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Reserving the Right to Object
December 4, 2015 - Provided by The Pennsylvania Manufacturers' Association
Pennsylvania is charging ahead with regulations to implement the Obama Administration's master plan to cool down a planet we are told is on the verge of boiling over.

Twenty-seven states, three labor unions and 24 national associations have sued in federal court to block implementation of the "Clean Power Plan" (CPP). Not Pennsylvania. Nearly all the other states are taking advantage of a two-year grace period to implement the rules. Not Pennsylvania. Our Department of Environmental Protection is shooting to submit a final and legally binding State Implementation Plan to the EPA in September 2016, before a new president could modify or jettison the rule.

The science behind climate change leaves plenty of room for debate - especially in Pennsylvania. The extent of man's role in what the climate change models are predicting is a subject that is rarely examined, but is of utmost importance.

In the Pennsylvania Climate Impacts Assessment Update, published by Penn State University in May 2015 for DEP it stated, "The projections of future change in this report are primarily based on the RCP8.5 scenario." Upon further examination, the RCP8.5 may be the most aggressive model in use today.

  • In a 2014 report, a distinguished Texas A&M scholar, Dr. John Nielsen-Gammon, wrote, "RCP8.5 comes in around the 90th percentile of published business-as-usual (or equivalently, baseline) scenarios, so it is higher than most business-as-usual scenarios."
  • Even authors of the Intergovernmental Panel on Climate Change (IPCC), the group that publishes the models, acknowledges that the RCP8.5 scenario is the highest model a study can use. Dr. Mat Collins wrote in a 2013 report, "The scenario with the most warming is the 'business-as-usual' RCP8.5, in which global mean temperature could be 4°C or more above pre-industrial times. Perhaps these don't sound like big numbers, but the regional changes which go with the global warming could be very much greater. For this highest scenario, it is likely that we will see an Arctic Ocean that is virtually free of sea-ice in summer by the middle of the 21st century."
  • Retired geophysical consultant Andy Skuce recently wrote, "The worst-case emissions pathway, RCP8.5, is a scenario that burns a huge amount of fossil fuels, especially coal. The model has sometimes been criticized as implausible because of its huge resource consumption and emissions of ~1700 billion tonnes of carbon (GtC) over the century. Together, these feedbacks suggest that the greenhouse gas concentrations in the RCP8.5 case could be achieved with ~400 GtC smaller human emissions, making the RCP8.5 worst-case scenario more plausible."

The CPP is based on presumptions, distortions, and fanciful science. The real agenda is a political one: wedging expensive alternative energy sources in and shoving fossil fuels out. At look at the details of the EPA's plan bears this out.

Start with crux of the argument that we are on a steady climb, getting hotter every year. Climate models said that years ago but later couldn't account for a lengthy cooling period that started in 2002. Thus, showing one of the many problems with all models, holistically.

Benjamin Zycher, the American Enterprise Institute's scholar on energy and the environment, faults climate modeling for being too aggressive at best. "No one knows why (we had the cooling period); the science is not settled, nor can it ever be, by definition," Zycher wrote.

While addressing 2014 as the hottest year on record Zycher said, ".such factoids are far less informative than many seem to assume. The recent year-to-year differences are almost never statistically significant."

More importantly, Zycher notes, the "hottest year" rhetoric is based on the surface temperature record, a collection of data that he calls "deeply problematic, with heat-island effects difficult to expunge from the data, poor placement and shifts in the measurement stations, etc." As example, China has 137 monitoring stations in four cities, and as those cities grew, China warmed.

The satellite data tells a different story, which is why the reported surface temperature path is consistently higher than the satellite record. More broadly: The earth has been warming in fits and starts since the end of the little ice age around 1850, and so a warming trend is neither surprising nor informative, Zycher says.

However, the economic harms are real. A recent analysis from NERA Economic Consulting reveals significant negative economic impacts resulting from EPA's carbon emissions regulations, as the costs to comply with the plan could total nearly $300 billion from 2022 to 2033.

