The supporters of the rule argue that it is just a part of a larger effort to reduce global greenhouse gas emissions by an amount sufficient to limit temperature increases to 2 degrees. But under the assumptions of the plan's supporters, that would require a global emissions reduction of almost 80%, a goal impossible both economically and politically.
In brief, the rule would mandate an aggregate reduction of 30% in power plant emissions below 2005 levels by 2030, with specific reduction requirements imposed on each state. It allows "flexibility" for the states in how they lower emissions (through efficiency standards, cap-and-trade programs, etc.), ostensibly to reduce the costs of meeting the requirements. But it is obvious that a major purpose of the flexibility is to obscure the ways in which implementation will proceed, and thus to hide the true cost of the emission reductions. Those costs are certain to be large; that is why the proposed rule is so contentious. One recent estimate from the
More interesting is the wide difference in cost effects across the states. As coal-fired electricity is more emissions-intensive than other kinds of power generation, the rule will increase power costs more in states especially dependent on coal-fired power, and impose higher economic costs in states in which the coal industry is a bigger part of the economy.
It is no accident that the states that will bear the brunt of the costs are red politically. Thus, the effect of the rule will be to increase energy costs in red states relative to those in blue states.
The Obama "carbon" policy promises to raise costs in the latter states disproportionately, because they will have to reduce emissions by far more, thus reducing their advantages in terms of economic competition.
The combination of large costs and zero climate benefits explains why the president argued in a recent radio address that the new rule would prevent "up to 100,000 asthma attacks and 2,100 heart attacks" in the first year, rising thereafter, presumably because of ancillary reductions in such other effluents as particulates, mercury and nitrogen oxides. (Carbon dioxide does not cause adverse health effects even at concentrations many times higher than those current or projected.)
But those pollutants already are regulated under other sections of the Clean Air Act, and the legal requirement is that those regulations "protect the public health" with an "adequate margin of safety," without consideration of costs. Is it the position of the Obama administration that those regulations do not satisfy the requirements of the law? Or is the EPA double-counting the health benefits from other regulations already in force? Or is the EPA assuming further health benefits from reducing pollution levels that already are lower than those at which the epidemiological analyses suggest no adverse effects?
No one knows, because the EPA analytic methodology to a substantial degree is obscure and the EPA's answers to analysts' questions often are unclear.
Given the minuscule effect of this policy on global temperatures under the standard climate models, it is clear that the administration's touting of other health benefits is a political maneuver. As used by proponents of the plan, the terms "carbon" and "carbon pollution" are little more than propaganda. "Carbon" is not carbon dioxide, a natural substance not toxic to humans at many times current ambient concentrations; and to define carbon dioxide as "pollution" is an attempt simply to assume the answer to the central policy question.
The real pollution attendant upon this proposed regulation is that of our political institutions. A