Tag: "EPA"

Adaptation Strategies for Climate Change

Although negligibly, climate change is happening, and addressing the issue in the short-term may prevent drastic future effects. When determining how to actually address climate change, two main strategies exist: mitigation and adaptation. While these two may appear similar, a nuanced difference distinguishes the two. Mitigation addresses the causes of climate change, while adaptation addresses the effects of climate change. Even though adaptation is a form of mitigation, it attempts to mitigate the harmful effects, not the causes. According to the Environmental Protection Agency (EPA), adaptation strategies can be either protective (guarding against the negative impacts of climate change) or opportunistic (taking advantage of any beneficial effects of climate change).

While an exact range is not agreed upon, most studies predict that the global mean in temperature has and will continue to rise. Some predict marginal gains, while others predict a drastic spike. Nevertheless, most agree that climate change is happening, and the evidence clearly reveals a trend in increasing temperatures. However, even though a consensus exists with regards to the veracity of climate change, no consensus exists on its causes. If the exact causes are unknown, nations spending money on mitigation strategies are taking shots in the dark at trying to stop climate change. Thus, nations may find adaptation measures more economically sensible than mitigation, as these strategies are a guaranteed way of protecting society.

As adaptation clearly appears the appropriate method of addressing climate change, many different strategies have been proposed to protect various sectors and industries. However, while the strategies may differ, the process of planning effective adaptation strategies tends to follow a similar, cyclical pattern for most nations. Here are the most common and effective six steps, according to the National Research Council:

  1. Identify current and future climate changes relevant to the system.
  2. Assess the vulnerabilities and risks to the system.
  3. Develop an adaptation strategy using risk-based prioritization schemes.
  4. Identify opportunities for co-benefits and synergies across sectors.
  5. Implement adaptation options.
  6. Monitor and reevaluate implemented adaptation options.

With this established methodology for discovering and implementing adaptation strategies, the EPA has given various examples of policies for each sector.

SECTOR ADAPTATION STRATEGY
Agriculture and Food Supply
  • Breed crop varieties that are more tolerant of heat, drought, and water logging from heavy rainfall or flooding
  • Protect livestock from higher summer temperatures by providing more shade and improving air flow in barns
Coasts
  • Promote shore protection techniques and open space preserves that allow beaches and coastal wetlands to gradually move inland as sea levels may rise.
  • Identify and improve evacuation routes and evacuation plans for low-lying areas, to prepare for increased storm surge and flooding.
Ecosystems
  • Protect and increase migration corridors to allow species to migrate as the climate changes.
  • Promote land and wildlife management practices that enhance ecosystem resilience.
Energy
  • Increase energy efficiency to help offset increases in energy consumption.
  • Harden energy production facilities to withstand increased flood, wind, lightning, and other storm-related stresses.
Forests
  • Removing invasive species.
  • Promoting biodiversity and landscape diversity.
  • Collaborating across borders to create habitat linkages.
  • Managing wildfire risk through controlled burns and thinning.
Human Health
  • Implement early warning systems and emergency response plans to prepare for changes in the frequency, duration, and intensity of extreme weather events.
  • Plant trees and expand green spaces in urban settings to moderate heat increases.
Society
  • Developing plans to help elderly populations deal with more extreme weather.
  • Relocating communities where in-place adaptation is not feasible.
  • Considering how the private sector can support and promote adaptation.
  • Understanding the specific needs of sensitive populations.
Transportation
  • Raising the level of critical infrastructure.
  • Changing construction and design standards of transportation infrastructure, such as bridges, levees, roads, railways, and airports.
  • Abandoning or rebuilding important infrastructure in less vulnerable areas.
Water Resources
  • Improve water use efficiency and build additional water storage capacity.
  • Protect and restore stream and river banks to ensure good water quality and safe guard water quantity

Often times, an effective strategy takes the dual-mandate approach, implementing adaptation and mitigation processes. However, with mitigation looking less effective each day, going all in on necessary adaptation strategies seems to be more appropriate. While mitigation strategies may buy a little more time in the long-run, adaptation strategies must take precedence as they will have definitive positive impacts. Rather than implementing new regulations to curb carbon emissions or regulate business, the federal government should work to prioritize the protection of these industries.

