Multi-Pollutant Madness

Today the Senate Environment and Public Works Committee will hold its fourth hearing on the “Clean Power Act” (S.556) proposed by Sen. James Jeffords, Vermont Independent. This bill, and its House companion, Henry Waxman’s “Clean Smokestacks Act” (H.R. 1256), would establish new controls on power plant emissions of sulfur dioxide (SO2), nitrogen oxides (NOX), mercury and carbon dioxide (CO2).<?xml:namespace prefix = o ns = “urn:schemas-microsoft-com:office:office” />


CO2 is the inescapable byproduct of the carbon-based fuels that supply 70 percent of U.S. electricity and 84 percent of all U.S. energy. CO2 is also the principal “greenhouse” gas targeted by the Kyoto Protocol, the non-ratified U.N. global warming treaty. The Jeffords-Waxman bills aim to make the Kyoto agenda of climate alarmism and carbon suppression the central organizing principle of U.S. energy policy.


The Jeffords-Waxman bills, touted by proponents as “integrated” air quality management, rest on a popular fallacy – that the best or only way to clean the air is to curb energy production from fossil fuels. History refutes this gloomy dogma. From 1970 through 2000, total emissions of the six principle (“criteria”) pollutants EPA regulates under the Clean Air Act decreased 29 percent, while vehicle miles traveled increased 143 percent, total energy consumption increased 45 percent, and coal consumption increased 106 percent. How is this possible?


As air-quality analyst Joel Schwartz explains, technological advances are slowly but surely “decoupling” air pollution from energy production. A new car manufactured in 1997 or later emits 98 percent fewer volatile organic compounds and 89 percent less NOX per mile than a new car manufactured in 1975. New natural gas plants in California emit 90 percent less NOX per kilowatt-hour than the average California plant. Automobile and equipment turnover will continue to reduce emissions for years to come, with no big changes in regulatory law.


For three decades, the Clean Air Act has targeted limited resources at specific pollution problems. The Waxman-Jeffords bills would abandon that common-sense approach and attempt to reduce pollution indirectly, by suppressing energy use. A more wasteful procedure is hard to imagine.


In a December 2000 study, the Energy Information Administration (EIA) estimated the individual, aggregate, and “integrated” costs of reducing emissions of NOX, SO2, and CO2. Reducing NOX and SO2 to 75 percent below 1997 levels by 2005 would cost $3 billion each. Reducing CO2 to 7 percent below 1990 levels would cost $77 billion. Implementing those targets one at a time would cost $82 billion. Implementing the targets in an “integrated” fashion would cost $77 billion. Five billion dollars would be “saved” due to the fact that CO2 reductions entail ancillary NOX and SO2 reductions, and vice versa.


But, if the goal is cleaner air, then the “multipollutant” approach doesn’t save any money at all. Rather, it spends $77 billion for $6 billion worth of NOX and SO2 reductions – it wastes $71 billion.


In an October 2001 analysis, EIA estimated that the Jeffords-Waxman multi-emission caps would increase consumer electricity prices 33 percent, increase power producers’ cumulative production costs $177 billion, and cut electric power generation from coal (America’s most abundant fuel source) 55 percent. Those impacts are a steep price to pay for pollution reductions that may not even be necessary for protection of public health, or that could be achieved far less onerously the old-fashioned way.


But it is not the direct costs of the Jeffords-Waxman bills that are most worrisome. Because CO2 is neither an “ambient” nor a “hazardous” air pollutant, there are no air quality or health-based standards for regulating CO2. Even with respect to climate change, no one knows how much CO2 in the atmosphere is too much, too little, or just right. Consequently, agencies regulating CO2 would not be constrained by any objective health or welfare criteria. And, as is well known, the avowed goal of many Kyoto supporters is to eliminate the use of fossil fuels.


Not only are there no limits in principle to the regulatory burdens government could place on individual entities under a CO2 control regime, there are almost no practical limits to the number of entities government could regulate. A recent report by the Pew Center on Global Climate Change estimates that, in the United States, more than 186,000 firms emit upwards of 1,000 metric tons of CO2 per year. An earlier study by energy analyst Mark Mills estimated that nearly 1 million U.S. establishments emit more than 100 tons of CO2 per year. The EPA does not currently regulate CO2, and has no authority to do so. The Jeffords-Waxman bills would smash that barrier, rendering as many as 1 million firms vulnerable to new EPA regulation, monitoring and enforcement.


Kyoto supporters often say that we do not have to choose between a healthy economy and a healthy environment. They are right, but for the wrong reasons. Carbon-based fuels are increasingly abundant, affordable, safe and clean. Only wealthy societies can afford to invest in high levels of environmental protection, and only free societies can invent the breakthrough technologies of tomorrow. The Kyoto agenda is a prescription for poverty and regulatory excess. Policymakers are well advised to shun it and every initiative that would advance it.