Proposed CO2 Standards: Expensive Hot Air

October 25th, 2013 by 2 Comments

By Benita M. Dodd

(This commentary is the basis for testimony by Benita Dodd on behalf of the Georgia Public Policy Foundation at the EPA Listening Session on 111(d) Carbon Pollution Standards for Existing Power Plants in Atlanta on October 23 and was submitted in full to the EPA.)

BENITA DODD Vice President, Georgia Public Policy Foundation
Vice President, Georgia Public Policy Foundation

The Foundation believes that tougher standards on carbon dioxide emissions being proposed by the Environmental Protection Agency and under discussion at the EPA’s 11 listening sessions around the nation will have unfortunate consequences for the United States.

This nation holds the world’s largest estimated recoverable reserves of coal; in fact, the United States is a net exporter of coal. In 2012, 81 percent of the coal produced in the nation was used by U.S. power plants to generate electricity, providing 42 percent of the energy mix.1 The currently recoverable coal reserves represent enough coal to last 194-236 years.

The importance of coal in Georgia’s energy mix is not to be underestimated, either. According to the EIA, of the state’s electricity generation in 2011, coal accounted for 48 percent.2 The mix has changed somewhat now that natural gas factors in.3 Still, coal remains a crucial and reliable domestic source of energy.

Now comes the proposed regulation under the president’s Climate Action Plan. According to the EPA Web site, “Carbon dioxide (CO2) is the primary greenhouse gas pollutant, accounting for nearly three-quarters of global greenhouse gas emissions and 84 percent of U.S. greenhouse gas emissions.”

The EPA is working to redefine a gas that every living being exhales into a pollutant. Carbon dioxide emissions do not equate to carbon dioxide pollution. Further, water vapor is the primary greenhouse gas. And we exhale that, too. Should we regulate water vapor?

The EPA is proposing a standard not yet met by any coal plant. The EPA finds the standards “will result in negligible CO2 emission changes… by 2022.”4 And it “will result in negligible changes in GHG emissions … Even in the absence of this rule, the EPA expects that owners of new units will choose generation technologies that meet these standards due to expected economic conditions in the marketplace.”5

If the EPA believes the marketplace is heading that way, and that the standard will have no impact on emissions, why promulgate this regulation? How responsible is it that producers will be shipping coal abroad instead, where environmental standards frequently are less stringent?

This proposed standard threatens future domestic use of an abundant and reliable energy resource, which utilities have used responsibly to provide affordable energy to consumers. Just this week, the EIA announced that 2012 U.S. carbon dioxide emissions from the consumption of fossil fuels declined almost 4 percent from the 2011 level. Energy-related CO2 emissions have declined in five of the last seven years and are the lowest they have been since 1994.6 American innovation, efficiency and a mix of energy sources are providing greater air quality improvements than government can.

This future of U.S. coal-fired plants and a dependable domestic source of fuel will be endangered by this proposal, and with it, our nation’s economic prosperity. As Americans continue to recover from the Great Recession, the federal government has a responsibility to ensure that citizens and industry are not burdened by higher energy prices because of policies that it readily admits will have minimal effect.



2 thoughts on “Proposed CO2 Standards: Expensive Hot Air


    The Environmental Protection Agency (EPA) had hearings in Atlanta, GA October 23 soliciting public comments about reducing carbon (carbon dioxide) pollution from existing stationary power plants. The EPA has a goal of eliminating coal from power production and if successful most likely would lead to future attacks on natural gas as a fuel source.

    Approximately 200 attended the opening session Wednesday afternoon. The Region 4 EPA Director made introductory remarks about the need for reducing carbon dioxide pollution siting severe climate events that plagued the United States in 2012. The country had 8 million acres burned by wildfires, droughts, floods, and in particular the devastating hurricane Sandy that hit New York last October. The EPA uses reports from the UN Intergovernmental Panel on Climate Change (UNIPCC) as their sole source for scientific information on climate change. Apparently no one told the Region 4 Director the 2013 UNIPCC report stated carbon dioxide is not responsible for weather events like Sandy

    Speakers were allowed 3 minutes for presentations which is a woeful lack of time for such an important topic. I stayed to hear presentations from 30 speakers–28 protested these rules would create burdensome increases in electricity prices and 2 said the rules were necessary to save the planet.

    I was the twentieth speaker and attacked the scientific basis EPA used for their rules that was not addressed by other speakers up to the end of 30 presentations. I passed out a 4-page handout that gave detailed, referenced reasons why EPA actions had no scientific merit. The handout follows this material.