"Consumers will ultimately foot the bill for these rising costs, which include double-digit electricity price increases in 40 states, with 28 states potentially facing peak year electricity price increases of at least 20 percent," the analysis finds.

"The Wolf Administration is playing a game of bait-and-switch on climate data," said PMA President David N. Taylor, "pretending that the most aggressive model is the most reasonable one. Combined with the rush to judgement on a state implementation plan, it proves the Wolf Administration cannot be trusted to act rationally on environmental issues and so the General Assembly must hold fast until after we inaugurate a new President."

The benefit side of the cost/benefit argument borders on the absurd: If the Obama Administration's Climate Action Plan- a 17 percent reduction in U.S. greenhouse gas emissions by 2020 - were to be implemented immediately, by 2100 the global temperature would drop 15 one-thousandths of a degree. Such a barely measureable estimate sounds as if it were contrived by climate change skeptics. But it's actually an older EPA estimate. The agency also predicted the plan would lower sea levels by what amounts to the combined widths of two sheets of paper.

The agency has since dropped the hard numbers and graphics from its predictions. The EPA now uses a theoretical "social cost of carbon" to project climate change benefits. NERA notes that under the "social cost of carbon" the EPA often estimates not only the benefits of reducing the specific pollutant targeted by a regulation, but also the benefits of accidental reductions in other emissions that result from the regulation ("co-benefits"). The EPA, for instance, often includes large PM2.5 co-benefits to justify rules that are not intended to reduce PM2.5. For example, between 1997 and 2011, EPA pointed to PM2.5 co-benefits to support 21 of 26 major air rulemakings. They're pulling the same fast one under the CPP.

Similar shenanigans happened before with the EPA's Mercury and Air Toxics Standards (MATS). The industry finally won the war against MATS this past July in the Supreme Court, but not before the casualties had mounted.

The Court sided with industry that the EPA should not have been double-counting health benefits for ancillary reductions of pollutants that aren't the regulation's focus. Unfortunately, the opinion came four years after the rule had been implemented. To comply, the industry was forced to close 400 coal units in 36 states. Two of those were in Pennsylvania, leaving nearly 400 out of work, out of high-paying-jobs work.

The Pennsylvania Coal Alliance predicts the fallout in industry from the CPP will be on a much larger scale than MATS. Spokesperson for the Alliance, Abby Foster, noted that carbon wasn't even considered a pollutant until 2007.

"We haven't have sufficient time for research and development to advance on carbon capture and utilization technologies," Foster said. "Therein lies the main difference between the CPP and MATS rule. The technology to retrofit a plant is not even commercially tested and available. Compliance with the CPP leaves only the option to transition away from, rather than evolve the industry. It's a lack of achievable standards and the EPA is well aware of this."

World leaders gathered in Paris this week for COP 21. Some notable facts never entered the discussions. Never was it mentioned, for instance, that carbon dioxide emissions don't even cause or worsen asthma. What's more, the data show that while the levels of other pollutants have been dropping for decades, asthma rates are still rising. Other factors must be at play.

President Obama put the battle against climate change on at least a par with the fight against global terrorism. It's an old political trick to boost your popularity by whipping the populace into frenzy against a common enemy. He's just putting a new twist on an old gimmick by ignoring the real enemy.

It's not as though this is the Wild West; that there are no current regulations that maintain the necessary pollutant levels. It's in fact quite the opposite. The fact is that the air today is cleaner than it's been in measurable history. According to the EPA's own publications air quality continues to improve as emissions have continuously declined in all major measurable categories since being catalogued in the 1980's. The manufacturing sector takes pride in continuing to advance technological limits to produce goods in a safer, cleaner, and more environmentally friendly manner. But we keep moving the goalposts, leading to excessive compliance costs and higher energy costs thus curbing the growth of our sector and the commonwealth's economy.

Nothing contained here should be considered as an attempt to aid or hinder the passage of any legislation.

The views expressed here are those of the author and not necessarily those of The Susquehanna Valley Center.

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