Tanner Davis is a research associate at the National Center for Policy Analysis.

EPA Attacks Coal

Part of President Obama’s plan to fight climate change includes closing down 140 existing coal fueled power plants. The plan calls for a shift from carbon emitting sources of energy to more efficient renewable source that will do less to affect the climate.

Impact of government action:

  • 140 coal plants closed
  • Those plants account for only 4 percent of all CO2 emitted last year by U.S. coal plants
  • Coal facilities will provide 30 percent of the nations’ electricity
  • Down from 52 percent in 2000
  • 35,000 to 38,000 coal industry jobs lost

According to USA TODAY:

The electric power industry’s plan to retire more than 10 percent of its coal-fired generators within a decade will do almost nothing to reduce emissions of heat-trapping carbon dioxide.

EPA Advancing on Numerous Fronts

The Environmental Protection Agency has been all over the new recently with a flurry of activity. Joining the President’s strategy of going forward with their agenda and without Congress, the EPA is taking bold steps while receiving some harsh criticism.

The latest action by the EPA directs bold new standards/regulations on carbon emissions. According to the EPA, by 2030:

  • Cut carbon emission from the power sector by 30 percent nationwide below 2005 levels, which is equal to the emissions from powering more than half the homes in the United States for one year.
  • Cut particle pollution, nitrogen oxides, and sulfur dioxide by more than 25 percent as a co-benefit.
  • Avoid up to 6,600 premature deaths, up to 150,000 asthma attacks in children, and up to 490,000 missed work or school days — providing up to $93 billion in climate and public health benefits.
  • Shrink electricity bills roughly 8 percent by increasing energy efficiency and reducing demand in the electricity system.

While the EPA clearly states some benefits to the new carbon emissions regulations, greater consequences could result from such carelessly calculated action. Electricity rates could skyrocket and the entire economy suffer.

According to the Heritage Foundation there will be serious economic damage:

  • Cumulative gross domestic product (GDP) losses are nearly $7 trillion by 2029 (in infla­tion-adjusted 2008 dollars), according to The Heritage Foundation/Global Insight model (described in Appendix A).
  • Single-year GDP losses exceed $600 billion (in inflation-adjusted 2008 dollars).
  • Annual job losses exceed 800,000 for several years.
  • Some industries will see job losses that exceed 50 percent.

Further action by the EPA has modified the Clean Water Act and directly affects the definition of water ways and the productive aspects of agriculture. EPA also modified the Reasonable and Prudent Alternative (RPA).

The EPA ruling on carbon emission gives the opponents of the Keystone XL Pipeline greater hope that they will succeed in their fight on the pipeline front.

“Going it alone” is a reckless decision for the entire Obama administration. Already reinforcing greater partisan divisions in Washington, completely ignoring entire branches of our government will only lead to greater problems for our entire country.

Fracking Bans Continue to Proliferate

The city government of Denton, TX has recently voted to impose a temporary moratorium on any new fracking wells until September of this year, and it is looking to make it permanent. They would not be the first community to do so.

Food and Water Watch, a non-profit NGO, tracks the number of communities across the nation that ban fracking operations. Three states (New Jersey, New York and Vermont) and the District of Columbia have all banned fracking. Indeed, over 400 counties and municipalities across 21 states have also passed anti-fracking measures.

Such bans arise from safety concerns, including groundwater contamination. Yet, an Institute of Energy Resource report reveals that even though over 1 million fracking wells having been drilled in the U.S., the EPA has not found any confirmed incidents of groundwater contamination from fracking. Even Lisa Jackson, then head of the EPA, has stated, “In no case have we made a definitive determination that the fracking process has caused chemicals to enter groundwater.”

