responsibly estimatable. The relationship is not quackery.
A theory tends to have a broad scope. For instance darwins theory of natural selection aimed to address all life on earth present and past. That is Ambitious scope. unsure it can be “proven”, but I believe it is still generally well regarded. I suspect some could challenge aspects of it, responsibly. I assume the theory can be built upon and improved.
Gores global warming theory is also an ambitious scope, but poor al is no intellectual Titan like Darwin. Gores theory involves the whole earth and all climate conditions, so it cannot be not measured. The mathematical models that express the theory do a poor job of predicting the future and explaining historical climates. gores theory is not well supported by scientific evidence persuasive to the critically minded, though many loyal alarmists value the quantity of supporting claims as opposed to the quality of supporting evidence.
I trust the reliability of understanding about photosynthesis, but am not persuaded by Al’s science. This is why I could trust an agricultural benefit estimate for CO2, whereas do not trust a social cost of carbon based on cargo cult quackary science.
One semantic quibble: “no statistically valid proof….”. Mathematics has proofs, whereas Statistics as a field concerns the unknown. There can never be a statistical proof about climate alarmism, pro or con. How about “despite abundant study, there is not robust scientific evidence to suggest higher reported levels of CO2 cause reportedly higher surface temperatures. The hypothesis that CO2 emissions raise temperatures or otherwise perturbate climate is not clearly supported by evidence.”
I am delighted to have it sink in finally that the social cost of CO2 emissions should be negative. This is because CO2 emissions are beneficial, increasing growth of trees and crops. The Dubya Bush Administration must have conceded CO2 emissions were harmful and assigned a cost resulting from emissions. Maybe Dubya was besotted with turning useful corn into ethanol, so as to buy votes in Iowa.
The case for harm resulting from CO2 emissions is weak and highly uncertain. There is no warming in temp data from satellites. And the three surface data sets are likely corrupted. Can anyone trust Mad Jim Hansen’s data?
So there is no reliable and plausible evidence of warming, just a lot of unjustified groupthink from lefty academics and unionized Federal workers. Cargo cult nonsense.
The only reliably known consequence of CO2 air emissions is to enable photosynthesis. CO2 emissions have reliably positive effects on crops, forests, and the economy. If the economic impacts are expressed negatively as a cost, then value assigned should be negative too. Doubled negatives provide the positive benefits accruing from CO2 emissions.
It’s highly laudable and compelling to emphasize that C02 is essential to life on this planet, despite being at trace levels.
It may merit added emphasis that atmospheric levels of essential CO2 are extremely low. Many layman may not realize how very low they are. 0.0000004 is a low number.
Great to make the point that the social cost of emitting carbon dioxide is negative. This makes an economics analysis directionally correct. living things gain biologically from emissions of CO2 and this also helps the economy. CO2 emissions are virtuous for the Biosphere, plus benefit the economy. A win-win. By following enlightened self interest, industry benefits the environment.
Learning this will astound the CIC.