September 2012

On September 21, the Cooler Heads Coalition hosted a Capitol Hill briefing on “The Costs and Benefits of Green Jobs,” featuring Diana Furchtgott-Roth, Senior Fellow at the Manhattan Institute and author of a new book, Regulating to Disaster: How Green Jobs Policies Are Damaging America’s Economy.

Video of the briefing is below.

I can understand why President Obama would deny that his administration is waging a war on coal. In the midst of difficult economic times, it would be politically risky if he told the bald truth, that his administration has launched a pincer attack on both coal production and consumption, for no discernible purpose other than to placate a political constituency.

I do not, however, understand why informed reporters (most recently, at Politico) and esteemed colleagues (Cato) mistakenly posit that the war on coal is an empty rhetorical device. The truth is so obvious; I can’t fathom how they miss it.

Consider: In 2012, the Environmental Protection Agency promulgated two regulations—the Utility MACT (final) and the Carbon Pollution Standard (proposed)—that effectively ban the construction of new coal-fired power plants. This is extraordinary. An Agency within the Presidency, without a Congressional mandate, has closed the future for an industry that provides 40 percent of the nation’s electricity. And for what? Not for any public health benefit, to be sure.

The regulatory justification for the Utility MACT is particularly risible. Its purpose is to protect a supposed population of pregnant, subsistence fisherwomen, who consume at least 225 pounds of self-caught fish from exclusively the 90th percentile most polluted fresh, inland water bodies. You can’t make this stuff up! Notably, EPA never identified a single member of this putative population. Rather, they are modeled to exist.

The EPA’s case for the Carbon Pollution Standard is subtler, but no less pointless. In the proposed rule, EPA never even tried to tether the regulation to a specific benefit accruable to the American people. This makes sense, because there are no such benefits. U.S. policy on new electricity generation (like the Carbon Pollution Standard) is an insignificant driver of global greenhouse gas emissions relative to coal-fueled Asian economic growth. In fact, the Carbon Pollution Standard rested on a discretionary authority; there was no pressing concern. EPA merely exercised an option resulting from the Agency’s endangerment power grab.

Thus, neither the Utility MACT nor the Carbon Pollution Standard engenders a “real” public health benefit. On the other hand, the rules will cause expensive energy, which is a very real cost to be borne by all of society.

For existing coal-fired power plants, EPA’s strategy is to impose three types of expensive retrofits on every existing coal-fired power plant, regardless whether or not they would serve an actual purpose. The three controls are: selective catalytic reduction for nitrogen oxides; scrubbers for sulfur dioxide; and electrostatic filters for fine particulate matter. The aforementioned Utility MACT would require scrubbers and electrostatic filters. EPA is using the Regional Haze rule to compel selective catalytic reduction systems. Regional Haze is the archetype of all-pain, no-gain regulation. It’s an aesthetic regulation, whose benefits are literally invisible.

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Yesterday, by an 8-3 vote, the San Francisco Board of Supervisors approved CleanPowerSF, a municipal energy plan that would force about half the city’s ratepayers into using electricity that was generated entirely from renewable sources, like wind and solar power.

The cost? According to the San Francisco Chronicle, the measure would increase utility bills about 23 percent*.

And I thought renewable energy was supposed to be competitive! California already has the 13^th most expensive electricity rates in the country, so this 23 percent green energy premium is on top of relatively high utility bills. [updated 10:23 AM, 9/20/2012: I completely forgot to mention that this renewable energy is 23 percent more expensive than conventional energy (in a market, California, whereby a state law forbids the consumption of coal, the most conventional electricity source) after accounting for federal, state, and municipal subsidies. Moreover, I don’t know the extent to which this “100 percent” renewable power is “real” rather than an artificial construct. The grid requires a reliable flow of power, but renewable energy is intermittent, and there’s no technology to store utility-scale electricity. Therefore, I presume CleanPowerSF entails a reliance on imported hydropower (the “real” source of power) while the city purchases renewable energy credits (which are basically the environmental attributes of renewable energy produced elsewhere) equal to the amount of hydropower consumed. This is necessary because Californians don’t consider hydropower to be “green” due to the fact that it harms some kinds of fish. Again, this is reasoned speculation on my part–I can’t imagine how CleanPowerSF would work otherwise. I’ll post again when I find out.]

In addition to being expensive, CleanPowerSF is also coercive. On the basis of already-conducted public surveys that purport to have identified those neighborhoods that are willing to pay more for green energy, the city has chosen 375,000 customers who will be automatically enrolled into CleanPowerSF. That’s about half the ratepayer base. It is incumbent upon these unfortunate residents to opt out of the program. By making participation a default option, the city is trying to take advantage of humankind’s innate aversion to dealing with minutiae, and thereby compel (dupe) as many citizens as possible into using 100 percent green, expensive energy. It’s an old sales trick.

Evidently, San Francisco Mayor Ed Lee’s support for CleanPowerSF is tepid. There’s no guarantee he’ll lend his approval, which is necessary for the project to move forward. I appreciate his reservations.