While the risks from fracking operations are often overblown, the benefits of fracking to the American economy and the environment are not:

  • A Penn State University study found that between 2007 to 2010, Pennsylvania state sales tax revenues declined by 3.8%. While state sales taxes increased by 11.4% on average among those counties with high numbers of fracking wells, it decreased by 6.6% on average in those counties without any fracking wells.
  • The Institute for Energy Research estimates that in the near-term, over half a million jobs and $32 billion in wages will be added to the nation’s payrolls annually, which is an average income level of nearly $60,000. State and local tax revenues would increase by more than $10 billion annually. Further, the federal government stands to add $24 billion dollars in tax revenues annually, which would help offset our persistent federal deficit spending problem.
  • A U.S. Energy Information Administration report reveals that oil and gas industry employment grew by 40% between 2007 and 2012, which far outpaced the 1% rate of employment growth in the U.S. economy during that same period.
  • An EPA report estimates that greenhouse gas production from power generation has fallen by 11%, due largely to energy companies switching to burning natural gas for power generation instead of burning coal and oil. Aggregate U.S. carbon dioxide emissions have fallen from a peak of 7.3 billion metric tons emitted in 2007 to 6.5 billion metric tons emitted in 2012. This is a market response to lower natural gas prices caused by increased gas production from fracking.

One can only hope that the remaining communities located over oil shale areas will weigh the benefits and costs more carefully before considering a local fracking ban.

Is the EPA Playing Politics?

According to reports, the Environmental Protection Agency (EPA) may have held back on the publication of a new energy regulation in order to protect Democrats in the 2014 midterm elections.

In June 2013, President Obama asked the EPA to issue rules regulating carbon dioxide emissions from power plants, and the EPA proposed such standards on September 20, 2013.

But this is where the agency started to deviate from normal procedure.

Typically, rulemaking goes like this: The EPA proposes a new rule (usually, it announces this on its website for the public to see) and then — generally within five days — it submits the rule to the Federal Register for publication. Once published in the Federal Register, the public has a limited number of days to comment on the proposal. Notably, the Clean Air Act requires the EPA to finalize emissions rules for new power plants within one year of publication in the Federal Register.

But the September emissions rule was not sent to the Federal Register within five days. It was not even sent there a month later. Instead, a full 66 days after the rule was proposed, the EPA finally sent the proposal to the Federal Register for publication, on November 25, 2013.

What does this have to do with the 2014 midterms?

Because the publication date determines when the rule is finalized, pushing the publication date to January 2014 meant that the controversial rule would not become final until January 2015.

But had the EPA followed protocol and submitted the rule for publication in September within the usual 1-5 day window, it would likely have been published just prior to the November 2014 midterm elections. Senator James Inhofe (R – OK) said just this in a letter to EPA Administrator Gina McCarthy:

The costs of the President’s [greenhouse gas] regulations are going to be enormous with far-reaching and irreparable impacts on our electricity generation capacity, affordability and reliability. With this in mind, it makes sense that the American public would react negatively to the finalization of this first round of [greenhouse gas] regulations…This makes the timing of your proposal very important. If the rule was finalized by September 20, 2014, the American people would have about six weeks to consider the negative impact of the rule on the economy prior to going to the polls. In addition to this, my colleagues and I would have been able to force a vote on a resolution of disapproval against the final rule…This possibility of electioneering is deeply troubling.

Had the EPA submitted the rule in a timely fashion, lawmakers could have been forced to take a stand on it prior to the November elections.

The EPA has blamed the delay on consistency needs and “formatting” (it is not entirely clear what would make this rule so unique that it would require two months of formatting…), as well as the government shutdown. But the shutdown did not start until October 1, seven working days after the rule was proposed. As Sen. Inhofe said:

If the EPA had followed…protocol, the [New Source Performance Standards] rule would have been submitted to the Federal Register’s office two full working days before the shutdown.

