Oops, A "Typo"! EPA Left Alaska, Hawaii, Territories Out Of "Replacement" For Clean Power Plan
When EPA released its Affordable Clean Energy rule earlier this month, it appeared to leave Alaska, Hawaii and U.S. territories out of its cost-benefit analysis. The regulatory impact analysis for the power plant carbon rule posted on EPA's website on June 19, a few hours after the rule itself included language strongly hinting that displaced Alaskan villages and flooded Hawaiian coastal infrastructure had never been part of the Trump administration's controversial accounting for the cost of climate change to the American economy.
That appears to have been a mistake. A spokesperson for EPA called it a "typo" in an email last Tuesday and two days later reported that the "typo" had been corrected. But how, exactly, the Trump administration arrived at its carbon cost estimates remains unclear. The Trump administration has used the so-called interim domestic social cost of carbon estimates to justify the ACE rule and a handful of other administration regulatory actions over the last two years.
Before E&E News inquired about the issue, EPA's regulatory document stated that the estimates "account for the direct impacts of climate change that are anticipated to occur within the contiguous 48 states." That sentence seemed to imply that carbon cost estimates which environmental economists already criticize as artificially low because they exclude climate-related economic pain outside of U.S. borders might also ignore impacts for two states and five U.S. territories.
If the line was an error, last year's proposed version of the ACE rule included it, too. And it caught the eye of analysts at New York University School of Law's Institute for Policy Integrity. "The arbitrary limitation of EPA's 'domestic-only' focus is highlighted by the fact that the regulatory impact analysis reports that the social cost of greenhouse gas estimates actually only cover effects to the contiguous 48 states, meaning some of the most climate-vulnerable areas of the United States Alaska, Hawaii, Puerto Rico, other island and maritime territories, and military bases located outside U.S. borders are all omitted," wrote the Institute for Public Policy and partners, including the Union of Concerned Scientists and Natural Resources Defense Council, in comments to EPA.
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https://www.eenews.net/climatewire/2019/07/01/stories/1060678675