CFACT testified today at EPA’s hearing on proposed emissions regulations for new power plants.  These regulations will make it nearly impossible to create a new coal-fired electricity plant in the United States at a time when China, India and even Germany are expanding their use of coal.

CFACT senior policy analyst Bonner Cohen, Ph. D. presented CFACT’s testimony today at the Clinton Building in Washington D.C.


Comments on

Proposed Carbon Pollution Standards for New Power Plants

Submitted to the U.S. Environmental Protection Agency

Bonner R. Cohen, Ph. D.

On Behalf of the Committee for a Constructive Tomorrow

February 6, 2014

My name is Bonner Cohen and I am taking this opportunity to comment on the Environmental Protection Agency’s (EPA) proposed carbon-pollution standards for new power plants. .

There are two reasons why the agency’s propoBonner Cohen EPA hearingsal is ill-advised. One is scientific; the other is regulatory. 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 United States is responsible for 3 percent of that 4 percent. All the rest of the CO2 in the atmosphere (96 percent of the total) comes from purely natural causes, such as volcanos, 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 EPA to the Earth’s climate also cannot be measured. Thus, EPA has absolutely no way of saying how its proposed regulations will affect the climate.

Furthermore, in justifying its regulatory action, EPA accepts the theory of anthropogenic (human-induced) global warming driven by the burning of fossil fuels. The 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, EPA constantly refers to “climate change,” as opposed to “global warming.” This is a tacit admission on the part of the agency that the “global warming,’ so confidently predicted by the climate models on which EPA relies, has failed to take place. 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. I would remind the agency that 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 EPA is proposing to do.

The proposal also makes no regulatory sense. China has alreadyChina coal v US surpassed the U.S. as the world’s greatest 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 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, 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.

Bonner R. Cohen, Senior Policy Analyst

Committee for a Constructive Tomorrow

Arlington, Virginia


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