Steve Seidel, vice president for policy analysis, co-wrote this post.
With the failure of the Senate to act on climate change legislation, the focus of attention now shifts to possible regulatory actions by EPA. The Supreme Court in 2007 made it clear that greenhouse gases (GHGs) are pollutants under the existing Clean Air Act (CAA), and the overwhelming scientific evidence (spelled out in great detail in the endangerment finding) demonstrates that such pollutants represent possible harm to public health and welfare.
Opposition to EPA action rests in part on concerns that any regulations will be excessively costly and burdensome to households and U.S. manufacturers. While it is certainly true that regulating GHGs will result in costs, it is also important to look at whether the economic benefits from those regulations will be greater than the costs they impose. In other words, will societal costs of allowing global GHG emissions to continue unabated (costs that will come in the form of impacts from rising sea levels, increased extreme weather including heat waves and droughts, among others) be greater than the costs of regulating those emissions responsibly?
This basic regulatory framework – that regulatory costs should be less than the resulting benefits – is codified in OMB review of all major federal regulations by both Republican and Democratic Administrations, has historically been applied to all EPA regulations, and would certainly be applied to any future regulations of GHGs.
So what have been the costs and benefits of past EPA regulations under the CAA historically? Congress required EPA to undertake a retrospective assessment of the costs and benefits of regulations under this statute. The conclusion of this retrospective review is that the CAA resulted in total benefits that are around $37 trillion, while total costs were $0.874 trillion (in 2010 dollars) – an astounding 40 to 1 benefit to cost ratio!
EPA has also produced a prospective assessment of the costs and benefits of the CAA – this time for the time period of 1990 through 2010. In this review, EPA estimated that the most likely benefit to cost ratio of the CAA for this period is 4 to 1. While a very strong and positive value, the ratio is substantially lower than the estimated benefits for the first 20 years of the CAA.
This is not unexpected – early gains are usually greater, and more cost effective, because simple or cheap remedies are the first to be applied in response to regulatory requirements. As those requirements become more stringent, creating additional benefits becomes more costly (from an economics perspective this is described as moving up the marginal cost curve).
How credible is EPA’s assessment of its regulations? Alan Krupnick, formerly of the President’s Council of Economic Advisors, has testified before Congress about the credibility of EPA’s analyses: “Under the auspices of the agency’s Science Advisory Board, both studies were scrutinized throughout the decade-long preparation by at least three expert committees of outside economists, air quality modelers, epidemiologists, and other health experts.”
In addition to these EPA assessments, there have been a handful of quality external analyses of the costs and benefits of the CAA. The Office of Management and Budget (OMB) found that the “major rules” from EPA’s Office of Air resulted in total benefits between $145 and $218 billion annually, for the years between 1992 and 2002. This is compared to costs of between $22 and $25 billion over that same period. A study by researchers at MIT found total annual benefits rising from $50 billion in 1975 to $400 billion in 2000. This report accounts for the monetary benefits of avoided premature death differently than the EPA studies, and as a result reports lower values for the total benefits. A sum of the total discounted benefits yields a total benefit of $6.85 trillion from 1975 through 2000 – a figure still substantially greater than the EPA estimate for the costs of the regulations.
So how might this play out in terms of future regulations of GHGs? EPA’s first GHG regulations were standards set for light duty vehicles (which it coordinated with the efficiency standards set by NHTSA). These standards are expected to lead to net benefits of between $0.5 and 1.2 billion dollars (discounted back to present values using 7 percent and 3 percent discount rates, respectively) without even including a social cost of carbon. If a value is assigned to the avoided GHG emissions associated with this regulation, the net present benefits are even greater!
If there is a lesson that can be drawn from these previous regulatory efforts it is that while regulations do impose real costs, EPA’s actions under the CAA have consistently led to positive environmental and economic outcomes. By not regulating, we would have foregone these positive net benefits and incurred the social costs imposed by unabated pollution.
So the next time someone tells you that the costs of reducing air pollution are too high, ask them what would be the costs to society of not reducing those emissions.
