Comments on the EPA proposed Carbon Pollution Standards for New Power Plants by Bonner R. Cohen, Ph. D. on behalf of the Committee for a Constructive Tomorrow, on February 6, 2014.
There are two reasons why the EPA’s war against coal is ill-advised. One is scientific; the other is regulatory.
The EPA’s primary target is carbon dioxide (CO2) emitted from new coal-fired power plants. Current concentrations of CO2 in the atmosphere are 400 parts per million (ppm). Human activities in all their forms account for 4 percent of that total. The U.S. is responsible for 3 percent of that 4 percent total. All the rest of the CO2 in the atmosphere (96 percent of the total) comes from purely natural causes, such as volcanoes, undersea venting, animal fluctuation, etc.
The total U.S. contribution to atmospheric CO2 is one-tenth of one percent, or 0.01 percent. This 0.01 percent includes the CO2 that is emitted every time one of the approximately 315 million Americans opens his or her mouth to speak, cry, or engage in any other verbal activity.
The contribution of coal-fired power plants to the U.S., much less global CO2 emissions, is so miniscule that it cannot be measured with any degree of accuracy. And the contribution of those entities targeted by the EPA to the Earth’s climate also cannot be measured.
The EPA has absolutely no way of saying how its proposed regulations will affect the climate. Furthermore, in justifying its regulatory action, the EPA accepts the theory of anthropogenic (human-induced) global warming driven by the burning of fossil fuels. That theory, however, provides NO explanation for the extended periods of warming and cooling that predated the widespread use of fossil fuels to produce energy. Nor can it explain the confirmed lack of any warming over the past 15 years, a time when fossil-fuel use throughout the world has increased.
In keeping with political fashion, the EPA constantly refers to “climate change,” as opposed to “global warming,” which is nothing more than a tacit admission that global warming, so confidently predicted by the UN climate models on which the EPA relies, has failed. Indeed, even the UN’s Intergovernmental Panel on Climate Change (IPCC), in its latest report, had to acknowledge that global temperatures have shown no warming since 1998.
Science is based on observation and not on “consensus,” much less on mathematical models that can be, and are, easily constructed to produce the desired result. And the climatological observations provide NO justification for what the EPA is proposing to do, nor does it make an regulatory sense. .
China has already surpassed the U.S. as the world’s largest emitter of greenhouse gases, and India will shortly do so. The governments of those two countries have said repeatedly over the past 20 years that they will not be a part of any scheme aimed at reducing their emissions of greenhouse gases. They have no intention of denying their citizens and businesses the affordable energy that fossil fuels provide.
For the EPA to impose carbon-pollution standards that by design will make the introduction of new coal-fired power plants all but impossible is to adopt a policy that by design will drive up the cost of electricity by limiting America’s sources of power. This will be done under the justification that it will have a positive effect on the climate (whatever that is). In doing so, the EPA is engaging in a complete fabrication, one that will put an end to an industry that supplies the U.S. with 37 percent of its electricity. This, of course, is exactly what the proposed regulations are meant to do. It is nothing less than industrial sabotage by regulatory means.
To sum up Dr. Cohen’s testimony in a nut-shell: If promulgated, these regulations will raise the price of electricity, potentially cause brownouts, and destroy jobs while having no meaningful impact on world temperatures.
Between 2006 and 2012, more than 214 million work hours were performed at utilities across the U.S., the vast majority at coal fired plants. These 214 million work hours translate into over 120,000 jobs. If the EPA’s Carbon regulations are implemented, as written, almost all of these jobs will disappear because coal fired plants will be regulated out-of-business.
The EPA’s regulations on Mercury Air Toxic Standards (MATSL) has already been cited as a factor in the announced closing of 205 coal units, representing 31,000 megawatts of coal fueled generating capacity in twenty-six states with estimated job losses of between 13,000 to 17,000 jobs.
While the government is boasting an unemployment rate of only 6.6% to point to recovery and “their” job creation, the truth is the real unemployment rate is 11.5%. Unemployment for ages 16-19 is now 20.7% while unemployment for blacks is 11.9%. So why do we allow the Obama administrative to continue to destroy our jobs?
No agency possesses the power to make law yet this is exactly what the EPA has done by placing itself above Congress on all matters relating to energy production and consumption. The only option we possess to stop this rogue agency is to cut the purse string. We must demand that Congress defund the EPA.