Comments to US EPA on the Proposed Affordable Clean Energy Rule

At a press briefing in mid-August, Bill Wehrum, the appointed head of the US Environmental Protection Agency’s (EPA’s) Air Office, reiterated the Trump administration’s position that ancillary benefits are not to be counted in cost-benefit analysis of major rules, this time in the context of the Affordable Clean Energy (ACE) rule proposed to replace the Obama administration’s Clean Power Plan (CPP). If only the forgone carbon dioxide (CO2) benefits of pulling back on the CPP are counted, the cost savings from ACE outweigh these forgone benefits. But adding the ancillary health benefits that are lost with the ACE rule—the value of 1,400 fine particulate matter (PM2. 5)-associated deaths related to greater coal use under the ACE rule—turns ACE into an economic loser, with net social costs relative to the CPP. At the briefing, Wehrum said:“We’re not dealing with [sulfur dioxide] SO2. We’re not dealing with [nitrogen oxides] NOX. We’re not dealing with particulate matter.… We have abundant legal authority to deal with those other pollutants directly, and we have very aggressive programs in place that directly target emissions of those pollutants. So our view is, if we want to regulate PM, we regulate PM straight up. If we want to regulate SO2, we regulate SO2 straight up.”