Russell Meyer is the Senior Fellow for Economics and Policy. Steve Seidel is Vice President for Policy Analysis.
A small company finding it hard to sell its residential energy usage monitoring devices starts a “parent-teenage contract” marketing campaign. The teenager gets the parents to buy the device, and then they both sign a contract stipulating that the teenager will keep half the money saved on reduced energy usage. As the savings start to roll in, the teenager becomes more motivated to improve the household’s energy efficiency as do the parents, while the company points to this positive experience as it seeks additional customers for its monitoring device. This model has achieved success on a small scale, but could it be adopted on a wider level as it is driven by a business case, contains ingredients for cultural transformation and taps into incentives that appear to be driving action?
This was one of the many thought-provoking anecdotes shared at the ninth Green Innovation in Business Network (GIBN) Solutions Lab held in Boston where the 90 or so participants spent the day coming up with solutions to barriers faced by companies pursuing energy efficiency. The Pew Center on Global Climate Change was a co-sponsor of the event, along with the Environmental Defense Fund, Ashoka, Microsoft, Net Impact Boston, and many other partners. (For more information on GIBN Solutions Labs and the topics discussed at this specific event please click here.)
The GIBN Solution Labs are one-day workshops structured in an “unconference” format where participants are divided into small groups of about eight or less. Each group brainstorms solutions to a specific issue or barrier and reports back to the whole group at the end of the day. With the umbrella theme of overcoming barriers to energy efficiency, the Boston GIBN Solutions Lab focused on 14 specific topics, such as financing, making the business case and motivating the public on energy efficiency. Participants including companies, consultants, academics, and non-governmental organizations spent the morning exploring a variety of topics and then chose one in the afternoon to focus on in depth through a problem identification and solution design process.
Peter Senge, founding chair of Society for Organizational Learning and senior lecturer at the Massachusetts Institute of Technology, kicked off the workshop with a thought-provoking speech that emphasized the need for a comprehensive vision for energy efficiency instead of piecemeal solutions. By the end of the workshop some pieces of the vision had emerged: establish energy efficiency as a social norm; create business models that support energy efficiency investments; and design methods to more effectively communicate the benefits of energy efficiency.
The day was filled with a constant buzz of conversations out of which emerged some “out of the box” ideas as well as best practices. The group tackling the issue of motivating the public on energy efficiency proposed a K-12 energy efficiency curriculum that would result in children passing along the learning to their parents. Interestingly, the group on improving energy efficiency of buildings also saw children as key players. It proposed student projects involving energy audits and efficiency implementation measures for school buildings. A “just do it,” results-oriented approach was suggested to get senior management buy-in for energy efficiency projects: do the energy audit (which many utilities will provide free of charge) and then use the results of potential energy savings to convince senior management to implement the energy efficiency measures. Creative employee communication methods were also suggested such as distributing figures on how much paper and printer toner is being used by the office or putting up a sign next to the printer asking “Do you really need to print this?” There were also some “out of the box” topics: one group looked at the water-energy nexus and noted that understanding the relationships between water usage and energy could spur new technical innovations such as water-less laundry systems.
Discussions also emphasized known best practices, which were useful to participants just getting started on energy efficiency and sustainability issues. For example, developing a detailed work plan and timeframe when proposing an energy efficiency project to senior management was essential in getting their approval to move ahead. Additionally, continuous monitoring and progress reports are critical in maintaining momentum and receiving the okay to pursue more projects in the future. Recommendations for embedding energy efficiency within corporate supply chains included clearly communicating energy efficiency expectations to suppliers; helping them find the right resources to implement energy efficiency measures; and auditing suppliers to ensure implementation and maintenance.
The end-of-day presentations highlighted that while each group was tackling different topics related to energy efficiency they struggled with some common barriers. For example, financing and communicating energy efficiency were issues that almost all groups found necessary and yet difficult to overcome.