Perhaps most damning of all, Administrator McCarthy, testifying before the Senate Environment and Public Works Committee, said, “I will assure you that as soon as that proposal was released, we had submitted it to the Federal Register office.” She went on: “The delay was solely the backup in the Federal Register office.”

The Office of the Federal Register disagrees. Federal Register Director Charles Barth said that his office did not receive the EPA’s proposal until November 25. Moreover, once the agency did receive it and scheduled it for publication on December 30, the EPA requested that publication date be pushed forward even farther, to January 8, 2014!

Politico reports that the EPA says it pushed for the delay because it did not want to release the rule during the holidays. So the government wanted to wait and release controversial news when the public was actually paying attention? That would be a first.

Government Subsides Help Distort Science

A $500,000 study released this past Sunday in the peer-reviewed journal, Nature Climate Change, detailed how corn-based biofuels release seven percent more greenhouse gases in the initial five-year time frame compared with conventional gasoline. The study which was paid for by the federal government found that regardless of how much corn residue is taken off the field, the process contributes to global warming.

But administration officials who have devoted more than a billion dollars of taxpayer funds as well as the biofuel industry disagree. DuPont claims that the ethanol it will produce will be 100 percent better than gasoline in terms of greenhouse gas emissions. The Environmental Protection Agency (EPA) says the study “does not provide useful information relevant to the life cycle greenhouse gas emissions from corn stover ethanol”.

But there are reasons to doubt DuPont and the EPA. DuPont is getting billions in subsidies to produce biofuels. Federal subsidies help its stock price; the company would be foolish if it did not defend biofuels. Meanwhile an Associated Press investigation last year found that the EPA’s analysis of corn-based ethanol failed to accurately predict the environmental consequences. California regulators earlier declared that corn ethanol would not reduce global warming and may in fact make it worse. Other federal studies have reached the same conclusion. David Tillman, a researcher at the University of Minnesota who has researched biofuels emissions from the farm to the tailpipe, says the recent study is the best he has seen on the issue.

This controversy highlights several problems. Despite claims to the contrary, politics seem to play a part at the EPA. The EPA could have simply released a statement that research in this area is still developing and it is sticking with its initial conclusion that biofuels improve the environment. By issuing such a strong rebuke, it seems the organization is not open to new information. Real scientists know new discoveries come along all the time. Scientists do not offer blanket statements, but politicians do.

Further, no matter how well intentioned, subsidies distort the market. Reducing carbon emissions is a good goal, but when government picks a winner everybody else loses. We do not know if there is a better solution that corn-based ethanol. We do not know if the EPA is investing in real science or attaching itself to its preferred winner. The EPA’s role should be to judge the best solution the private sector develops. When the EPA provides subsidies to one technology over another, taxpayer money and possibly scientific integrity are lost forever.

Power Grid Reliability as Coal Plants Retire

As the Obama administration’s EPA continues to promulgate regulations that will effectively close coal plants, or prevent the construction of new ones, much of the debate over these regulations, and coal in general, has centered on the appropriateness of coal as an energy source — is it too polluting? Will it hurt the environment? Is it worth the cheap cost? Are coal alternatives too expensive?

There has been less focus, however, on the ability of the power grid to meet U.S. demand if more coal plants continue to go offline. While industry groups, states and energy companies have raised these concerns, the American public remains largely unaware of the ramifications of dialing back coal-powered electricity generation.

To much of the general public, the EPA’s regulations are simply making for a safer, happier, cleaner world.

But on April 10, the Senate Energy and Natural Resources Committee held a hearing on the reliability of the electric grid. At the hearing, Senator Lisa Murkowski made a rather astonishing statement: “Eighty-nine percent of the coal electricity capacity that is due to go offline was utilized as that backup to meet the demand this winter.”

The New York Times reported on this issue back in March — noting that it was American Electric Power, a Midwest energy provider that was running 89 percent of its soon-to-be-retired coal plants. And PJM Interconnection, a power grid operator that serves Pennsylvania, Maryland, and Ohio, among other states, set a record for peak energy use this winter season.

