Comment on EPA Power Plan’s Alleged Air Pollution “Co-Benefits”

Marlo Lewis

Climate activists assure us that even if we don’t consider global warming a big problem, we should still support carbon taxes, renewable energy quota, and EPA’s so-called Clean Power Plan (CPP). Such policies, we are told, will save thousands of lives, delivering billions of dollars in net benefits, by coincidentally reducing airborne concentrations of fine particulate matter (PM2.5).

There are three main problems with this “co-benefits” argument. First, EPA’s own data show that total emissions of six principal air pollutants declined 62 percent since 1980 even though carbon dioxide (CO2) emissions increased by 14 percent. What’s more, PM2.5 concentrations declined by 34 percent just since 2000 (the earliest year for which national data are available). History refutes the claim that we need carbon taxes or climate regulations to clean the air.

Second, in the USA, today’s historically low PM2.5 levels likely pose no threat to human life, as UCLA Prof. James Enstrom and nine other experts argue a letter summarizing their work in the field. Among other points, the Enstrom team explain:

“No plausible etiologic mechanism by which PM2.5 causes premature death is established. It is implausible that a never-smoker’s death could be caused by inhalation over an 80 year lifespan of about one teaspoon (~5 grams) of invisible fine particles as a result of daily exposure to 15 µg/m³ [15 micrograms per cubic meter]. This level of exposure is equivalent to smoking about 100 cigarettes over a lifetime or 0.004 cigarettes per day, which is the level often used to define a never-smoker.

The notion that PM2.5 causes premature death becomes even more implausible when one realizes that a person who smokes 0.2 cigarettes/day has a daily exposure of about 750 µg/m³. If a 10 µg/m³ increase in PM2.5 actually caused a 0.61 year reduction in life expectancy, equivalent to the claim of Pope [one of the chief studies on which EPA relies], then a 0.2 cigarettes/day smoker would experience about a 45-year reduction in life expectancy, assuming a linear relationship between changes in PM2.5 and life expectancy. In actuality, never-smokers and smokers of 0.2 cigarettes/day do not experience any increase in total death rate or decrease in life expectancy, in spite of a 50-fold greater exposure to PM2.5. Furthermore, hundreds of toxicology experiments on both animals and humans have not proven that PM2.5 at levels up to 750 µg/m³ causes death.”

Third, even if we assume PM2.5 pollution in the USA poses mortality risks, EPA’s huge PM2.5 co-benefit estimates are implausible. As Anne Smith of NERA Economic Consulting explains, EPA illegitimately assumes the health benefits of PM2.5 reductions from concentrations already below the national ambient air quality standard (NAAQS) for fine particulate matter are as certain as the benefits of reductions from concentrations above the NAAQS.  That is inconsistent with the basic concept of the NAAQS program, which is to set concentration standards at a level “requisite to protect public health . . . allowing an adequate margin of safety.”

Once we factor in the lower probability of PM2.5 health benefits in areas where exposures are already below the NAAQS, the lion’s share of the Power Plan’s purported health benefits disappears.

For further discussion, see my blog post “EPA’s PM2.5 Co-Benefits PR Trick Exposed.”

 The Cooler Heads Digest is the weekly e-mail publication of the Cooler Heads Coalition. For the latest news and commentary, check out the Coalition’s website,

How Continued Life on Earth Depends on Humans—Too Many of Whom Misunderstand the Problems

Alan Carlin | September 8, 2016

Most people understand that our green planetary oasis in the immense universe is highly unusual in terms of the favorable conditions it offers for life on Earth. But from a long-term perspective, there are some troubling signs. The Earth’s internal temperatures are gradually cooling and less carbon dioxide is being naturally emitted into the atmosphere from sources within the Earth. Ice ages are becoming more severe with lower temperatures and declining levels of atmospheric carbon dioxide (CO2).

These signs of an aging planet are troubling because they indicate Earth is very gradually becoming less accommodating for life. Fortunately, humans have come along and are capable of helping out–but only if they can understand the clues and take helpful actions based on them.