In terms of specific solutions, not everyone went home with sure-fire answers to how they were going to fund their energy efficiency projects or convince senior management to make energy efficiency a priority. However, most participants did leave with at least a few new ideas to try out and the understanding that in order to be an effective component of the effort to reduce greenhouse gas emissions, energy efficiency required a comprehensive, system-based approach.
Aisha Husain is an Energy Efficiency Fellow
This month I joined John Donahue, the CEO of eBay, at a National Press Club event to discuss the climate benefits created by small, online retail businesses. The retail sector—and the private sector more broadly—has a huge opportunity to innovate and drive us toward a more climate-friendly clean energy economy, and we are encouraged that eBay is stepping forward to make this point.
Active business community engagement is fundamental both to achieving effective climate policy and to achieving real reductions in greenhouse gas emissions. Industry must work with their employees, their supply chain, and policy makers to make the case that addressing a changing climate is essential and can be good for business—providing policy certainty, leading to innovation and investment, and ultimately helping to move our economy towards a low-carbon future.
According to the new eBay-commissioned white paper, small e-retailers facilitate the reuse of products and eliminate the need for carbon-intensive brick-and-mortar stores, both of which are climate-friendly compared to big box retail. For instance, it suggests that since eBay’s founding 15 years ago, the infrastructure savings from its online marketplace alone have cumulatively displaced emissions equivalent to approximately 4 million tons of CO2 per year, or the annual output of 760,000 cars—roughly the number registered in the state of Kansas or West Virginia.
In our current period of policy uncertainty, one thing we do know is that energy efficiency matters and it works. We also know from the work we do on employee engagement that individuals and consumers are a huge untapped resource in the effort to seriously address our energy-climate challenges. It’s clear that the key role for retailers—both online and “offline”—is to connect consumers to low-emission/energy-efficient goods and services, and companies such as eBay and Best Buy, a featured case study in our recent report on corporate energy efficiency, are doing just that.
Eileen Claussen is President
This blog post originally appeared on Belfer Center's An Economic View of the Environment
Cap-and-trade has been demonized by conservatives as part of an effective strategy to stop climate legislation from moving forward in the U.S. Congress. As I wrote in my previous blog post (“Beware of Scorched-Earth Strategies in Climate Debates,” July 27, 2010), this unfortunate tarnishing of market-based instruments for environmental protection will come back to haunt conservatives and liberals alike when it becomes politically difficult to use the power of the marketplace to reduce business costs in the pursuit of a wide variety of environmental objectives.
Cap and trade has gotten a bad rap. It’s been vilified as a national energy tax, an elaborate Ponzi scheme, and a giveaway to corporate polluters.
While these attacks are wrong, they succeeded in shaping the political discourse around national climate and energy policy, which undoubtedly contributed to last week’s decision by Senate leaders to delay consideration of legislation that would limit greenhouse gas emissions.
This is unfortunate. We need a national policy to reduce emissions, and, as our new white paper shows, cap and trade is still the best, most cost-effective way of doing so. When lawmakers turn their attention back to this issue — as they must — they should make cap and trade a foundational element of the policy response to climate change.
By: Janet Peace and Robert N. Stavins
There is broad consensus among those engaged in climate policy analysis—from academia, government, NGOs, and industry—that any domestic climate policy should include, at its core, market-based policy instruments targeting greenhouse gas (GHGs) emissions, because no other approach can do the job and do it at acceptable cost. By “putting a price on carbon,” market-based polices harness the power of our free enterprise system to reduce pollution at the lowest costs. Recent concern, however, about the role of financial markets—and specific fraudulent investment vehicles—in the recent recession have raised questions among the public about the efficacy and functioning of markets. Not surprisingly, some have questioned the wisdom of employing market mechanisms to tackle climate change. Critics ask, how can market-based policy instruments be trusted to look after the public’s welfare with regard to global-warming pollution (or anything else, for that matter)?
