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Unpacking the Coal Lobby's Claims about NRDC's Carbon Pollution Standards Proposal

Dan Lashof

Posted November 15, 2013

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The so-called American Coalition for Clean Coal Electricity (ACCCE) will go to any lengths, including manipulation and mischaracterization, to ensure that coal-fired power plants are allowed to continue dumping unlimited carbon pollution into our air.

This week, ACCCE sent a misleading letter to Energy and Power Subcommittee Chairman Ed Whitfield summarizing their pro-pollution report. The report, not yet released as of today, is an attempt to critique NRDC’s proposal outlining cost-effective ways to reduce carbon pollution under the Clean Air Act. From the summary information released by ACCCE in its letter, it is clear that they use biased assumptions, make misleading comparisons, and completely ignore the benefits of reducing pollution. Despite all that, their analysis actually shows that carbon pollution standards would produce benefits that far exceed their own inflated cost claims. Here are some key points that emerge from just the limited information ACCCE has made available so far:

  • ACCCE reports its inflated costs in cumulative terms and compares those to annual average carbon emission reductions--a misleading comparison, designed to make costs look large and benefits smaller. Doing the math to compare apples to apples, ACCCE’s own worst case has cumulative benefits that exceed their inflated costs by more than two to one! (484 million tonnes/yr X 16 years X $43/tonne = $333 billion, compared to claimed cumulative costs of “as much as $145 billion.” This is based on the administration’s very conservative number for the benefits of carbon reductions in 2020 and does not include the benefits from SO2 reductions, which are likely about as large in aggregate).
  • ACCCE compares NRDC’s estimated yearly cost of $4 billion to its own inflated costs added up over 15 years. It’s misleading to make a confusing comparison of a one-year cost to a 15-year total cost.
  • ACCCE includes only the upper end of a range, with slippery language such as “as many as 83 GW” of additional coal retirements.
  • ACCCE ignores the NRDC jobs analysis, released in July, showing our proposal would create over 200,000 jobs in the U.S.
  • ACCCE uses an upwardly biased estimate of energy efficiency costs. This assumption is presumably responsible for driving up the overall costs of reducing emissions and driving up demand for natural gas and hence natural gas prices. NRDC’s analysis showed that emission reductions could be achieved without driving up natural gas demand or prices by relying primarily on energy efficiency to reduce carbon pollution.   

Although we’ll need the full analysis to get to the bottom of ACCCE’s summarized conclusions, the group has a long history of manipulation in pursuit of their agenda, exaggerating the benefits of burning coal while artificially inflating the estimated costs of reducing carbon pollution. The consulting firm that conducted this study for ACCCE, the National Economic Research Associates (NERA), also has a history of producing biased analysis for industry clients. See my colleague Laurie Johnson’s tracking of ACCCE studies here, here, and here.

A more trustworthy study done for NRDC—by the same firm used by the utility industry and the government to evaluate federal rules—shows the EPA can cut carbon pollution from power plants by at least 25 percent this decade. With flexibility for states and power companies, those cuts deliver up to $15 in health and environmental benefits for every $1 in costs. A subsequent analysis by Synapse Energy Economics, released by NRDC in July and ignored by ACCCE, shows that our proposal would also create over 200,000 jobs for electricians, carpenters, insulation installers and other American workers. No matter how much ACCCE tortures economic models, the facts on the ground are clear: Clean energy works for America.

It’s also clear that the U.S. Environmental Protection Agency should move forward to develop common sense standards reducing carbon pollution from power plants. We limit mercury, arsenic and soot from these plants, but not the key driver of climate change. That’s not right and it’s not safe. We have an obligation to protect future generations, and that means we need to put limits on carbon pollution…no matter how much the coal lobby complains about it.

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