The easiest problem to alleviate is the long term gradual decrease in the level of carbon dioxide in the atmosphere, which endangers the availability of this basic input to plant photosynthesis; in fact, humans may have already inadvertently implemented an interim solution. The ice age severity problem is more difficult to alleviate and appears to be a very serious problem from a longer term viewpoint.

So far humans are not doing very well even understanding the problems let alone taking actions that would alleviate them. In fact, the most outspoken group with regard to CO2 is taking actions that would make the situation worse. Fortunately, what they propose is very expensive and they will almost certainly ultimately prove unsuccessful in accomplishing their objectives. The same group generally refuses to consider anything that might actually help the ice age severity problem either.

The remainder of this post will largely discuss the easier of the two problems–keeping atmospheric CO2 above the starvation level for plants. It is easy to show what the problem is using what should be largely noncontroversial science. There is also arecent report by Patrick Moore discussing it, where a much more detailed discussion of the science can be found. CO2 levels in the atmosphere have been irregularly decreasing over geologic history and during the most recent ice age reached a low of about 180 ppmv. As discussed in JK Ward, plant growth was stunted because of low levels of an essential nutrient which is required for photosynthesis and thus for life on Earth. 150 ppmv, just 30 ppmv lower, appears to be the threshold of starvation for most plant life. Animals, including humans, would not be far behind if plants died from CO2starvation. Current atmospheric CO2 levels are about 400 ppmv, only about twice that at the depths of the last ice age.

So in terms of the long perspective of geologic history we are too close for comfort to the point where life on Earth will come to an end because of the lack of sufficient carbon dioxide in the air during future ice ages when atmospheric CO2 levels are much lower. This level probably will not be reached during the next ice age, but starving plants of a vital nutrient will hardly help the environment either. Plants appear to grow best in air at concentrations between 1,000 and 3,000 ppmv, where they have been for much of the last 300 million years with very favorable results for life on Earth and no proven or even signs of catastrophic adverse effects.

Humans Are the Only Likely Saviors of Life on Earth

Rather than being a burden on the environment as many “environmentalists” have often claimed, it now appears that humans are the only likely saviors of life on Earth. During earlier periods of geologic history when there were very high CO2 levels in Earth’s atmosphere, carbon deposits were created in the form of coal, oil, natural gas, and various kinds of carbonaceous rocks. The rock was created with the help of organisms looking for physical protection by creating shells made of calcium carbonate. Life on Earth will inevitably die unless carbon can be recovered from these deposits and put back into the atmosphere in the form of CO2 since natural additions to atmospheric CO2 have long since fallen below depositions into the oceans as the Earth has gradually cooled and natural emissions of CO2 from Earth’s interior have gradually decreased.

By a historical accident, humans have recently started using these deposits of fossil fuels for a highly useful purpose–multiplying their capabilities to use mechanical energy and very recently even for supplementing human brain power. This has resulted in the transformation of human life from brutish to prosperous where it has been pursued in the developed world and more recently in some less developed countries. The resulting emissions of CO2 make it very inexpensive to recover and restore the carbon sequestered long ago since it requires no added effort beyond what humans have already been doing for their own self-interest. Humans are the only ones likely to do this recovery and restoration so vital to prolonging life on Earth. We need to encourage them to do this, not discourage them (such as through regulations or even a carbon tax that may end up endangering life on Earth if pursued long enough, widely enough, and vigorously enough).

The Main Obstacles Are the So-called “Environmentalists” and Their Political Supporters

But there are many humans in the developed world who oppose doing what would really save life on Earth from CO2 starvation even though they mistakenly refer to themselves as “environmentalists.” Most environmental organizations and some politicians in the developed world actually support efforts to restrict human-caused CO2emissions on the basis of faulty science. It can thus be said that these “environmental” organizations and politicians do not have the best interests of the environment and the planet at heart, either through a lack of understanding of geologic history, pursuit of self-interest (such as profits from building wind and solar generating units), or faulty reasoning.

In the last few years, many of them have even taken to calling carbon dioxide a “pollutant.” It is nothing of the sort. It is absolutely necessary for the future of life on Earth and thus for the sustainability of life on Earth as the “environmentalists” are prone to refer to outcomes they approve of. Some “environmentalists” even advocate leaving fossil fuels in the ground, which is the worst policy judgment possible in terms of preserving life on Earth. Fortunately, earlier life forms saved up some of the surplus carbon in the atmospheres of their day and it has come time to take advantage of their “foresight,” not locking it away.

