SyracuseCoE Faculty Fellows News
What: SyracuseCoE Faculty Fellows Researcher Charles Driscoll joined researchers from the Harvard T.H. Chan School of Public Health and Boston University School of Public Health, and Resources for the Future evaluated the cost-benefit analysis for the U.S EPA’s Affordable Clean Energy (ACE) rule, known as a Regulatory Impact Analysis (RIA), to determine whether it incorporates the best available information and the conclusions are fully supported. The results are summarized in their working paper, Carbon Standards Re-Examined: An Analysis of Potential Emissions Outcomes for the Affordable Clean Energy Rule and the Clean Power Plan.
Context: On June 19, 2019, the EPA repealed the Obama-era Clean Power Plan (CPP) and finalized the ACE rule. The intent of the ACE rule is to establish the Best System of Emission Reduction for carbon pollution from coal-fired power plants, a requirement under the Clean Air Act. The research team evaluated the RIA by undertaking new energy modeling and conducting side-by-side comparisons of EPA’s findings and assumptions with those of other scenarios.
Key Take-Away: The results from this analysis call into question the assumptions and conclusions in EPA’s cost-benefit analysis. They demonstrate that the ACE rule does little to address climate change and is likely to have even greater adverse air quality and health effects in some states compared to no policy than EPA has projected.
Why It Matters
For the rule – By underestimating the magnitude of emissions rebound in the RIA, EPA may have overestimated the net economic benefits of the ACE rule, calling into question whether its benefits truly outweigh its costs. The effect of underestimating emissions rebound on the benefits calculation for the ACE rule depends on how large the actual emissions rebound is likely to be and where it would occur.
For health – Underestimating emissions rebound means that the ACE rule may result in more cases of respiratory illness, heart attacks, worsening asthma, and premature death in some states from exposure to higher fine particulate matter and ozone than EPA has estimated.
For states – In some states, the emissions rebound expected from the ACE rule would shift the burden of curbing CO2 emissions to the states and could undercut their ability to meet their greenhouse gas reduction goals. Emissions rebound may also impact the ability of some states to meet and maintain federal air quality standards.
For the nation – Carbon dioxide (CO2) emissions in the U.S. increased approximately 3.5% in 2018. Our analysis suggests that ACE could drive emissions higher still, making it even more challenging for the U.S. to meet its previous commitments under the Paris climate agreement and to achieve emissions reductions needed by 2030 to avoid the worst impacts of climate change.
Professor Charles Driscoll, University Professor of Environmental Systems and Distinguished Professor, College of Engineering & Computer Science, Syracuse University is a SyracuseCoE Faculty Fellow. His research focus areas are:
- Aquatic chemistry
- Climate change science and engineering
- Environmental quality modeling
- Ecosystem restoration
- Ecosystem science
- Stormwater management
- Soil chemistry
See a list of Professor Driscoll’s published research.