Next year is an especially significant year for coal, as April 2015 is when coal plants are required to be in compliance with the EPA’s Mercury and Air Toxics Standards rule. Compliance with the rule effectively means shutting down operations or spending hundreds of millions of dollars to conform — spending that will, of course, find its way into consumers’ power bills. Some parts of the U.S. already saw electricity prices this winter that were a whopping 10 times higher than last year’s average.

If, in order to meet this winter’s energy demands, providers had to use almost all of their coal capacity that is actually scheduled to be retired next year, what is going to happen if we have a particularly hot summer this year? Or another round of Polar Vortexes this upcoming winter, when those plants we relied on are no longer operating?

Mike Duncan of the American Coalition for Clean Coal Electricity echoed Murkowski’s concerns when he spoke with Fox News two weeks ago: “Regulation from five years ago is closing about 20 percent of the coal plants. Regulations being proposed now could close an additional 20 percent of coal plants. And that creates huge stresses — we’re just not ready for anything like that in this country.”

The EPA, of course, insists that reliability is not an issue and that coal will remain viable. But anti-coal groups know better. As a recent FOIA request revealed, the Sierra Club’s John Coequyt (head of the group’s Beyond Coal Campaign) forwarded a news story in an email to the EPA’s own Michael Goo and Alex Barron. The news story carried the headline “Coal to Remain Viable, says EPA’s McCarthy at COAL-GEN Keynote.”

Coequyt wrote just three words above the news story to his EPA friends: “Pants on fire.”

Losing coal would not be as much of a problem if we had a cost-effective, large-scale energy alternative available. But the environmentalist left will not touch nuclear power (an energy source that produces no carbon emissions), and renewables are unreliable and expensive, hardly suited to replace coal. If any coal survives the EPA’s onslaught, electricity will be markedly more expensive, hurting American consumers, especially the poor.

President Obama bragged of his plans to drive out coal in 2008: “If somebody wants to build a coal-fired power plant, they can. It’s just that it will bankrupt them. Under my plan, electricity rates would necessarily skyrocket.”

Those who cheered this plan either failed to realize, or did not care, that it was average, ordinary Americans who would have to, quite literally, pay the price.

EPA Testing Seems At Odds With Public Statements

“Call us for more information and to see if you qualify!”

What exciting opportunity might this be? How about the chance to be exposed to toxins that the researchers say can cause death.

Indeed, this cheery offer came from a set of flyers printed by the EPA seeking human testing subjects for air pollution experiments.

According to an EPA Inspector General report, during five studies conducted in 2010 and 2011, the EPA conducted experiments on 81 individuals, exposing them to airborne particles known as PM2.5 (basically, soot and dust), diesel exhaust, and ozone. Some test subjects experienced cardiac arrhythmias during the testing, and one woman, with a history of medical problems, was sent to the hospital.

The report describes the five air quality studies, expressing concern that the agency exposed a research subject above the study’s concentration targets and that the EPA’s consent forms did not address all of the risks (including death) surrounding pollutant exposure.

Moreover, only one of the studies’ consent forms “identified the upper range of pollutant exposure for each study subject.” The other four consent forms “did not mention the level of pollutant exposure. Instead, the forms…compared the subject’s level of exposure during the study to the exposure they would receive visiting major cities on smoggy days.”

Why was this info left out? The EPA justified its “smoggy days” description of the study because a study manager “explained that a person breathing 420 [micrograms per cubic meter] for 2 hours would inhale the same concentration as they would breathing 35 [micrograms per cubic meter] (the EPA’s 24-hour standard for PM2.5) for 24 hours in a city such as Los Angeles.”

(The studies actually exposed participants to PM levels of 600 micrograms per cubic meter, and one subject up to 751 micrograms per cubic meter — over 21 times the 24-hour standard!)

“The manager also stated that…the risk is small for those with no overt disease.”

Similarly, the agency failed to mention long-term cancer risks from diesel exhaust because “[a]n EPA manager considered these long-term risks minimal for short-term study exposures.”