So anyone that refers to CO2 as a “pollutant” or advocates leaving fossil fuels in the ground or reducing human emissions of CO2 to zero can immediately be categorized as anti-environmental in their views on one of the most important environmental issues of all time. How can you consider yourself an “environmentalist” if you advocate starving plants, which are the basis of the food chain for all life on Earth?

Given that most “environmental” organizations appear to have increasingly dug themselves into this anti-environmental viewpoint it may be necessary to found entirely new environmental organizations that actually adopt an environmentally friendly viewpoint on this very critical issue for the sake of everyone and every form of life on Earth. Some politicians, including many prominent members of the Democratic Party in the US and in many countries in Western Europe, have similar problems.

Three Important Explanations

Some may wonder about the fact that some organic compounds are pollutants and do cause harm to the environment if not adequately controlled, as they largely are in the US. Advocacy of reducing emissions of these pollutants are not covered by my comments even though these efforts can and have been pushed too far here in the US. My comments only relate to advocacy of reducing human-caused emissions of CO2, not other carbon compounds which are genuine man-made pollutants of concern.

A second possible issue is so-called ocean acidification, which some have alleged will occur if atmospheric CO2 levels are not drastically reduced. One of the many problems with this assertion is that marine calcifying organisms survived for hundreds of millions of years when atmospheric CO2 levels were at far higher levels, so this concern can be safely dismissed.

A third important footnote is that if there are indeed significant effects of CO2 emissions on global temperatures (there is considerable dispute on this topic, and it seems much more likely that the primary effect is of temperature changes on CO2 concentrations, not vice versa as the “environmentalists” claim), CO2 emissions may also reduce the effects of future likely new ice ages. This would also be of extreme importance for the future of life on Earth since life cannot easily defend itself against advancing continental glaciers. Defending Earth from a new ice age is much harder than maintaining adequate levels of CO2 in the atmosphere but needs to be addressed as well. The one thing that life on Earth does not need is lower global temperatures, which would only make future ice ages more damaging.

In Summary

The very future of life on Earth, which is itself very rare and possibly even unique in the universe, depends on abandonment of the current prevailing “environmental” orthodoxy on the issue of human CO2 emissions, and those holding opposing views need to be confronted on this issue before they inflict any more of their catastrophically bad anti-environmental views on life on Earth. Their current views are surely environmentalism gone mad—in fact totally mad—since if continued they almost certainly will result in bringing life on Earth to an end when it is truly easy to postpone this fate for many many millions of years by continuing what is also in the best interests of humans and life on Earth as well.

This is truly a win-win situation. Humans need the energy fossil fuels can produce, and plants need the resulting CO2. The long term future of life on Earth literally depends on understanding and acting on this knowledge that plants need far higher levels of atmospheric CO2, not lower.

Ratifying the Paris climate change agreement

Scientific Alliance

At the recent G20 meeting in Hangzhou, Presidents Obama and Xi announced that they would be ratifying the climate deal reached in Paris last December. Superficially, this is a big deal – if the two largest global emitters of carbon dioxide are prepared to sign up to this agreement, others will surely follow – but is it really going to make a difference?

The main reason this is significant is that, for the first time, it potentially brings all countries into a global agreement to reduce emissions. The Kyoto Protocol, the only previous binding commitment, included only industrialised countries and reflected the situation when the agreement was first drawn up, in 1997. However, it only entered into force in 2005, when sufficient signatories had finally ratified it.

The key stumbling block was the lack of ratification from the USA. Despite then-President Clinton’s strong support, ratification was never put to the vote in the Senate, due to overwhelming opposition. This was primarily due to the unwillingness of American legislators to burden their economy with commitments not shared by major emerging economies, in particular China.

Given China’s rapid growth and role as a major manufacturing and exporting nation, this is not surprising. Indeed, China overtook the US to become the world’s largest emitter of CO2 in 2007, just two years after the Kyoto Protocol finally came into force. And the growth has not stopped; by 2014, China was responsible for about double the total emissions of America and close to a third of the global total, albeit still with a significantly lower level of emissions per capita than in the US.