When it comes to climate change and environmental issues more generally, environmental economists recognize that the source of many problems is not markets per se, but the absence of markets for environmental goods and services, such as clean air and water. In the absence of prices (costs) associated with environmental damages, producers and consumers need not account for such damages in their activities and choices. Environmental damage is thus an unintentional byproduct of decisions to produce or consume. Because these negative consequences are external to the firm or individual creating them, economists refer to them as externalities. They are one category of market failures; in this case, the failure of existing markets to price accurately the full costs to society of producing and consuming goods that create a pollution externality.
In the case of climate change, the burning of fossil fuels and other activities that release GHGs into the atmosphere are associated with increasing global temperatures. The costs of these impacts, including an increase in extreme weather events, rising sea levels, loss of biodiversity, and other effects, are borne by society as a whole, including future generations. In the absence of a price on carbon, these environmental costs are not included in the prices of GHG-based goods—thus there is no direct cost for emitting GHG pollution into the atmosphere. From a societal perspective, this leads to an inefficient use of resources, excessive emissions, and a buildup of excess concentrations of GHGs in the atmosphere.
The current status quo or “laissez-faire” approach to dealing (or rather failing to deal) with GHG pollution results in an outcome that is not in the interest of society. For this reason, many people have advocated putting a price on GHG emissions to cause market participants to confront or “internalize” the costs of their actions and choices. A policy instrument that puts a price on GHG emissions would, for example, raise the cost of coal-generated electricity, relative to electricity generated with natural gas, because coal as a fuel emits more carbon dioxide (CO2) per unit of energy. Producers and consumers would take this relative cost differential into account when deciding how much electricity to produce and what fuels to use in producing it. That is the point — to make the cost of emitting carbon explicit, so that it becomes part of the everyday decisionmaking process.
Two alternative market-based mechanisms can be used to put a price on emissions of GHGs—cap and trade and carbon taxes. With cap and trade, an upper limit or “cap” on emissions is established. Emission allowances that equal the cap are distributed (either freely or through auction) to regulated sources which are allowed to trade them; supply and demand for these allowances determine their price. Sources which face higher abatement costs have an incentive to reduce their abatement burden by purchasing additional allowances, and sources which face lower abatement costs have an incentive to reduce more and sell their excess allowances. Thus, the government establishes the environmental goal (the cap), but the market sets the price.
In contrast, a carbon tax sets a price on emissions, but leaves the environmental outcome uncertain. The tax creates an incentive for firms to reduce their emissions up to the point where the cost of reductions is equivalent to the tax. If the tax is low, fewer reductions will result; if the tax is high, more abatement effort will be forthcoming. Given the real-world U.S. political context, the more promising of the two market-based approaches to addressing climate change is clearly cap and trade, which creates a market for GHG reductions.
While the common sense justification for putting a price on carbon emissions seems straightforward, some of the public and even some policy makers are questioning whether creating a market for GHG reductions is a cure worse than the disease itself. Some questions and concerns include the following:
- Why employ market-based approaches to GHG emission reductions, when markets are subject to manipulation?
- Would a market-based approach to reducing GHG emissions be a corporate handout?
- Can markets be trusted to reduce emissions?
- Will a market-based approach, such as cap and trade, be too costly?
- Are other approaches—including conventional regulation and taxes—likely to be more effective and less complicated?
Our goal in this paper is to address the questions above, and—we hope—leave the reader with a better understanding of the issues, the rhetoric, and the fundamental reasons why cap and trade is the most promising approach to address the threat of climate change. We believe that past concerns about how markets operate can be effectively addressed and result in a policy that is both environmentally and economically superior to alternative approaches.
By: Jessica Shipley, Solutions Fellow, Pew Center on Global Climate Change
Any climate and energy legislation will impact U.S. farmers and ranchers, and this paper examines the many legitimate concerns the agriculture sector has with such legislation. There have been a large number of economic analyses, modeling exercises, and reports published in the past several months based on an array of climate policy assumptions, and the resulting scenarios have ranged from realistic to doomsday. The results of these efforts have often been skewed or cherry-picked to support particular arguments. This brief tries to objectively assess the impacts of climate legislation and identify ways that such legislation could be shaped to provide greater opportunities for the sector. U.S. farmers have long exhibited adaptability and entrepreneurship in the face of changing circumstances, and they will be presented with a host of new markets and opportunities with the advent of climate and energy legislation.
