The Trump administration proposed last month to change the way it calculates the costs and benefits of environmental regulations. The move is yet another to add to a long list of efforts by the Trump administration to roll back environmental regulations. Many of these efforts are now being fought in the courts—and not just by environmental and health advocates. Economists, energy modelers, electric grid engineers, and even former FERC commissioners are pushing back—and for good reason.
As one example, the Trump administration replaced the flagship Obama-era environmental rule the Clean Power Plan last summer with the Affordable Clean Energy (ACE) Rule. While the Clean Power Plan set ambitious targets to reduce carbon emissions from existing coal-fired power plants, the ACE Rule could potentially increase emissions by eliminating those targets and making it cheaper to produce power from coal plants. In doing so, the U.S. Environmental Protection Agency’s (EPA) own estimates show thousands more could die prematurely every year, along with a jump in the number of people suffering from respiratory disease. Experts across the spectrum agree that the rule doesn’t pass the test on the basis of critical science, industry experience, or technological feasibility.
On the science, the Rule vastly underestimates the cost per ton of carbon, or the “social cost of carbon,” which provides a gauge to justify stronger limits on carbon. While the Clean Power Plan put the social cost of carbon at around $45 per ton, the Trump Administration placed it between $1 and $6 per ton. The EPA erroneously arrives at this absurdly low value for carbon through two main changes to the way it calculated the social cost of carbon, and my colleagues and I at the University of Chicago Law School have challenged ACE based on these arguments.
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