It has been clear during this entire period that the Chinese government would not compromise the country’s growth and development in the name of climate change mitigation, although it has naturally been happy for policy instruments such as the Clean Development Mechanism to be used to transfer international funds for its benefit. Now, though, as the economy is maturing, it suits President Xi to make a gesture that is good for public relations without harming future growth prospects.

So, on the eve of the G20 summit and despite continuing concerns about China’s regional expansionist policies, President Obama committed the US to ratification of the Paris agreement, following President Xi’s announcement of China’s willingness to do so (see, for example, Breakthrough as US and China ratify Paris climate deal). This caused relatively few ripples outside the world of climate change negotiations, and the topic overall merited only a paragraph towards the end of the final G20 summit communique:

“We reiterate our commitment to sustainable development and strong and effective support and actions to address climate change. We commit to complete our respective domestic procedures in order to join the Paris Agreement as soon as our national procedures allow. We welcome those G20 members who joined the Agreement and efforts to enable the Paris Agreement to enter into force by the end of 2016 and look forward to its timely implementation with all its aspects.”

The reason China is now happy to join the party is that it has already done the heavy lifting in terms of development of its primary energy infrastructure. Its annual per capita emissions (7.6 tonnes CO2) now exceed those of the EU (6.7t) (List of countries by carbon dioxide emissions). Having got to this stage, it would be normal to begin taking measures to increase energy efficiency and hence reduce emissions. Over a longer period, the country can also be expected to reduce its dependence on coal, particularly in light of the severe air pollution problems it faces.

So, in essence, China gets brownie points for doing what it would probably be doing in any case. The government plans to reduce energy intensity, have emissions peak by 2030, and have 20% of its energy from non-fossil sources by the same date. In fact, it already has a significant amount of both hydro and nuclear generating capacity and is continuing to build new reactors (and perhaps some in the UK before too long), so these things will tend to happen anyway. It also has a large fleet of wind turbines, but their overall contribution is low in percentage terms, can be accommodated quite easily and will thus also reduce emissions.

The US is in quite a different situation. It is a mature economy with the highest per capita global emissions (with the exception of the Gulf States and Australia). However, it is in the fortunate position of being able to replace coal by domestic shale gas, reducing both energy costs and emissions, so some emissions cuts can be made without suffering any competitive disadvantage.

On the other hand, ratifying the Paris agreement means not only international pressure to meet further targets, but a commitment to work towards ever more stringent policies designed to keep global warming to less than 1.5°C above pre-industrial temperatures. In the feisty world of American politics, it is quite possible to see the Senate refusing to ratify, whether next year sees President Clinton or Trump in the White House. Presidents may make promises, but they cannot always fulfil them.

If we assume that the US does ratify, it would only take the EU (including, for the time being, the UK) to do the same and the thresholds necessary for the agreement to come into force would be passed. But there is a clear impression at the moment that many governments are going along with this agenda in part because of peer-group pressure but without wholehearted enthusiasm to drive the process forward. In the short-termist world of politics, this is not surprising.

But what is more surprising is the ambition of the Paris accord to limit average temperature rise to 1.5° when there is little likelihood of emissions plateauing before 2030 and the 2° cap proposed at the failed Copenhagen summit in 2009 was believed to be increasingly unreachable. Since there is no acceleration apparent in the rate of reduction in emissions growth, this can mean one of two things. Either hope springs eternal that something can be pulled out the hat in the next decade or two, or there is tacit recognition that the climate sensitivity parameter (the increase in temperature from a doubling of carbon dioxide level) is unlikely to be as high as we have been led to believe. If it is the latter, we may be seeing some welcome reasonableness entering the debate.

Renewables cannot guarantee security of supply

Scientific Alliance

For most of us, it’s back to work, with summer receding fast. With autumn and winter just round the corner, our thoughts will turn from keeping cool to keeping warm. Energy prices and security will be priorities once again.