Farmers have many reasons to be engaged participants in the climate and energy policymaking process. It is imperative that the United States take constructive action on climate and energy to maintain a leading role in the new energy economy. In shaping those actions, productive engagement by American farmers can help ensure that U.S. policy addresses their concerns and embodies their ideas. America’s farmers will be the best advocates of both the principles of a robust offset market and the creation of other market and renewable energy opportunities.
Key takeaways from this brief are:
- American farmers and industry will face greenhouse gas limitations regardless of what happens in the legislative and regulatory process. Market-driven requirements from the private sector (e.g. Walmart), regulation by the U.S. Environmental Protection Agency (EPA), state or regional programs, and nuisance lawsuits will continue to require greenhouse gas (GHG) emissions to be reduced going forward. Legislation can simplify requirements on business, provide incentives and new markets for farmers, and provide mechanisms to lower the risks and costs to all sectors of the economy. In fact, without legislation, the piecemeal nature of GHG limitations will likely result in a worse outcome for farmers.
- Costs to farmers from GHG legislation can be substantially mitigated by cost-containment mechanisms. Though there is potential for increased costs (namely energy and fertilizer input costs) to farmers, mechanisms potentially available in legislation can significantly minimize price volatility and cost impacts to farmers and the economy as a whole, even though not all these can be adequately reflected in economic modeling.
- The opportunities for farmers to realize a net economic gain from climate legislation are significant. Offsets, biofuel and biopower, renewable power, and the ability to receive payments for multiple environmental benefits from well-managed working farmlands are among the new potential opportunities. The key to making this a reality is climate and energy policy that is shaped by the agriculture sector and farmers themselves.
- Climate change and resulting weather patterns pose numerous risk management concerns for agriculture. The strong scientific evidence behind climate change should concern farmers because of the significant new risks climate change poses to farmland and the rate at which those risks are increasing.
Companies that make everything from computer chips to potato chips, search engines to jet engines, rubber tires to rubber soles, have stepped up this year to publicly support passage of comprehensive clean energy and climate change legislation. Why are companies calling for increased regulation? Isn’t that akin to a teenager arguing for an earlier curfew, or a second grader demanding an end to recess?
Actually, no. The days when businesses could be counted on to reflexively oppose all environmental regulations are over, and that’s a good thing. Nowhere is this shift more evident than in the case of climate change policy. American Business for Clean Energy tracks nearly 6,000 businesses, both large and small, that support energy and climate legislation. Dozens of companies, representing trillions of dollars in revenue, have signed on to letters and paid advertisements calling for prompt action on such legislation. These companies have determined that a clear and consistent national framework to begin reducing emissions is good for the economy and good for their industries. Our new brief, The Business Case for Climate Legislation, details the reasons why.
This briefing will be held at two separate times and locations to accommodate House and Senate staff.
Wednesday, June 30
12:00 Noon to 1:30 PM
Rayburn House Office Building, Room 2325
3:30 to 4:45 PM
Capitol Visitors Center, Room SVC 202
Seasonal forecasters predict that 2010 will produce between 14 and 23 named hurricanes -- the most active season since 2005, when Hurricane Katrina and 27 other named storms swept the Atlantic and Gulf of Mexico. As economic challenges continue and oil spews from the damaged Deepwater Horizon well in the Gulf, the growing impacts to the region's economic recovery and unique ecosystems are staggering. What risks does an active hurricane season pose for other energy-related infrastructure, for inland areas as storm surges push oil beyond beaches and marshland, and for stakeholders dealing with flooding in coastal communities in the Gulf and along the East Coast? Can recent advances in hurricane prediction help manage these risks? Might related climate change impacts exacerbate them in the future? What does an increasing scale of catastrophic loss associated with hurricane activity mean for critical services provided by the insurance sector? Please join our panelists as they address these questions and discuss research results, institutions, and processes in place to help manage potential catastrophic risk of this hurricane season.