As I’ve argued here, here, and here: San Francisco could have achieved its green dreams, at zero cost, by freeing the city’s electricity market from the shackles of socialism. Instead, municipal leaders have opted to trade one government granted monopoly (PG&E) for another (Shell, the sole provider of electricity for CleanPowerSF).

*The Chronicle reports that the San Francisco Public Utilities Commission estimated that lower income customers, with utility bills of $40 per month, would see an increase of $9.55. For the average monthly utility bill, which the Energy Information Administration pegs at $81 in California, the San Francisco PUC estimated that the increase would be $18.53.

Although harvesting season for corn is ongoing, there isn’t much hope from the Agriculture Department for a strong season. We know that production levels are already down 13 percent from 2011. Adding to the hurt caused by this year’s devastating drought on corn is the Renewable Fuel Standard (RFS). Under the Clean Air Act the RFS requires that in 2012, refiners sell 13.2 billion gallons of corn ethanol – this number equates to roughly 4.7 billion bushels of U.S. corn.  Corn estimates were down to 10.8 billion bushels last month; right now that means that at least 40 percent of corn production is being forced into the ethanol market.

The decline in corn production is already leading to rising prices in various farming sectors — cattle, swine, poultry — that use corn as feed. These economic effects will be intensified by the diversion of corn supply by ethanol requirements. This has prompted Congress, National Associations, and now individual state Governors to urge the EPA to permit a waiver for ethanol requirements in 2012-2013 under the Renewable Fuel Standard.

In Governor Deal’s August 20th letter to EPA Administrator Lisa Jackson describes the importance and scale of the livestock agriculture to the Georgia economy:

As Georgia’s largest industry, agriculture accounts for over 15.7 percent of the state’s economy in terms of sales and output and represents 11.2 percent of the state’s value added production. Georgia agriculture has an annual impact of $68.9 billion on the state’s economy and provides 380,000 jobs to citizens of the state.  Poultry and livestock are critically important components of the state’s economy, representing over 50 percent of Georgia’s farm gate value, while broilers alone account for over 40 percent of farm gate value. From a national perspective, Georgia ranks first in broiler production and third in value of eggs produced. For Georgia, the poultry industry alone accounts for over $20 billion in annual economic impact, and an estimated 98,000 jobs depend on poultry directly or indirectly.

He also points out the grueling effects the Renewable Fuel Standard will have on not only Georgia, but the whole country coupled with this drought:

According to the University of Georgia, the state’s poultry producers are spending $1.4 million extra per day on corn due to the drought and the upward pressure on corn prices caused by the demand created by the RFS for ethanol. This translates to over $516 million per year if these market conditions continue. These additional input costs are not sustainable, and I urge you to consider all options available to the agency to provide some relief in the coming year.

The ultimate impact on consumers in Georgia and throughout the United States in the form of higher food prices must also be fully considered. A recent analysis confirmed that food inflation, particularly for those food categories most impacted by grain costs, has risen much faster than overall inflation since 2005. The reality of this current crisis is that consumers will have to pay more for protein and other food items, or they will simply not be able to afford certain food items.

As I have outlined, Georgia is experiencing severe economic harm during this crisis, and important economic sectors in the state are in serious economic jeopardy. This harm is precisely of the type, character and extent that Congress envisioned when it granted EPA authority to waive RFS applicable volumes in both the original RFS enacted in 2005 and in the substantial revisions made to the law in 2007 by the Energy Independence and Security Act.

Other states such as; Arkansas, Texas, North Carolina, and others have also filled letter with Administrator Jackson.

On August 20th the EPA opened a 30 day comment period for the public on the waiver requests specifically from the Governors of Arkansas and North Carolina. This week, the comment period was extended another 30 days. After the comment period ends, EPA is afforded time to consider the public’s input. As a result, EPA won’t have to make a decision until after the election. How convenient.

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Today, the Environmental Protection Agency imposed on Montana a Federal Implementation Plan under the Regional Haze Rule that will cost scores of millions of dollars, but achieve no discernible purpose.

Specifically, EPA is requiring $82 million in unnecessary capital expenditures at the Colstrip coal-fired power plant located east of Billings, Montana, in order to engender an ‘improvement’ in visibility that is imperceptible to the eye.

Don’t take my word for it! See the images directly below. They depict the visibility “benefits” wrought by EPA’s regulations. They were generated using WinHaze visibility modeling software, with inputs from EPA data.

Notably, these mandated controls are 500% more expensive than what EPA’s standing rules presume to be “cost-effective.” Given that the benefits are invisible, the severity of these Regional Haze requirements suggests that EPA’s motivations were political.

Remember, environmental special interests are a significant component of the President’s organizational base. And for them, coal is evil, because it is “dirty.” That’s why, way back in 2008, then-Senator Barack Obama told the San Francisco Chronicle editorial board that he would “bankrupt” the coal industry if elected President. Now, EPA is following through on the President’s promise. The powers of the presidency are the means by which he satisfies the environmentalists’ desired ends. To be sure, it’s an American outrage that the fate of an entire industry can thus be subjected to the capricious winds of presidential politics, but that’s a different blog post. For now, it suffices to say that this Administration is imposing billions of dollars of costs, in the midst of difficult economic times, in order to placate a political constituency, and for nothing else.