The UK is one of a number of countries apparently set firmly on a path to rely increasingly on renewable energy sources. In practice, this means the focus is firmly on the electricity generating sector, where such a transition can in principle be made with least difficulty. Transport is rather more problematic, although the powers that be retain a touching faith in consumers beginning to buy electric cars in significant numbers. The other major sector – heating – is presently dominated by gas and looks set to continue so for many years to come. In the longer run, electricity again seems to be the energy of choice for this application.

The generating sector thus faces a two-stage problem. In the medium term, the current demand (maybe reduced to some extent by energy efficiency measures) has to be met securely while emissions are considerably reduced (for this is the aim of the entire exercise). If this can be done successfully, then the longer-term challenge is to increase generating capacity very significantly to power road transport and heat domestic and commercial property.

Meeting this bigger challenge would be infeasible if the carbon dioxide emissions associated with the present system cannot be successfully reduced without compromising security of supply, so the stakes are high. Before significant wind and solar energy generating capacity had been installed, the grid was balanced relatively easily by ensuring enough power stations were ready to increase or decrease their contribution at the right time. Since conventional and nuclear sources are dependable – despatchable, in industry jargon – problems would tend to arise only in exceptional circumstances, when demand was very high and a number of breakdowns had occurred.

Most renewable energy is not despatchable, however. Solar farms produce quite predictably, but only during daylight hours and with an output that varies during the day. The output of wind farms is forecastable to a degree, but varies in a wide range over both short and long timescales. So, whatever we hear reported about the contribution of renewables on a given day or over a whole year, this is meaningless when it comes to meeting the essential aim of supplying electricity across the whole country 24 hours a day, seven days a week, 52 weeks a year.

Somewhat surprisingly, National Grid’s new executive director, Nicola Shaw, does not seem to regard this as a problem. According to a BBC report, smart energy revolution ‘could help to avoid UK blackouts’. Ms Shaw, despite her undoubted experience in management (her previous role was as chief executive of HS1) is not an engineer (she has a BA in Modern History and Economics and a Masters in Transport) and will have to rely on advice from experts on such matters, so the optimism apparently runs deep in the organisation.

To be fair, demand management is not seen as the complete answer: “Ms Shaw agreed that more investment in gas-fired power was needed, but argued that between 30% and 50% of fluctuations on the electricity grid could be smoothed by households and businesses adjusting their demand at peak times.” Nevertheless, it has a major role in NG thinking, and yet the efficacy of automatic switching off of domestic appliances is still something of an unknown factor.

In the meantime, we know that peak demand will always come in the early evening period during winter. Even if fridges, washing machines and water heaters are switched off, many people will put the kettle on and cook their evening meal. There is no output from solar panels, and when high pressure areas bring cold, calm conditions, wind output is also minimal. This could result in extended power cuts most winters unless sufficient conventional capacity was available on standby.

Others have also concluded that there may be a degree of complacency to the NG view. For example, the GMB union (which represents power workers), pulls no punches: DSR is ‘fanciful nonsense’ says union. It calls the National Grid ‘naively complacent’ for placing its faith in demand side management. It also slams the use of consumers’ money to compensate companies for interruption of their supply a ‘bonkers policy that only a natural monopoly would dare to implement.’

A more measured but equally damning opinion comes from a new report published by the Scientific Alliance: An examination of National Grid’s Future Energy Scenarios. This study was written by two highly experienced industry professionals – Capell Aris and Colin Gibson – and concludes that current plans will almost certainly lead to severe blackouts. The established supply security criterion, pre-privatization, was for there to be a grid supply failure in no more than four years in a hundred. To meet this standard up to 2025, between six and 16 new gas-fired power stations would have to be built.

Despite this, National Grid and the government seem to be satisfied that there will be no serious problems in the short to medium term. Maybe they have been encouraged by recent winters where, despite warnings of historically low margins of generating capacity, only localised, weather-related blackouts have occurred. But we have enjoyed a series of mild winters and there is no guarantee that we will be so lucky in coming years. Even a single stationary high pressure system could bring a very cold few days and lead to supply failures in an otherwise warm season.

The energy security situation could quickly become the country’s number one priority in such circumstances and cast real doubt on the wisdom of current strategy for the sector. Crisis focusses minds wonderfully, but how much better if the reality of the situation was grasped before the lights go out.