Opening remarks by Senator Mary Landrieu, Honorary Host (3:30pm briefing only)
- Heidi Cullen
CEO and Director of Communications, Climate Central
- Greg Holland
Director, NCAR Earth System Laboratory, National Center for Atmospheric Research
- Rick Luettich
Professor & Director, Institute of Marine Sciences, University of North Carolina at Chapel Hill
- Rowan Douglas
CEO, Global Dynamics, Willis Re and Chairman, Willis Re Research Network
RSVP to Gloria Kelly at firstname.lastname@example.org or (303) 497-2102 by Monday, June 28
Sponsored by the American Geophysical Union (AGU), the Congressional Hazards Caucus Alliance, the National Science Foundation (NSF), the Pew Center on Global Climate Change, the University Corporation for Atmospheric Research (UCAR), and the Weather Coalition.
With appreciation to the House Committee on Science and Technology and the Senate Subcommittee on Disaster Recovery of the Committee on Homeland Security and Governmental Affairs.
June 23, 2010
By Eileen Claussen and Jim Rogers
This op-ed first appeared in Politico.
Passing a meaningful energy and climate bill this year will be challenging — but not impossible.
It’s time for all of us — politicians, business leaders and environmentalists — to put wishful thinking aside, establish realistic goals and develop a consensus for legislation that can be passed this year.
If that means capping emissions from the utility sector first — so be it. There is growing consensus in the electric utility industry to act now, so let’s move forward.
Duke Energy and other electric utilities are already scheduled to retire and replace virtually all coal and other large power plants with cleaner and more efficient technologies by 2050.
A clear and predictable federal energy and climate policy can accelerate these projects and put private capital to work more rapidly. It can also create millions of jobs.
This would not only reduce greenhouse gas emissions but would also reduce sulfur dioxide, nitrogen oxide and mercury emissions, which contribute to acid rain, smog and other health issues. That would improve air quality across the board.
At Duke Energy, approximately 6,000 people are now working on designing and building more advanced power plants. That’s quite an economic stimulus.
When their work is done, permanent jobs would be created, municipal and county tax collections would increase and old and inefficient power plants would be shut down.
With the right signal from Washington, the company can by 2020 close roughly 4,000 megawatts of coal plants more than 45 years old.
This action will drive greater use of cleaner, domestic energy sources that will enhance our nation’s security and limit pollution.
Sensible policy should include incentives for new emissions-free nuclear power, renewable energy and carbon capture and storage for coal plants. It must also clarify federal emissions regulations so electric utilities can shift to cleaner and more efficient power plants without the uncertainty of patchwork regulatory approaches and the threat of litigation.
Electric utilities have some of the strongest balance sheets in industry. They can now borrow private capital at historically low rates. For example, over the past 2½ years, Duke Energy has borrowed $8 billion at an average rate of less than 5.5 percent.
This means lower long-term costs to electric consumers — with no increase in the national debt and deficit.
But this will all take time. We need to be willing to adopt the three C’s: commitment, collaboration and compromise.
Commitment: We have to be in this together — for the long haul. Good energy and climate policies will allow the electric utility industry to make sound investment decisions.
Electric utilities may be willing to go first. But they are not going to be willing to go alone.
Collaboration: All successful environmental legislation has been predicated on a collaborative and bipartisan approach. The 1990 Clean Air Act amendments, designed to reduce acid rain, urban air pollution and toxic air emissions, passed the House by a 401-21 vote and the Senate by a 89-11 vote.
That process of working together to find common ground among diverse stakeholders is what we need now.
Compromise: Collaboration succeeds only when there’s a real spirit of compromise. That’s why it is the cornerstone of our democracy. There must be give-and-take at every decision point.
Current clean energy and climate legislation is not an all-or-nothing proposition. It’s a work in progress that can begin our transition to a clean energy future. We need to look past our differences and act where there is agreement.
It’s time to get started.
Eileen Claussen is president of the Pew Center on Global Climate Change. Jim Rogers is chairman, president and CEO of Duke Energy.