*JimH* wrote:
Where did GWB say he does not believe in global warming theories?

I said "BushCo".

Bush's Flawed Arguments Against Regulating Carbon Pollution
Backing off his pledge to cut global warming pollution, President Bush
cited a flawed study and got the law wrong.


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On March 13, 2001, President Bush backed away from his campaign pledge
to seek cuts in emissions of carbon dioxide -- the main cause of global
warming -- as part of a strategy to regulate together, rather than
separately, four air pollutants emitted by power plants. In a letter to
Sen. Chuck Hagel (R-Neb.) explaining his reversal, the president cited
a recent Department of Energy report that concluded it would be too
costly to regulate CO2; he also claimed that CO2 is not considered a
pollutant under the Clean Air Act. Below, David Hawkins, director of
NRDC's air and energy program, and Dan Lashof, director of our global
warming project, let the air out of these arguments.
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Carbon Dioxide Is a Pollutant
The McIntosh-EIA Report: a Flawed Study


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1. CARBON DIOXIDE IS A POLLUTANT

In his letter to Senator Hagel, President Bush wrote that carbon
dioxide is not considered a pollutant under the Clean Air Act. This, of
course, is just a hair-splitting interpretation of current law, one
that provides no logical basis for the president to drop his promise to
seek a new law to control CO2. But it is worth noting that the
president is also wrong in his legal claim. CO2 is a pollutant under
the Clean Air Act, as well as in the real world.




How does the Clean Air Act define "air pollutant"?

The act says that an air pollutant is any "physical, chemical,
biological, [or] radioactive . . . substance or matter which is emitted
into or otherwise enters the ambient air." (CAA, sec. 302(g)) CO2 is
certainly a chemical substance and it is emitted into the ambient air
when fossil fuel is burned in vehicles and power plants.




Is there anything in the act that suggests Congress considered CO2 an
air pollutant?

Yes. In section 103(g) of the act, Congress explicitly included
emissions of CO2 from fossil fuel power plants in a list of air
pollutants that it directed the Environmental Protection Agency to
include in pollution prevention programs. Section 103(g) of the act
calls for "[i]mprovements in nonregulatory strategies and technologies
for preventing or reducing multiple air pollutants, including sulfur
oxides, nitrogen oxides, heavy metals, PM-10 (particulate matter),
carbon monoxide, and carbon dioxide, from stationary sources, including
fossil fuel power plants." (Emphasis added)

It is correct that this section by itself does not allow or require EPA
to regulate any of the listed pollutants, including CO2. Those
authorities exist in other sections of the act and EPA has used those
authorities to regulate other pollutants listed in Section 103. The
fact that EPA has not regulated CO2 to date does not transform CO2 into
a "nonpollutant." In the early 1970s, EPA had not acted to control lead
pollution, but it was clearly a pollutant because of its potential
adverse effects on health and the environment. EPA did subsequently
establish regulations for lead.




Isn't CO2 a "natural" part of the atmosphere?

Yes, but a pollutant is a substance that causes harm when present in
excessive amounts. CO2 has been in the atmosphere since life on earth
began, and in the right amounts CO2 is important for making the earth
hospitable for continued life. But when too much CO2 is put into the
atmosphere, its becomes harmful. We have long recognized this fact for
other pollutants. For example, phosphorus is a valuable fertilizer, but
in excess, it can kill lakes and streams by clogging them with a
blanket of algae.

In the case of CO2, fossil fuels have stored carbon for hundreds of
millions of years. Over the last 150 years, by burning fossil fuels,
humans have released that carbon into the atmosphere in a geologic
instant of time. We now are burning billions of tons of fossil fuels
every year. This has caused CO2 to build up in the atmosphere much as
an excessively rich diet causes life-threatening deposits to build up
in human arteries. Scientists agree that if today's fossil-fuel burning
trend continues we will build up concentrations of CO2 in the
atmosphere at ever-increasing rates. This build-up of CO2 threatens our
health and environment, just as excessive cholesterol threatens our
bodies. Scientists expect accelerating global warming to trigger severe
droughts, floods and storms; destroy coral reefs and habitats; and
increase the incidence of certain diseases.




What can we do to reduce carbon dioxide pollution?

Electric power plants emit 40 percent of U.S. carbon pollution, and
unless they change their current practices their emissions will
increase dramatically. Fortunately, there are simple, affordable
measures that can put us on a path to reducing carbon pollution from
our electric generators:


Retiring and repowering inefficient, outmoded power plants can
simultaneously cut emissions of carbon dioxide, sulfur oxides, nitrogen
oxides and mercury.
Reasonable steps to make our homes and businesses more energy efficient
will further cut carbon dioxide and other pollutants from electricity
generators.
Increasing our reliance on renewable fuels (such as those grown on
American farms) and natural gas is one more method to cut carbon and
other pollution.

Motor vehicles are the second biggest source of carbon pollution. We
have the know-how to build cars and sport utility vehicles that pollute
less and do less damage to our wallets. We do not need technical
breakthroughs, because the technology is available today. What we need
is political leadership.