    I immediately attacked the EPA for rules that endangered public health and would ruin the nation’s economy. I challenged the EPA to bring their top scientific advisor to Atlanta and engage in a debate on the merits of carbon dioxide being anything but a necessary airborne fertilizer and an insignificant player on climate behavior. The public should put pressure on the EPA to be forthright in engaging in open debate about the merits of their onerous proposals. The rules proposed by EPA will have a negative impact of trillions of dollars on the United States’ economy.


    Dr. James H. Rust, Policy Advisor The Heartland Institute

    J’accuse the Environmental Protection Agency (EPA) of proposing rules to abolish use of coal for stationary power plants that unnecessarily increases costs of electric power generation with harm to health and economy of our country.

    J’accuse the EPA of implementing rules to abolish use of coal for future electric power plants with unnecessary harmful increased cost for electricity.

    J’accuse the EPA of implementing Mercury and Air Toxic Standards (MATS) rules on coal-fired electric power plants that added unnecessary expenses to their operation with forced plant shutdowns and increased electricity costs.

    For five years the EPA has waged war on fossil fuels due to misguided views carbon dioxide from burning fossil fuels causes catastrophic global warming. The EPA is substituting words carbon pollution for carbon dioxide in order to mislead the public about its aims. To the public, the words carbon pollution means soot that conjures up images of blacked snow in the winter and soot-covered cars prevalent before the 1960s—a time when coal was burned without environmental controls. This is the same misrepresentation applied to global warming alleged due to burning fossil fuels. When global warming stopped in 2000 in spite of increased use of fossil fuels, climate change was substituted for global warming as key words for predicted cataclysmic planet future. In a sense alarmist views can’t miss with this label because climate change is continuous over the 4 billion-year planet history.

    Fossil fuel use has annually increased in an energy-starved planet due to demands of poorer inhabitants for a decent living standard. This caused an increase in atmospheric carbon dioxide from 310 parts per million (ppm) in 1950 to 400 ppm in 2013. For more than a century it has been hypothesized atmospheric carbon dioxide absorbs infrared radiation and re-emits the radiation back to the atmosphere causing planet warming labeled the greenhouse effect. Water vapor, with an average atmosphere concentration of 10,000 ppm, produces the same effect. Concerns about global warming caused by increased fossil fuel use resulted in creation of the United Nations organization Intergovernmental Panel on Climate Change (UNIPCC) in 1988 to study effects of increasing atmospheric carbon dioxide. Since 1990, the IPCC has published a series of five reports (1990, 1995, 2001, 2007, and 2013) stating their beliefs in the role of carbon dioxide on climate and made projections of future global temperatures based on computer generated data from global climate models.

    The EPA has used IPCC reports as their sole source of information about the role of increasing atmospheric carbon dioxide from increasing fossil fuel use. The IPCC reports estimate increased global warming so the EPA embarked on a path to reduce fossil fuel use starting with coal, oil, and, natural gas.

    The UNIPPC was an international organization predicting future climate change without oversight. To balance their reporting, the Nongovernmental International Panel on Climate Change (NIPCC) was created in 2003.

    The 2007 IPCC report stirred up controversy over errors and the NIPCC issued a countering report Nature, Not Human Activity, Rules the Climate in 2008. To highlight more details about errors in the 2007 IPCC report, the NIPCC produced an 856-page report Climate Change Reconsidered: The 2009 Report of the Nongovernmental International Panel on Climate Change. The Heartland Institute assisted in preparation and publication of these reports.

    Anticipating science to be overlooked by the 2013 IPCC report, the NIPCC produced Climate Change Reconsidered: The 2011 Interim Report of the Nongovernmental International Panel on Climate Change. The report featured new scientific evidence and information overlooked by the 2009 report and is found on the Internet at .

    With much media attention and leaking of portions of its report, the UNIPCC announced publication of its fifth report September 27, 2013. In anticipation of the IPCC report, the NIPCC released its first of two reports the 1000-page Climate Change Reconsidered II: Physical Science and 20-page Summary for Policymakers September 17, 2013. The key takeaway messages are (1) the human impact on climate is very small and (2) any change in temperatures that might be occurring or will occur in the future is so small that it will not be noticed against the climate’s entirely natural variability. These reports are available on the Internet at .

    In order to compare information from the NIPCC with that of the IPCC, the 2013 IPCC Summary for Policymakers issued September 27, 2013 is found at

    The IPCC report glosses over no global warming for 15 years and failure of all global climate models to match experimental global temperature data.

    The EPA refuses to examine information that counters global warming is produced by increased use of fossil fuels and any benefits achieved by global warming. There are thousands of papers and books showing benefits of global warming and increased carbon dioxide on the planet. A good summary of benefits is the paper in the October 19, 2013 Spectator “Why Climate Change is Good For The World” by Matt Ridley found at

    Warming saves lives while cold kills. It is estimated 29,000 Britons died in the United Kingdom the past winter due to cold. Increasing atmospheric carbon dioxide increases plant growth and makes plants more resistant to drought due to larger root systems. We are able to produce enough food to feed 7 billion on the planet due to the 40 percent increase in atmospheric carbon dioxide concentrations since the start of the Industrial Revolution.

