The Environmental Protection Agency recently proposed onerous new limits carbon dioxide emissions from coal-fired power plants. The standards would prevent construction of new facilities, gradually close older ones, and eventually affect even gas-fired units.
EPA says the rules will safeguard our health and welfare from storms, sea level rise and other ravages of man-made climate change. They are in addition to 1,900 other Obama-era regulations designed to curtail or terminate coal mining and use – and dictate activities affecting air and emissions, land and soils, waterways and puddles.
Far too often, the rules are based on speculative health and environmental claims, cherry-picked studies, dismissal of analyses that contradict agency assertions, and computer models that reflect unfounded assumptions and agenda-driven rule-making.
Many scientists challenge EPA’s claim that carbon dioxide controls climate change; point to solar, cosmic, oceanic and other factors the agency ignores; and note that higher concentrations of atmospheric CO2 spur plant growth and green our planet. They point out that humans contribute only 4% of the CO2 that enters the atmosphere each year, and US coal-based power generation is responsible for only 3% of worldwide human CO2 emissions.
In other words, the power plants EPA wants to shut down account for a trivial 0.01% of the carbon dioxide added to Earth’s atmosphere annually, raising CO2 levels to about 0.04% of the atmosphere
There has been no increase in average global temperatures in 16 years. No Category 3 hurricane has hit the USA in eight years. 2013 has spawned the fewest tornadoes in decades.
Making EPA’s global warming claims even more preposterous, China, India, Russia and Brazil alone emit twice as much carbon dioxide as the United States. That means EPA’s regulations will have zero effect on climate change, and zero benefits, even if CO2 does control Earth’s climate.
EPA justifications for expensive, job-killing mercury, soot and other regulations are equally questionable.
Moreover, this is just one agency. Countless other federal, state, local and international regulatory authorities are also busy interpreting, implementing and imposing rules under thousands of laws, ordinances and treaties. The Competitive Enterprise Institute’s “Ten Thousand Commandments” project calculates that federal rules alone cost American businesses and families $1.8 trillion in annual compliance costs.
No one has estimated the enormous cumulative costs of all the multiple layers of rules – on our economic growth, innovation, competitiveness, job creation and retention, prosperity and pursuit of happiness.
Legislators and regulators justify the rules with assertions that they control miscreants and bring vast benefits to the citizenry. All too often, however, the benefits exist only in their minds, computer models and press releases.
Worse, this is barely the tip of the iceberg. This legal and regulatory behemoth, our crushing $17 trillion national debt and massive unfunded entitlements mean fewer jobs, more layoffs and steadily declining quality of life for tens of millions of Americans. They cannot heat and cool their homes properly, pay rent, mortgage or other bills, take vacations, or save for college and retirement.
Work also brings purpose, pride, stature, and opportunities to serve one’s family and community. Being unable to find or keep a job erodes self-confidence, self-worth and psychological well-being.
The stress of being unemployed – or having to hold several low-paying part-time jobs – meanspoor nutrition, sleep deprivation, more miles of stressful, expensive commuting, family dysfunction, and higher incidences of depression, and alcohol, drug, spousal and child abuse. It means lower life expectancies and higher suicide rates.
It means the complex, indecipherable, burdensome regulations themselves impair our lives, livelihoods, liberties, living standards and life spans – for few or no benefits.
It means every life allegedly saved because of countless, often unjustified regulations is offset by lives lost or shortened because of those rules.
EPA doesn’t even mention any of this – much less include them in its “human health and welfare” analyses, place quantitative values on these impacts, conduct cost-benefit studies, or calculate how many lives will be shortened or lost because of its rules. This failure violates the National Environmental Policy Act, which requires that regulatory actions protect the quality of the overall “human environment.”
It violates Information Quality Act guidelines, which require that regulatory agencies base “major” and “influential” rule-makings on analyses that are accurate, unbiased and complete – not cherry-picked, agenda driven and without regard for the pernicious impacts of the regulations themselves.
It violates the most fundamental principle of regulation: First, do no harm.
Congress, state legislatures and the judicial system must address this huge and growing problem, and not just for EPA; for all regulatory agencies. Not being part of the solution means continuing to be part of the problem, responsible for a growing debacle for workers, living standards, health, welfare and lives.
Requiring this comprehensive analysis for all regulations would be a valuable addition to the REINS legislation (Regulations from the Executive In Need of Scrutiny). However, our courts could already demand it under the NEPA, IQA and other laws.
Business, family, health, welfare and other public interest organizations should nevertheless join concerned legislators in requiring this fundamental and essential cost-benefit analysis for all regulations. Who could honestly oppose safeguarding the health, welfare and lives of American citizens?
This article first appeared in