This week, the Trump Administration’s Environmental Protection Agency (EPA) will finalize carbon pollution standards for fossil fuel-fired power plants. Bold federal action on climate change could not come at a more urgent time. Except this rule will be bold for all the wrong reasons.
In the past two and a half years, 32 weather and climate-related disasters have totaled at least a billion dollars in damages each, together affecting at least 44 states and totaling more than $413 billion in costs. From raging wildfires to roiling floodwaters, searing temperatures to deepening droughts, the shocking impacts of climate change have lengthened in reach and strengthened in punch, ravaging communities and upending livelihoods all across the nation.
These devastating events have been made starker still with the parallel clarity that has emerged around the science of where the climate is headed and the magnitude of ambition it will take to avoid that dismal place.
It’s no surprise, then, that climate change has skyrocketed in political salience as a key voting issue and that states, cities, and corporations have begun committing to ever higher levels of renewables to clean up their power supply.
Which brings us to today, and the Trump administration’s mandated plan for limiting emissions from power plants, the country’s largest stationary source of global warming pollution. Cutting these emissions is a linchpin of our nation’s contribution to global efforts to limit the harms of climate change, here and abroad. Except from an administration that gleefully jackhammers facts on the daily and an EPA with a former coal lobbyist at the helm, we get this, the “Affordable Clean Energy” (ACE) rule, which will at very best tinker at the frayed fringe edges of the problem, minimally boosting efficiencies at coal plants while at the same time advancing a mile-wide loophole that would allow those exact same plants to be exempt.
It takes dedicated work to justify such a gallingly insipid response to incontrovertible evidence on climate, on health, on economics, and on an affirmative statutory obligation to act—but then again, this administration has had a whole lot of practice, and a whole lot of gall to boot.
Here are five attacks on science we’ll be on the lookout for as the administration attempts to subvert facts and evidence in order to eviscerate climate action and arrive at this stunning polluter reprieve.
1. Don’t acknowledge dead people
In the Regulatory Impact Analysis (RIA) accompanying the proposed rule, the EPA demonstrated what has now become a favorite administration point of attack: rejecting the science that makes clear there is no safe level of exposure to one of the most hazardous types of pollution—fine particulate matter (PM2.5)—thereby clearing a path to ignore significant numbers of premature deaths.
The upshot of this counter-to-scientific-evidence approach is that the EPA could now report far lower numbers of premature deaths associated with its final rollback, which in the last go-around, according to Office of Air and Radiation Assistant Administrator Bill Wehrum, resulted in an “unfortunate” bit of reporting when headlines unsurprisingly led with the fact that the EPA’s proposal would result in “up to 1,400 more deaths a year.”
2. Actually, don’t acknowledge any people
When it comes to considering different regulatory scenarios and understanding the relative impact of a rule, the associated costs and benefits of regulatory action can be hugely helpful in puzzling out what the various effects may be. Except the Trump administration is now in an all-out battle to limit what counts as a “benefit,” suggesting that only a narrow subset of health and environmental benefits accruing from any given rule should ever be considered at all.
For the ACE rule, look for the Trump administration to lead with a reporting of benefits limited just to the (curtailed) calculations from reducing carbon, while comparing that to the whole of direct and indirect costs of implementation—meaning the administration will outright ignore the enormous public health benefits simultaneously arising from limiting pollution by coal-fired power plants, like fewer premature deaths, heart attacks, asthma attacks, emergency room visits, missed work days, missed school days, and on, and on, and on. Of course, it’s not that these effects will go away; the Trump administration just wants us to no longer acknowledge that they exist. Why the Orwellian dictate? Because these effects are all to the towering benefit of the public, meaning pleading the case of a select polluting few would otherwise look a whole lot worse.
3. Assign a vanishingly small number to the value of acting on climate
Another way to mask the need for regulatory ambition is to minimize the apparent magnitude of the problem itself. In the proposed ACE rule, the Trump administration employed a deeply diminished value for the “social cost of carbon,” or SCC, which is a calculation that attempts to assign a value to the climate benefits (or avoided climate costs) per ton of carbon dioxide reduced in the atmosphere.
The administration slashed the value by first ignoring how cutting heat-trapping emissions in the US has globe-spanning benefits (and conversely, how not cutting heat-trapping emissions in the US has globe-spanning costs—the scientific reality of a global pollutant like carbon emissions), then only considering a subset of “home” by limiting domestic considerations to the lower 48—thereby excluding the far-flung states, territories, possessions, and bases reeling on the front lines of climate change—and finally by applying to whatever was left an inappropriate and indefensibly high discount rate so as to further sink the apparent value of action.
4. Implicate the fewest polluters with the lightest touch
The president campaigned on an outright repeal of the Obama-era Clean Power Plan, but once in office, his administration quickly ran up against the reality of being statutorily required to act. The resulting proposed replacement did everything it could to handcuff its own ability to regulate, including by ignoring the historic transition underway in the power sector and adopting a purposefully blinkered view of how the power sector works, which all combined to arrive at a “best system of emissions reduction” (BSER) that was so weak as to hardly register at all.
Previously, this administration failed to reckon with the massive and compelling record underpinning the Clean Power Plan; in the final rule, we’ll look to see if they do more of the same, and in the process leave themselves highly vulnerable to court challenge. We’ll further keep an eye out for whether natural gas plants remain excluded from regulation, despite their now-dominant role in the electricity generating mix and their growing contributions to power sector carbon emissions. And though we now expect changes to the New Source Review program to be advanced under separate cover, we will be looking to see if the agency maintains its significant proposed changes to the implementing regulations, which stretched out timelines and gave states effectively unlimited permission slips to decline to act, thereby greenlighting a race to the bottom and a standard that doesn’t actually require any action at all.
5. Keep attacking science from all sides
In addition to all the attacks on science, health, and the environment within the rule, the Trump administration has also steadily advanced an unrelenting barrage of attacks on science, health, and the environment from outside the rule as well. From attempting to limit the science that is allowed to inform regulations, to hamstringing the scientific advisory committees that provide expert and leading advice on complex issues, to propagating changes to how climate impacts are analyzed to minimize the case for action, to formalizing the exclusion of vast swaths of public health benefits from rulemaking—science is under attack, and the administration is demolishing the very foundations on which the EPA, with a mission to protect human health and the environment, can stand.
Subverting truth for profit, paid for by the public
Who wins when an administration actively hides evidence that the public will be harmed by the actions it proposes to take? What happens when an agency charged with protecting human health and the environment bars science and analysis revealing thousands more will die? Where will we be when facts no longer count?
For the profit margins of a select polluting few, the Trump administration is attempting to find out, subverting truth for money and public health for polluter profit gain.
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