And just two of the studies “alerted study subjects to the risk of death for older individuals with cardiovascular disease.”

The IG report provides a table detailing health impacts derived from EPA regulations and assessments from short-term exposure to particulate matter and diesel exhaust. For PM2.5, “mortality” is listed as a risk of short-term exposure.chart

What else has the EPA told us about PM2.5?

  • “If we could reduce particulate matter to levels that are healthy, we would have an identical impact to finding a cure for cancer.” — EPA Administrator Lisa Jackson, testimony in front of the Subcommittee on Oversight and Investigations, House Committee on Energy and Commerce, September 22, 2011.
  • “Particulate matter causes premature deaths. It doesn’t make you sick. It is directly causal to dying sooner than you should.” — EPA Administrator Lisa Jackson, testimony in front of the Subcommittee on Oversight and Investigations, House Committee on Energy and Commerce, September 22, 2011.
  • “Overall, there is strong epidemiological evidence linking… short-term (hours, days) exposures to PM2.5 with cardiovascular and respiratory mortality and morbidity.” — EPA report on Air Quality Criteria for Particulate Matter, Volume II, October 2004.
  • “Short-term exposures to particles (hours or days) can aggravate lung disease, causing asthma attacks and acute bronchitis, and may also increase susceptibility to respiratory infections. In people with heart disease, short-term exposures have been linked to heart attacks and arrhythmias.” — EPA brochure on Particle Pollution and Your Health.
  • “The new studies support previous conclusions that short-term exposure to fine PM is associated with both mortality and morbidity.” — EPA report on Provisional Assessment of Recent Studies on Health Effects of Particulate Matter Exposure, July 2006.
  • “The best scientific evidence, confirmed by independent, Congressionally-mandated expert panels, is that there is no threshold level of fine particle pollution below which health risk reductions are not achieved by reduced exposure.” — Letter from Gina McCarthy, Asst. Administrator of the EPA, to Rep. Fred Upton, February 3, 2012.

In these reports and statements, exposure to PM 2.5 is dangerous (indeed, there is apparently no level of pollution at which health risks cease!). But the EPA’s human testing? Apparently not so dangerous.

The IG report summed up the agency’s missing warnings about the link between PM exposure and health effects this way: “This lack of warning about PM…is also different from its public message about PM.”

When an agency hails the reduction of particulate matter as the public health equivalent of curing cancer — and regulates on that basis — it loses credibility when it exposes humans to high levels of the pollutants and deems such exposure safe.

So, has the EPA exaggerated the effects of these particles in order to justify heavy-handed regulation? Or is the agency knowingly conducting dangerous experiments on human subjects?

Whichever it is, neither answer is comforting.

EPA Raises a Stink over Sulfer Restrictions for the Oil Industry

The Wall Street Journal (WSJ) reports that the Environmental Protection Agency (EPA) has recently issued rules to cut the sulfur content of gasoline by 67% and to significantly reduce tailpipe emissions in cars and pickups, starting with the 2017 models. These new rules are known as “Tier 3 standards.” They are designed to reduce the smog created from tailpipe emissions and the subsequent incidence of various lung diseases.

Not surprisingly, both the WSJ and the New York Times (NYT) reports that federal adoption of these stricter Tier 3 standards found broad based support among many environmental and health groups. The Natural Resources Defense Council said the Tier 3 standards could save America $19 billion a year in health-related costs by 2030. The American Lung Association said that Tier 3 standards will reduce pollution equivalent to taking 33 million cars off the road.

Sue and Settle: The Performance Enhancement Drug (PED) of Public Regulators

When Bruce Yandle wrote his classic article in Reason Magazine entitled, “Bootleggers and Baptists: The Education of a Regulatory Economist,” he artfully explained how profit seeking law breakers sidled up with religious do-gooders to accomplish a common social objective: keeping liquor sales illegal. More and more examples of such unexpected bedfellows are appearing in Washington each year. To understand why, just think like a federal bureaucrat.