    It is suspected the EPA will issue rules involving carbon dioxide emissions for current power plants similar to rules applying to future power plants—1000 pounds of carbon dioxide emissions per megawatt-hour (MW-hr.) for natural gas-fueled power plants and 1100 pounds of carbon dioxide emissions per MW-hr. for coal-fired power plants. The rules for future power plants were issued September 2013 which prompted Investor’s Business Daily to write an editorial September 20, 2013 “New Rules On Power Plants Will Kill Coal Industry” found at . The editorial stated, “Far from being a plan to clean up the environment, it is in fact a road map to de-industrialization and poverty.” Examples were given of power plant shutdowns and the threat of businesses to leave the country because of escalating electricity prices.

    Gas turbine combined cycle (GTCC) power plants can meet the requirement of 1000 pounds of carbon dioxide emissions per MW-hr. High performance coal-fired power plants typically emit 1800 pounds of carbon dioxide per MW-hr. and can’t meet these standards without carbon dioxide capture and sequestration (CDCS) of at least 40 percent of carbon dioxide emissions.

    CDCS has not been demonstrated for large power plants. It is a very costly process that requires one-third the power output of plants and needs safe places for underground storage of enormous amounts of high-pressure carbon dioxide. Widespread application of CDCS would require annual storage of billions of tons of carbon dioxide.

    Underground storage of high-pressure carbon dioxide presents safety problems never encountered in the United States. Carbon dioxide is denser than air and large leaks from underground storage would produce situations where leaking gas spreading along the earth’s surface would suffocate all encountering the gas. In 1986, carbon dioxide emerging from Lake Nyos in the Cameroon suffocated 1700 people and thousands of head of cattle. Similar situations have occurred elsewhere in Africa.

    It is ironic the EPA charged with safety of American citizens is taking a non-existent hazard of carbon dioxide emissions from burning coal and creating situations of enormous waste of money on CDCS that kills unsuspecting citizens. This debacle applies to controlling carbon dioxide emissions from current and future coal-fired power plants.

    A critique of EPA’s Mercury and Air Toxic Standards (MATS) by Prof. James H. Rust “Do New EPA Regulations on Power Plant Mercury Effluents Make Sense?” is published May 3, 2011 by The Heartland Institute . These rules reduce mercury emissions, that are not problems, from coal-fired power plants at great costs and shut downs of operating power plants. At the same time EPA endorses use of compact fluorescent light bulbs (CFL) because they use less electricity. CFLs contain about 4 milligrams of mercury and when you factor in over one billion CFLs in use today and fast growing, you have a vast potential for mercury contamination directly inside homes from bulb breakage and improper disposal. When the four billion light sockets in homes are filled with CFLs (18 tons of mercury), considerations of mercury contamination from coal-burning power plants may look silly. Humans occupy less than one-tenth percent of the United States’ land area for living space; so inside mercury contaminations per square foot can be large.

    In summary, using poor science and a lack of judgment, the EPA has promulgated rules pertaining to fossil fuel use that are aimed at eliminating use of the nation’s vast reservoir of fossil fuels. Once these rules are implemented, more onerous rules must follow. Great economic damage is done that leads to poverty for the nation. On top of these problems, the rules that are issued in the name of promoting health create health problems far more damaging.

    The EPA is succeeding in these objective due to lack of realistic media attention and public apathy. At the end of WWII, Pastor Martin Niemoller was asked how this destructive Nazis Party could take over the country in the 1930s. He said apathy and produced a four-sentence verse that described his failure to sound alarm about impending events from demonic National Socialism.

    In our present time, Pastor Niemoller might have said the following about EPA pollution rules:

    First they closed the coal mines, and I didn’t speak out because I was not a miner.

    Then they stopped oil and gas drilling, and I didn’t speak out because I didn’t work in oil fields.

    Then they shut down nuclear power plants, and I didn’t speak out because I didn’t work at nuclear power plants.

    Then they shut off all my electricity and there was no one left to speak out for me.

    Heed these words; the EPA is set upon a path to destroy the Unites States economy and impoverish most of our citizens. Poverty kills as surely as disease.

  2. I think this post was EXTREMELY informative. I think CO2 standards is a topic that is not covered enough by the press. It’s absolutely crazy how many legal battles are being waged over this subject. I really appreciate that you actually listed your references at the end of this article — many people who discuss this topic don’t bother to show where they’re getting their information from, so it can be hard to believe what they have to say.

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