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2. THE MCINTOSH-EIA REPORT: A FLAWED STUDY

In his letter to Senator Hagel, President Bush cited a Department of
Energy report that concluded it would be too costly to regulate carbon
dioxide. That report is seriously flawed and contradicts a number of
authoritative reports that reached the opposite conclusion.




What report did President Bush refer to?

The so-called Department of Energy report is actually a report by the
Energy Information Administration (EIA), a statistical agency housed
within DOE. The report was prepared at the request of then-Rep. David
McIntosh (R-Ind.), one of Congress' most active opponents of mandatory
reductions in carbon dioxide emissions and the Kyoto Protocol. In
preparing the report for McIntosh, EIA ignored the findings of the
DOE's much more thorough report, "Scenarios for a Clean Energy Future,"
as well as input from independent reviewers and analysts at the
Environmental Protection Agency and Resources for the Future.




Is the McIntosh-EIA report consistent with other analyses?

No. The McIntosh-EIA report is contradicted by four other recent
studies that conclude major multi-pollutant reductions can be achieved
at modest costs. There are five recent studies of the costs of
multi-pollutant programs for the electric sector. Four of them conclude
that the costs will be moderate; only the McIntosh-EIA report assumes
the costs will be high. Other studies published in the last six months
by EPA, Harvard University, Environmental Law Institute-Resources for
the Future, and the DOE, all conclude that multi-pollutant program
costs would be quite reasonable. (See U.S. EPA, "Technical Assistance
on H.R. 2569, the Fair Energy Competition Act of 1999," January 2001;
"Coal or Gas: The Cost of Cleaner Power in the Midwest," H. Lee and
S.K. Verma, Harvard University, John F. Kennedy School of Government,
August 2000; "Cleaner Power," Environmental Law Institute, November,
2000; U.S. DOE, "Scenarios for a Clean Energy Future," November 2000.)




What are the major substantive flaws in the McIntosh-EIA report?


The McIntosh-EIA report overstates total program costs by ignoring
gains from energy efficiency. The report analyzes an assumed future
where virtually no added effort is made to use electricity and natural
gas more efficiently. Because the computer modeling assumptions made by
EIA assume that unconstrained growth in electric generation will be
very high, the model must apply very large charges to achieve the
required pollution reductions. In November 2000, DOE published a
comprehensive study showing that sound efficiency policies could
achieve large multi-pollutant reductions from electric generators at a
net savings to the consumer. (See "Scenarios for a Clean Energy
Future," U.S. DOE, November 2000.)


The McIntosh-EIA report overstates costs by analyzing a program that is
not being considered. The McIntosh-EIA model does not analyze a genuine
multipollutant cap and trade program. Instead, it assumes the
equivalent of a carbon tax on top of emission controls for sulfur
dioxide and nitrogen oxides. The EIA model does not account for
recycling the carbon tax revenues in a realistic manner. The result is
that the EIA model allows all electricity generators to charge
consumers based on the highest costs experienced by the most expensive
generating unit in the country, even though the average costs for
generators would be far less than the costs to control the most
expensive unit. This assumption greatly inflates the calculated "costs"
of the program. In fact, these estimates are not costs at all but are
tax revenues or windfall profits that would be received by electricity
generators if Congress were to allow such an approach. Since no bills
have proposed the approach used by EIA, its report amounts to an
analysis of an imaginary policy that conflicts with approaches actually
being considered by Congress.


The McIntosh-EIA report overstates program costs by assuming an
artificial future with no additional controls under current law. The
EIA report calculates costs by comparing estimates for controlling
pollution in new legislation to a hypothetical future where no
additional control requirements occur under current law. This is a
completely unrealistic assumption that ignores the facts of current
policy. EPA's promulgated air quality standards for smog and soot
(ozone and fine particles), recently upheld by the Supreme Court, will
require large additional reductions in sulfur dioxide and nitrogen
oxides, yet EIA ignores these requirements. EPA is under a court order
to adopt controls on mercury from coal-fired power plants, but EIA
ignores this requirement. The United States has committed under the
Senate-ratified Rio Climate Treaty to adopt programs aimed at returning
U.S. carbon dioxide emissions to 1990 levels, but EIA ignores this
commitment. EIA assumes that no additional controls will occur under
current law over the next 20 years beyond requirements in current
regulations. This results in an unrealistically low-cost "reference
case" assumption, which causes EIA's estimates of multipollutant
policies to be grossly overstated.


The McIntosh-EIA report overstates costs of reducing CO2 by failing to
analyze mercury controls. The EIA report does not include any controls
on mercury, even though all multipollutant bills require such controls.
Mercury control requirements, when combined with controls on other
pollutants, will promote replacing old, inefficient plants with modern,
high-efficiency gas-fired plants. These new plants would reduce all
four pollutants significantly, including carbon dioxide. Yet, by
ignoring mercury controls, the McIntosh-EIA report assigns all of the
costs of switching to a new fuel source to carbon dioxide only, thus
making CO2 costs appear higher than they are.