Response to the Environmental Protection Agency: Reducing Greenhouse Gas Emissions from New and Existing Fossil Fuel-Fired Stationary Combustion Turbines at Power Plants

Summary

The Environmental Protection Agency in its “framing questions” on greenhouse gas
emissions from natural gas combustion turbines at electric generating stations asserts that such
GHG emissions are important “pollutants” in the context of anthropogenic climate change. But
that premise is not consistent with the future temperature effect — 0.017°C by 2100 — of
eliminating such emissions, as predicted by the EPA climate model under assumptions that
exaggerate the future effects of reduced GHG emissions. Given the standard deviation of the
surface temperature record, that impact would not be detectable, and the same is true for any U.S.
climate policy except the Biden administration net-zero emissions policy, the effect of which
would be barely detectable under a one-tailed statistical test.

Because of this obvious reality, EPA is certain to substitute the asserted social cost of GHG
(SC-GHG) as a “benefit” of reductions in GHG emissions. The SC-GHG is fatally flawed. It is
driven by RCP8.5, a scenario of future atmospheric concentrations of GHG that is virtually
impossible. It is driven also by climate models that overstate the atmospheric temperature record
by a factor of over 2.3. It includes as “benefits” the asserted global impacts of U.S. policies, even
though U.S. policies will have global effects either trivial or approximately zero, and even though
individuals not residing in the U.S. are essentially unaffected by U.S. policies in any event. The
SC-GHG ignores the substantial social benefits of rising GHG concentrations, among which are
planetary greening, a large net reduction in mortality from cold and heat, and increased agricultural
productivity. The federal government calculation of the SC-GHG includes the asserted “cobenefits” of reductions in the emissions of criteria and hazardous air pollutants already regulated
under various provisions of the CAA. The SC-GHG is calculated using discount rates that are
artificially low, failing to reflect the correct opportunity cost of government allocation of resources.
Moreover, the interests of future generations are not consistent with the application of discount
rates artificially low. Moreover, the SC-GHG mischaracterizes the future GDP effects of rising
GHG concentrations, as predicted in the central integrated assessment models and even in the
IPCC “1.5° Special Report.”

Finally, the EPA definition of GHG as “pollutants” is little more than political propaganda.
By far the most important GHG in terms of the radiative properties of the atmosphere is water
vapor, which few if any describe as a “pollutant” and which can be emitted in large quantities by
volcanic eruptions. The EPA “framing questions” in the context of GHG emissions from natural
gas turbines at EGUs are misguided, and should be revised in their entirety.

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