“Multi-Pollutant” Regulation Of Carbon Dioxide: Shrewd Politics, Bad Policy

Full Document Available in PDF

Although President Bush nixed any chance of the United States ratifying the Kyoto Protocol during his term of office, the Kyoto agenda of climate alarmism and energy rationing continues to shape public debate and action at all levels of government.

Senator James Jeffords’ (I-VT) “Clean Power Act” (S.556) and Representative Henry Waxman’s (D-CA) “Clean Smokestack Act” (H.R. 1256) are the Kyoto agenda’s cutting edge in the 107th Congress. These bills would require substantial reductions in power plant emissions of nitrogen oxides (NOX), sulfur dioxide (SO2), mercury, and carbon dioxide (CO2), the principal “greenhouse” gas targeted by the Kyoto Protocol.

This paper examines some of the scientific, economic, and political issues raised by “Multi-Pollutant” legislation, also described by proponents as “comprehensive, integrated air quality management.” Several key conclusions emerge:

The Jeffords-Waxman bills are based on a false premise – that we must reduce fossil energy use to reduce air pollution.

· During the 30-year period from 1970 through 2000, total emissions of the six principal (“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. Automobile and equipment turnover will continue to produce substantial air quality improvement under current regulatory law in the foreseeable future.

“Integrated” air quality management is false advertising.

· CO2 is neither an “ambient” air pollutant like NOX and SO2, nor a “hazardous” air pollutant like mercury. It does not foul the air, impair visibility, contribute to respiratory disease, or bio-accumulate as a toxin in fish. Putting CO2 in the same regulatory pot with noxious substances makes for an arbitrary hodge-podge, not an “integrated” strategy. However, mixing up climate policy with pollution control is shrewd politics. Any stand-alone CO2 bill would be instantly tagged as a Son-of-Kyoto ploy and shunned by most members of Congress.

As air quality management, “4-Pollutant” bills are horrendously wasteful.

· It costs billions more to reduce air pollution as a “co-benefit” of CO2 reductions than to control air pollution directly. An Energy Information Administration (EIA) study makes this clear. Reducing NOX and SO2 emissions 75 percent below 1997 levels by 2005 would cost $6 billion. Reducing CO2 emissions 7 percent below 1990 levels by 2005 would cost $77 billion. If the three requirements are “integrated,” the total cost is $77 billion – $5 billion less than the sum of their separate costs. That $5 billion “savings” is due to the “co-benefits” of “integration” – the fact that CO2 reductions entail ancillary NOX and SO2 reductions, and vice versa. But, if your goal is cleaner air, then you haven’t saved any money at all. Rather, you have spent $77 billion to achieve $6 billion worth of SO2 and NOX reductions. In other words, you have wasted $71 billion.

As climate change policy, “4-Pollutant” bills are totally useless.

· According to the world’s most advanced climate model, full implementation of the Kyoto Protocol would avoid only 14/100ths of a degree C of global warming by 2100 – probably too small an amount for scientists to detect. Since the United States produces 25 percent of the world’s greenhouse gases, U.S. compliance with Kyoto would offset global warming by a hypothetical 35/1000ths of a degree C. The Jeffords-Waxman caps would cut annual CO2 emissions by 217 million metric tons in 2010 – roughly 39 percent of the America’s annual Kyoto reduction target. Hence, those caps would avert 13/1000ths of a degree C of warming by 2100. This infinitesimal change would not benefit people or the planet one whit.

The Jeffords-Waxman bills would limit U.S. fuel options, squander billions of dollars, and harm consumers.

· The EIA analyzed the impacts of both Jeffords’ “4-P” caps and Senator Bob Smith’s (R-NH) “3-P” caps requiring power plants to reduce SO2, NOX, and mercury emissions from 50- to 75-percent. Whereas Jeffords’ caps would increase consumer electricity prices 33 percent in 2020, Smith’s would raise prices between 1 and 6 percent. Whereas Jeffords’ caps would increase power companies’ cumulative production costs $177 billion by 2020, Smith’s would increase such costs between $28 and $89 billion. Whereas Jeffords’ caps’ would reduce coal-fired generation 55 percent by 2020, Smith’s caps would reduce coal generation between 4 and 10 percent. When Jeffords’ caps are fully implemented in 2007, GDP declines nearly $100 billion.