New Carbon Dioxide Emissions Limits Cost Nothing and Offer No Benefits, Says EPA

CO2Griffin024Today the Environmental Protection Agency
issued proposed new regulations limiting the emissions of
carbondioxide from new electric power generation plants. The EPA

press release
states:

Under today’s proposal, new large natural gas-fired turbines
would need to meet a limit of 1,000 pounds of CO2 per
megawatt-hour, while new small natural gas-fired turbines would
need to meet a limit of 1,100 pounds of CO2 per megawatt-hour. New
coal-fired units would need to meet a limit of 1,100 pounds of CO2
per megawatt-hour, and would have the option to meet a somewhat
tighter limit if they choose to average emissions over multiple
years, giving those units additional operational flexibility.

Since current coal-fired electric generation plants emit about
1,800 pounds of CO2 per megawatt-hour, the new regulations would
essentially outlaw the construction of new conventional coal-fired
plants. Not to worry, says the agency in its
regulatory impact statement
:

Under a wide range of electricity market conditions – including
EPA’s baseline scenario as well as multiple sensitivity analyses –
EPA projects that the industry will choose to construct new units
that already meet these standards, regardless of this proposal. As
a result, EPA anticipates that the proposed EGU New Source GHG
Standards will result in negligible CO2 emission changes, energy
impacts, benefits or costs for new units constructed by 2020.
Likewise, the Agency does not anticipate any notable impacts on the
price of electricity or energy supplies…

These proposed EGU New Source GHG Standards is not anticipated
to change GHG emissions for newly constructed electric generating
units, and is anticipated to impose negligible costs or monetized
benefits. EPA typically presents the economic impacts to secondary
markets (e.g., changes in industrial markets resulting from changes
in electricity prices) and impacts to employment or labor markets
associated with proposed rules based on the estimated compliance
costs and other energy impacts, which serve as an input to such
analyses. However, since the EPA does not forecast a change in
behavior relative to the baseline in response to this proposed
rule, there are no notable macroeconomic or employment impacts
expected as a result of this proposed rule.

Surely if there are no costs, then there must be some benefits
accruing to the public from the new rules, right? Well, no. As the
agency impact statement notes:

…the proposed rule is anticipated to yield no monetized
benefits and impose negligible costs over the analysis period.

That’s right – no costs and no benefits. Just new
regulations.