Unnatural Instincts: The Trump Effort to Rollback Critical Climate Regulations Is Bad Science and Bad Business
The scale of these rollbacks — measured in GHG emissions, in economic costs to be paid and benefits to be lost, and in human lives — is breathtaking. These rollbacks not only reveal a bad “instinct” for science, they also show a bad sense for business
by Ryan Martel, director of federal policy at Ceres.
In a recent Associated Press interview, President Trump claimed to be “an environmentalist” and offered that he has “a natural instinct for science.”
The goals of his administration suggest otherwise.
In fact, this week we are in the middle of the public comment period on the Trump-directed rollback of four climate-related rules administered by the Environmental Protection Agency (EPA) — rules which make up the centerpiece of U.S. efforts to reduce greenhouse gas emissions (GHGs) and fight climate change.
The Trump Administration has been building up to this regulatory purge from the moment the President was elected, so it is no surprise that he is attempting to fulfill campaign promises on these issues. Still, it is remarkable that these major rules are all under consideration at the same time. It reflects the breadth and depth of this administration’s efforts to effectively erase the previous eight years of progress on addressing climate change — progress that was still only a stepping stone towards meeting the U.S. goals under the Paris Agreement.
The scale of these rollbacks — measured in GHG emissions, in economic costs to be paid and benefits to be lost, and in human lives — is breathtaking. These rollbacks not only reveal a bad “instinct” for science, they also show a bad sense for business.
All four rollbacks represent a seismic shift in regulations across huge sectors of the economy: oil and gas, electric power, transportation, and industry. In all cases these rollbacks will weaken our ability to transition to a low-carbon economy. They could split the U.S. auto market, put the nation out of step (and make us less competitive) with global markets, improperly subsidize old, non-competitive technologies, and put the U.S. in opposition to binding global treaties.
They also all-but-guarantee massive and lengthy lawsuits and other legal pushback — much of which is uncertain to come out in the EPA’s favor. These ongoing contests will lead to increased regulatory uncertainty and economic inefficiencies across major sectors of the economy, increasing prices for consumers and companies alike and making the U.S. a less attractive destination for global financial flows. And, as shown in a recent signal from French President Emmanuel Macron, they will weaken our ability to reach beneficial international trade agreements.
Here’s a brief overview of the four proposed rollbacks and their predicted negative environmental and public health impacts by subject area:
Finalized in 2012, the national vehicle standards for fuel economy and emissions were intended to be implemented over two phases: the first phase ran from 2012 through 2016 and the second phase will run from 2017 through 2026, following a midterm review. In the proposed “Safer Affordable Fuel Efficient (SAFE) Vehicles Proposed Rule for Model Years 2021-2026,” the EPA and Department of Transportation (DOT) would freeze the standards at 2020 levels and also revoke California’s ability to set its own standards, which are followed by more than a dozen states and represent more than a third of the U.S. market for cars and trucks. The proposal would lead to increased GHG emissions in the range of 321-931 million metric tons (MMt) (depending on oil prices) by 2035 — more than the total annual emissions today of 82 percent of countries. The proposed rollback would have significant economic consequences for the auto industry, undermining its global competitiveness and potentially costing auto suppliers (the largest U.S.manufacturing sector) $20 billion between 2021 and 2025 — in addition to increasing fuel costs for businesses and consumers, and undermining the broader economy as well.
The existing Clean Power Plan was designed to reduce GHG emissions from power plants. Trump’s proposed replacement, called the “Affordable Clean Energy (ACE)” plan, could actually result in higher emissions than under no rule at all. Rather than letting states choose the most efficient method of emissions reductions, the ACE rule would require only small efficiency upgrades to existing coal plants. This weakening of the Clean Power Plan and its replacement with the ACE plan is expected to increase emissions between 20 million tons carbon dioxide and 37 million tons carbon dioxide per year by 2025, and could result in 1,400 premature deaths a year as a result of air pollution by 2030.
The 2016 New Source Performance Standards were designed to help curb emissions of methane and other volatile organic compounds from the oil and gas industry, which emits about 13 million metric tons of methane (equivalent to 325 million tons of carbon dioxide) annually as a result of leaks that happen during the production, processing and transportation of oil and gas. Methane is about 30 times more potent than carbon dioxide, and emissions from leaks are equivalent to putting nearly 70 million cars on the road each year. Now, the EPA is proposing changes that would significantly reduce the frequency of required monitoring of leaks, extend the amount of time companies have to fully repair leaks from 30 days to 60 days, and create additional exemptions to the rule for certain oil and gas producers. The rollback is expected to result in the cumulative emission of 380,000 tons of methane (equivalent to 9.5 million tons of carbon dioxide) and 100,000 tons of other volatile organic compounds between 2019 and 2025.
HFC Leak Repair and Maintenance
In 2016, the EPA extended regulations that prohibit the intentional venting of refrigerant and air conditioning chemicals to include substitute refrigerants such as hydrofluorocarbons (HFCs), an extremely potent GHG. Under the Trump Administration, the EPA has proposed revisions to this rule that would rescind the extension of the rule to HFCs and other substitute refrigerants — a move that would lead to an expected 3.6 million metric tons of carbon dioxide equivalent per year.
Bad for Business
Underpinning the justifications for many of these rollbacks are new ways of calculating costs and benefits of regulations that seek to minimize benefits and make the regulations seem more costly. However, these rollbacks will be a disaster for public health and the environment, and will ultimately be a drag on the U.S. economy. A new study finds that the U.S. economy has more to lose from the effects of climate change than all other countries in the world except India, while another report shows that the Trump administration’s reckless deregulatory rollbacks would deprive workers, consumers and the economy of more than $2.1 trillion in benefits over the next two decades. The potential losses from the 13 rules examined in the report would amount to nearly $17,000 per household, far exceeding any savings for businesses.
Wrong Proposals at Exactly the Wrong Time
Rollbacks like those proposed will return us to the approach that has put us in this moment of crisis in the first place, and will worsen the already significant negative impacts from climate change for generations to come.
As the recent report from the Intergovernmental Panel on Climate Change (IPCC) made clear, we are at a critical juncture when it comes to reducing GHG emissions and combating the worst effects of climate change, with about 12 years left to reduce emissions so as to achieve a no-more than 1.5 degrees Celsius increase in average global temperature. As Ceres’ President and CEO Mindy Lubber puts it, this is our “all hands on deck moment” to secure a better future for our children and grandchildren. Yet President Trump seems determined to pursue 19th Century solutions and a 19th Century economy for this 21st Century problem.
Fortunately, the public can make its voice heard during the current comment period. We can also take heart from initiatives such as Ceres' Commit to Climate, which builds private sector leadership to address climate change, bringing investors and companies together to support clean energy and transportation policies in order to achieve the goals of the Paris Agreement and get us to a just and sustainable future.