By Institute for Energy Research ——Bio and Archives--March 27, 2013
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“Gina McCarthy, head of EPA’s air office, supported the agency's long-held precedent on the ‘fuel-switching’ question. ‘We haven’t done it in the past, and there's been good reason why we haven’t done it in the past,’ she said at an event hosted by the Johns Hopkins School of Advanced International Studies. ‘BACT is generally applied to the design of the facility, and that is where we are right now,' she said.”Despite McCarthy’s assurances, when the New Source Performance Standards for Greenhouse Gas Emissions from New Electric Utility Generating Units were released by EPA, it set a standard that coal generation cannot meet with commercial technology and thereby requires fuel switching. Does McCarthy still claim EPA’s regulations will not require fuel-switching? If so, how does she square her past statements and the proposed rule for new electric utility generating units? 5. Does Gina McCarthy support efforts to regulate carbon dioxide emissions from existing power plants? After EPA has finalized its regulation of new sources of greenhouse gas emissions (ie. the ban on new coal-fired power plants), many believe that EPA would like to regulate carbon dioxide emissions from existing power plants. Ostensibly, EPA would undertake this action because of global climate change mitigation efforts. However, unilateral action by the United States would have very little to no climate impact according to the models of the Intergovernmental Panel on Climate Change (IPCC). Based on assumptions in the IPCC’s Assessment Reports, if the U.S. as a whole stopped emitting all carbon dioxide emissions today, the impact on projected global temperature rise would be a reduction, or of approximately 0.08°C by the year 2050 and 0.17°C by the year 2100—amounts that are, for all intents and purposes, negligible. Why should EPA impose billions of dollars in costs, ostensibly to impact global climate change, when the IPCC’s science says that unilateral action by the United States have at most a negligible impact on global climate? 6. Will Gina McCarthy lead EPA to assault natural gas power plants the same way it has targeted coal-fired power plants? The EPA’s New Source Performance Standards for Greenhouse Gas Emissions for New Electric Utility Generating Units are not based on having any meaningful impact on climate. In fact, in the proposed rule, EPA stated “we do not anticipate any notable CO2 emission changes resulting from the rule.”[6] In other words, EPA admits that these greenhouse gas emission standards for new sources will not impact global warming and global climate in any way. Because EPA’s greenhouse gas emission standards are not based on any climatic improvements, or changes, after EPA regulates coal power plants out of existence, when will EPA also regulate natural gas power plants out of existence? After all, the logic of EPA’s proposed new source performance standard assumes that any greenhouse gas emissions cut is beneficial regardless of climate impact. Therefore, according to EPA’s logic, it should ban natural gas power plants as well. 7. Why was Gina McCarthy’s estimate of the impact of the MATS rule on power plant closures so wrong? McCarthy’s office was, at best, incompetent in their modeling of the impacts of the Mercury and Air Toxics Standards (MATS). Testifying before Congress, McCarthy claimed that the MATS rule would lead to only a “modest amount of generating capacity” (4,700 MW)[7] closing. This was a gross understatement. According to research by the Institute for Energy Research, the MATS rule will result in at least 35,000 MW closing[8] and Barclay’s estimates that 42,000 MW will close because of MATS.[9] McCarthy’s testimony was off between 650 percent and 800 percent. Why were EPA’s estimates for the impact on the electricity generating sector so wrong? Given EPA’s poor track record, why should anyone believe EPA’s claims on the amount of generation that will close as a result of EPA’s regulations? 8. How does Gina McCarthy justify the economic cost for EPA’s mercury reduction efforts when these regulations have minimal environmental impact? Truly, the impacts of the MATS rule are immense. The costs of the MATS rule are astronomical and the benefits of the mercury reductions are tiny. According to EPA, MATS would cost $10 billion and only result in $500,000 in benefits from mercury reductions.[10] Why should Americans pay $2,000,000 for every $1 dollar of mercury reduction benefits from the Mercury and Air Toxics Standards?' 9. What is Gina McCarthy’s commitment to transparency and accountability at the EPA in light of the agency’s refusal to release information about how regulations are crafted and marketed to the public? EPA refuses to release the databases upon which the benefits of the MATS rule, and 60 – 81 percent of the estimated benefits of all federal actions, are based.[11] The overwhelming benefits in EPA’s economic analysis of the Mercury and Air Toxics Standards rule come from reductions in particulate matter, not from reductions of mercury or air toxics. McCarthy and other administration official have repeatedly failed to respond to Congressional requests to make the underlying databases (the “Cancer Prevention Study” and the “Harvard Six Cities Study”) publically available. These datasets were funded by the public and yet EPA does not allow public access to the data. One of the tenets of science is replication of data, but this is impossible without EPA allowing the public access. President Obama has been very forceful on improving transparency and openness in government. In a memo to on transparency and open government, he stated, “We will work together to ensure the public trust and establish a system of transparency, public participation, and collaboration.”[12] Why has EPA violated President Obama’s pledge on transparency and open government? Why should the public trust EPA on science when EPA refuses to release the basis for most of the benefits EPA claims its regulations produce? Will Gina McCarthy adhere strictly to federal FOIA laws and other statutes that protect taxpayers? Does she intend to use a personal gmail account or an alias to conduct official EPA business? Has she in the past? 10. Does Gina McCarthy believe EPA’s economic analyses have any real value even though the analyses omit the impact of the costs of regulatory compliance? EPA’s use of economic models defies common sense. NERA economic consultants recently examined 48 air quality rulemakings from 1995 through 2010 and examined EPA’s estimates of employment impacts of these rules.[13] NERA found that EPA claimed job creation benefits from complying with the rules, but contrary to common sense, EPA ignored the effects of regulatory compliance costs. NERA compared their economy-wide modeling to EPA’s modeling and found:
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