The Administration is happy to claim that not extending the 2001 tax cuts would be a tax increase.
The administration is also happy to claim that increasing the amount of pollution allowed under Clear Skies is a 73% reduction in NOx even though current law would reduce it further.
So, by their own logic, they are for more pollution. Damn that consistency….
The bill increases the amount of pollution projected to be released. The administration has tried to sell it as being a more efficient way to protect the environment. Under Clear Skies, air pollution will be reduced far less than under current law. One could be sympathetic to the notion that market incentives are a more efficient way to achieve the same goals, but in this case, the goals have been changed.
When the EPA was charged with coming up with a more flexible plan, the Bush administration gutted the proposal.
Under Clear Skies:
SO2
2000 11 million tons
2010 4.5 million tons in 2010
2018 3 million tons in 2018.
Under EPA’s 2001
2 million tons in 2010
NOx Under Clear Skies
2000 5 million tons
2008 2.1 million tons in 2008
2018 1.7 million tons
NOx under 2001 EPA
2008 1.9 million tons
2012 1.25 million tons
Mercury Under Clear Skies
2010 34 tons
2018 15 tons
Under EPA 2001
2008 24 tons
2018 7.5 tons with 70% facility-specific reduction
All of this is assuming there is a change. The arguments the Administration makes concerning the comparisons to the current CAA assumes that the EPA doesn’t enforce the current CAA and that’s a ridiculous assumption.
If the administration wanted to simply improve the effeciency of obtaining the same level of pollution through market based incentives, it could do so approximately throught the 2001 proposal.
Or it could have a real debate about the appropriate level of pollution before it adjusts that level–a lovel that in the CAA had to be done with science in a rulemaking process, not designated in the legislation. The Administration doesn’t want that though and the science behind the recent updates to air quality withstood every test.
The bill is far more problematic when one looks at it including federal preemption of stronger state standards through the permitting process.
Also problematic are the provisions that avoid monitoring of emissions compared to the acid rain system. To have a working permit trading system you need someone to actual make sure the permitted emissions aren’t being exceeded–that is significantly reduced in this situation which means smarter operators can figure out when they have to run clean and when they don’t. Further, several aspects of the system allow it to be gamed. NRDC’s testimony offers one specific example I find interesting:
Section 407(d) of the bill provides opt-in units with a menu of options from which to select the method of establishing their baseline emissions. These baseline options are designed to allow manipulation to create high emission entitlements — that is, opt-in units’ baseline emissions may be manipulated and inflated well above their normal actual emissions, to enable plant owners and operators to receive higher numbers of emissions allowances (rights to emit). In turn these bogus allowances permit higher amounts of emissions in the overall trading scheme. Because this flood of higher, artificial allowances from opt-in units may be traded to power plants and other affected units, the effect is to create additional authorizations to emit above the caps. Stated differently, the infusion of bogus allowances from opt-in units effectively raises the caps above the levels claimed by the administration.
The one thing we should have learned is that when a market is allowed to be gamed, it will be. This system will offer the same sort of problems as California’s deregulation of power, where by allowing producers to determine the starting points, they get to set the rules of the game. If it doesn’t bother you, then think of it as a barrier to entry for new, cleaner players in the system. If that doesn’t bother you, you are not concerned about the environment or a neutral market for capitalism.