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

, Senior energy analyst | June 12, 2015, 4:03 pm EDT
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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.


Posted in: Energy, Global Warming Tags:

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  • Nancy Freeman

    There are two of the 15 dirtiest power plants on the Navajo Reservation. Both Salt River Project and Arizona Public Service plants send the power off the reservation! The majority of the Navajo homes do not have electricity Bottom-line is that the Navajo’s air, food and animal plants, soil and lungs has been polluted for decades so that Arizona, Colorado and New Mexico residents can have cheap power. Cheap water in the case of AZ, as 50% of the SRP power goes for their CAP project to bring the Colorado River to Phoenix and Tucson. (the majority of the Navajos don’t have running water either) And you can bet the populace and the CAP officials are ranting and raving that they can’t afford the cost of providing clean power. Same song, second with APS plant.

    • ucsjrogers

      Thanks for weighing in, Nancy. The energy-water-climate picture in northern Arizona is indeed complicated. It’s pretty clear, though, that clean energy can be a big part of addressing a lot of the issues you bring up. Thanks for trying to help make that transition happen sooner. – John

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  • Richard Mann

    Getting off fossil fuels is an admirable goal. The problem is with industrial Scale wind turbines. These will not work until we have energy storage. Many have pointed this out.

    OSPE (Ontario Society of Professional Engineers) have written a number of reports that show the difficulty integrating intermittent wind energy into the electrical grid. For details look at the document “Engineering Expertise Vital to Success of Ontario’s Electricity System: OSPE”, Jan 16, 2013.
    Link: ospe DOT on DOT ca/news/113930/Engineering-Expertise-Vital-to-Success-of-Ontarios-Electricity-System-OSPE-.htm

    Engineers’ reports are significant because they are legally bound to report success (or failure) of their projects. Reading the reports you’ll see what we have suspected all along. Engineers must follow government mandate (move to Green energy), but they cannot show a reduction in C02.

    • ucsjrogers

      Thanks, Richard. You’re right that getting off fossil fuels is important; I think it’s clear that moving away from fossils is even imperative. And storage can play a part.

      But it’s also clear that there’s a lot more we can do even — a lot further we can go — before cheap bulk storage becomes necessary. Here’s how my colleague Laura Wisland put it recently (

      However, storage is just one of the many tools we have at hand to help
      us integrate renewables, and states do not have to wait for storage
      technologies to mature before they make greater investments in clean
      energy. Even though 29 states and D.C. have renewable energy investment
      programs, most don’t have enough renewables on the grid to require
      storage right now in order to go further.

      And a study just released by NREL and others looks at what other studies say about how we get to Clean Power Plan-like levels of wind and solar: I think you’ll find that storage is only a piece — maybe a minor one — of how we get to 20 or 30% renewable energy.

      So don’t let storage seem like a barrier at this point. We can and will do lots more in the meantime.



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  • Analysis which shows the cause of climate change:

    1. Establish a least-biased assessment of all reported measured average global temperatures (AGT).

    2. From examination of historical AGT and historical solar cycles, form the hypothesis that a relation exists between sunspot numbers and the planet warming and cooling.

    3. From examination of historical AGT and other information, determine that ocean cycles contribute to AGT and the effect of ALL ocean cycles on AGT can be approximated by a saw-tooth function with period 64 years and amplitude of approximately ±1//5 K (to be determined more precisely later).

    4. Apply the first law of thermodynamics (conservation of energy) to obtain an equation relating the historical measurements. Incorporate coefficients on each term in the equation to facilitate optimizing the equation to best match the calculated temperature anomalies to the measured temperature anomalies.

    5. Apply the mathematics of coefficient of determination, R2, to compare the calculated temperature anomalies to historical measured temperature anomalies.

    6. Adjust the coefficients in the equation alternately and repeatedly to obtain the absolute maximum R2. This results in R2 greater than 0.90 irrespective of whether the influence of CO2 is included or not and an equation which predicts a future down trend in average global temperatures.

    7. After Schwartz (2007) and other considerations, rapid (year-to-year) variations in reported average temperatures contain substantial random uncertainty as to the true energy content of the planet. This uncertainty is substantially removed by taking a running average of reported measurements. A 5-year running average increases R2 to greater than 0.97 leaving less than 3% to explain all factors not explicitly considered such as volcanos, aerosols, measurement errors, non-condensing greenhouse gases (the average sunspot number is a proxy accounting for average water vapor, the sunspot number anomaly is a proxy which accounts for cloud variations), difference from assumed wave form of ocean cycles, ice change, etc.

    This analysis, along with independent proof that CO2 has no effect on average
    global temperature (and therefore no effect on climate) is at .

    • ucsjrogers

      Thanks, Dan. But the science is pretty clear on this:

      “Natural changes alone can’t explain the temperature changes we’ve seen.
      For a computer model to accurately project the future climate,
      scientists must first ensure that it accurately reproduces observed
      temperature changes. When the models include only recorded natural
      climate drivers—such as the sun’s intensity—the models cannot accurately
      reproduce the observed warming of the past half century. When
      human-induced climate drivers are also included in the models, then they
      accurately capture recent temperature increases in the atmosphere and
      in the oceans… When all the natural and human-induced climate
      drivers are compared to one another, the dramatic accumulation of carbon
      from human sources is by far the largest climate change driver over the
      past half century.” (from UCS’s global warming FAQ page:

      You can see other information and links on UCS’s related webpages:
      * The sun and climate change –
      * Aerosols (Pinatubo or other) and climate change –
      * Climate change science –

      – John

      • The science is very clear. Natural changes explain all reported average global temperatures with R^2 = 0.97+.

        Part of the problem that many researchers have is that they can’t get past the idea that the only thing the sun can do is change brightness.

        Another common part of the problem is failure to grasp that forcings must happen for a duration to effect temperature. Thus the temperature responds as a transient proportional to the time-integral of the difference between the instantaneous forcing and the average forcing. Sunspot numbers are a near perfect proxy for the forcing.
        Equation (ii) compared to a 5-year running average of reported average global temperatures gives R^2=0.97+.

        Do you not understand that everything not explicitly included (aerosols are in the list of things not included) must find room in the unexplained 2+%? Referring to work that might disagree does not cut it.

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