EPA carbon rule: cost and benefit

by PretiFlaherty
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Monday, the U.S. Environmental Protection Agency proposed a rule aimed at reducing carbon dioxide emissions from power plants.  Part of the EPA's "Clean Power Plan", the rule would rely on states developing and implementing their own plans to reduce the amount of carbon emitted by the electric power sector per unit of electricity generated.  EPA projects that if fully implemented, meeting this goal would reduce the power sector's carbon emissions to 30% below 2005 levels by 2030.  But what will this cost -- and what will the benefits be?

Steam rises from the Con Edison power plant at 14th Street and Avenue C, in New York City.  The plant can burn fuels including oil and natural gas.

Power plants represent the largest source of carbon dioxide emissions in the U.S., accounting for about one-third of the nation's greenhouse gas emissions.  Building on President Obama's 2013 Climate Action Plan and the May 2014 release of the third National Climate Assessment, the Clean Power Plan is premised upon the finding that greenhouse gas pollution "threatens the American public by leading to potentially rapid, damaging and long-lasting changes in our climate that can have a range of severe negative effects on human health and the environment."  The proposed rule targets carbon dioxide because is the most prevalent greenhouse gas, accounting for 82% of U.S. greenhouse gas emissions.

The Clean Power Plan requires states to develop plans to reduce the carbon intensity, or amount of carbon emitted per unit of useful energy, of their power plants.  Each state is allowed to select the measures it wishes to use to reach its carbon intensity goal.  This allows states flexibility to craft policies to reduce carbon pollution that:

1) continue to rely on a diverse set of energy resources, 2) ensure electric system reliability, 3) provide affordable electricity, 4) recognize investments that states and power companies are already making, and 5) can be tailored to meet the specific energy, environmental and economic needs and goals of each state .

The economic impacts of the Clean Power Plan will form a key theme in the debate over its implementation.  The flexibility afforded states makes projections of costs and benefits hard to quantify, even before consideration of the global social cost of carbon or economic concepts like the appropriate discount rate to apply to future costs and benefits.  With those caveats stated, EPA has analyzed two illustrative cases: a collaborative, regional compliance approach (perhaps along the lines of the Regional Greenhouse Gas Initiative) and a state-by-state approach.

Under EPA's analysis as stated in its proposed rule documents, the Clean Power Plan will produce economic benefits far in excess of its costs.  In 2020, EPA projects the regional compliance approach would have total costs of $5 billion, climate benefits of approximately $17 billion, and health co-benefits associated with reduced particulate matter and other emissions -- mostly in the form of reduced premature fatalities -- of between $16 billion and $37 billion.  In this scenario, the Clean Power Plan would yield net economic benefits of between $28 billion and $47 billion by 2020.  EPA's analysis of a state-by-state approach yields similar costs and benefits: a cost of $7.5 billion by 2020, climate benefits of approximately $18 billion, and health co-benefits of between $17 billion and $40 billion.  Under either case, net benefits continue to grow through 2030, reaching between $48 billion and $84 billion.

EPA also projects "job gains and losses relative to base case for the electric generation, coal and natural gas production, and demand side energy efficiency sectors."  In 2020, EPA projects job growth of 25,900 to 28,000 job-years in the power production and fuel extraction sectors, and an increase of 78,000 jobs in the demand-side energy efficiency sector.

What the ultimate costs and benefits of the Clean Power Plan will be remains uncertain, as does EPA's adoption of a final rule implementing the plan.  In the meantime, electric generators, consumers, and policymakers are taking close looks at the plan to ascertain its impacts.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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