On Monday, the Trump administration will announce a new regulatory agenda. Coincidentally, next Saturday, October 7th, is a deadline for the EPA to provide details on what it’s doing with the Clean Power Plan (CPP). Allow us to fire up the crystal ball to try and suss out what to expect when you’re expecting new climate change regulations from an administration in denial.
First off, it’s unlikely that Pruitt will simply repeal the CPP without some sort of replacement (even if that’s what the hardcore deniers want). Pruitt is sinister, not stupid. He knows the Endangerment Finding requires a policy to address carbon pollution.
But to justify overturning the CPP, Pruitt will likely trot out the same debunked criticisms deniers have leveled all along. We’re guessing the EPA will point to the debunked NERA report, lower the social cost of carbon by excluding international benefits and use other types of “fuzzy math” to claim that the benefits from the CPP are laughably low or even too uncertain to quantify.
But the administration has to replace the CPP with something or risk losing the inevitable lawsuit. As it turns out, even the fossil fuel and utility industries accept this fact. Industry lobbyists have been pushing for a replacement plan, and appear to be converging on an “inside the fence” approach.
But what might that replacement plan look like? As it turns out, we have some clues. While Pruitt has been hesitant (at best) to engage with mainstream media, he has done plenty of interviews with conservative outlets. (So many that the schedule he finally and begrudgingly released doesn’t include even close to all of the denier-friendly appearances he’s made.)
In one interview with the Washington Examiner from last week, Pruitt suggests that those wondering about what’s to come with the CPP “take a look at the Oklahoma plan” he released in 2014 as an alternative to other state’s thinking on how to meet climate goals. With considerable prescience, the NYTimes posted this plan earlier this year, so if you want all the details, here they are.
With the CPP, the EPA set science-based emission goals for states and let them figure out how best to meet that goal. By contrast, Pruitt’s Oklahoma plan would have each state doing only that which is convenient for the power plants, asking for efficiency upgrades based on their boiler design, coal type, plant age and other factors. So instead of the CPP’s free market-based mechanism which would allow for states to meet emission reduction goals by transitioning to clean, cheap renewables and away from dirty old coal, Pruitt’s plan is actually more in the vein of traditional liberal command and control regulations that create define specific actions that should or should not be taken for each individual polluter.
In practice, this will likely mean Pruitt’s plan would make sure that no dirty old plant has to close, as it requires that anything the state asks of a plant to not impose an onerous cost. If improvements to a plant would make it uneconomical to run, it could get a waiver. In turn, waivers could very well extend the lifetime of particularly dirty old coal plants. This could potentially lead to an overall greater level of carbon pollution than we would get without the plan. That’s because without Pruitt’s proposed plan, and/or with the CPP, utilities would probably retire the old plants and build cheaper new gas or renewables instead of spending the money to upgrade the coal plants and then running them for many more years to recoup that cost.
If our predictions are right, the replacement for the CPP will require states to do only what’s convenient. As NRDC’s John Walke said, this sort of approach would fit “industry talking points to a T.”
Of course, making industry happy fits Pruitt’s modus operandi to a T, making us pretty confident in this reading of the T leaves.
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