New Flawed Study of the Clean Power Plan: How the MISI Study Gets It So Wrong

June 12, 2015 | 4:03 pm
John Rogers
Energy Campaign Analytic Lead

An op-ed in yesterday’s Investor’s Business Daily uses a new study to make unsubstantiated claims about the economic impacts of the proposed Clean Power Plan on vulnerable communities. Since the op-ed didn’t provide a link to the actual analysis, we hunted it down and took a look behind the headlines. And when we did, we found that the foundations of this new “analysis” are shaky indeed.

A house built on sand

The new study, conducted by Management Information Services, Inc. (MISI) on behalf of the National Black Chamber of Commerce (NBCC), purports to look at a range of EPA regulations, but focuses on the Clean Power Plan (CPP).


But here’s the first of the study’s fatal flaws: it depends, as it explicitly says (p. 21), on the findings of seven other studies, which it lists. But those seven include:

  • Three studies that came out before the EPA published the draft CPP, meaning they don’t actually study the CPP as proposed—even though that’s the supposed focus of the NBCC/MISI analysis
  • One that was just (self-described) “preliminary analysis” from the United Mine Workers of America, a group you’d be hard-pressed to characterize as an unbiased voice in this debate
  • Three other studies funded by other fossil fuel interests who oppose the Clean Power Plan

Two of those studies were the focus of a recent UCS webinar showing how such studies use bad assumptions and get used to sow confusion and spread disinformation about the CPP.

One of those, done by IHS on behalf of the U.S. Chamber of Commerce, is the report most cited in this new work, even though it was one of those that came out before the draft CPP, and even though there was, as the Chamber itself admitted, “a big difference” between what they’d modeled and what EPA put forth (which the new study doesn’t acknowledge).

The flaws in the study by Energy Ventures Analysis (EVA) for Peabody Energy (the largest U.S. coal company) are also clear. The Center for Climate and Energy Solutions has pointed out that, unlike other studies, EVA’s didn’t even show a business-as-usual case, meaning that any CPP results were floating in a vacuum, without reference to a base case of shifting energy costs and other economic factors.

Ignoring the bedrock

Equally telling are the studies that didn’t make NBCC/MISI’s literature review:

But you wouldn’t glean any of that from the new NBCC/MISI report. No, it follows in the footsteps of previous misleading studies by exaggerating the costs and ignoring the benefits of climate action.

The elephant in the neighborhood

And that brings up another of the study’s fatal flaws: it forgets about climate change. In the op-ed, the only mention of “mitigation” is about avoiding the supposed impacts of the regulation. And even in the study itself, nary a word.

If you ignore the benefits side of the cost-benefit equation, it's hard to come up with anything but bad news. But when you take a solid look at both sides of the equation, you see a pretty impressive net-positive.

Hard to believe, I realize. But somehow the author makes it through the entire study without mentioning global warming. This, a purported study of a regulation, but it doesn’t even acknowledge the incredible amount of science behind the need for just such a regulation. All it’s got is one mention of “warmer climates” and the importance of air-conditioning… which, it turns out, we’ll need more of as the climate warms.

And who is going to be disproportionately affected by that warming climate and other impacts? In many cases, the same vulnerable populations that the new study is supposedly defending.

On the other hand, that grievous omission isn’t entirely surprising, since the author of the study has claimed—despite the wealth of information very much to the contrary—that more carbon dioxide is actually a good thing. Not so much.

Poor science, bad policy

It all adds up to a study that Juan Declet-Barreto of the Natural Resources Defense Council calls:

“…a cynical attempt at co-opting the Latino and African American communities into rejecting the most significant controls to power sector air pollutants and toxics affecting their health and communities.”

The Clean Power Plan is about the fundamental need to address climate change, including on behalf of those who are least equipped to deal with its impacts. A study of the CPP that forgets that isn’t worth the electrons it’s printed on.

Poor science may make for good headlines, but it definitely makes for bad policy.


About the author

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John Rogers is energy campaign analytic lead at the Union of Concerned Scientists with expertise in clean energy technologies and policies and a focus on solar, wind, and natural gas. He co-managed the UCS-led Energy and Water in a Warming World Initiative, a multi-year program aimed at raising awareness of the energy-water connection, particularly in the context of climate change, and motivating and informing effective low-carbon and low-water energy solutions.