The Francis Coppola film “Apocalypse Now” paints a surreal portrait of government institutions and military leaders whose methods and objectives have strayed far from their original design. During one of the film’s intense and understated moments, a CIA operative receives instructions to kill an out-of-control Army colonel. “Terminate,” comes the cold and sanitized order, “with extreme prejudice.” Today’s EPA may be a far cry from Vietnam-era spies, but with its new regulation for coal-fired electric plants it has given that chilling line new meaning.
Unlike the wayward Colonel Kurtz, there’s nothing out of control about these power facilities. America’s coal plants are cleaner than ever, and produce almost 40 percent of our electricity. Nearly six months ago, I wrote in this space that the administration’s proposed regulations could mean that there would never be another coal-fired electricity plant built in the United States. When the EPA stepped forward earlier this month with the final rule, it made that prediction into reality.
It’s a policy change with significant cost implications for ratepayers, given that most every alternative remains more expensive than coal — as much as three times more for some renewable projects like Cape Wind. Like any new regulation, these costs might be justified if the benefits are significant and measurable. Unfortunately, they are not.
The EPA’s justification for the dramatic regulatory incursion begins with its definition of carbon dioxide as a “pollutant,” notwithstanding the fact that it occurs naturally in the atmosphere and sustains plant life on earth. The basis for the agency’s claim, of course, is that CO2 contributes to greenhouse warming, which the United Nation’s climate report predicts will be about 1 degree Celsius over the next 50 years.
But even if we take this prediction at face value, the fact remains that coal plants generate less than 40 percent of America’s CO2 emissions, which are less than 20 percent of the global total. Imposing the rule on new plants would reduce global emissions and projected temperature increases by imperceptible and meaningless amounts. UN projections aside, current trends tell a different story: CO2 emissions in the United States have actually declined by 12 percent since 2007, while average global temperatures have been flat since 1998.
So what exactly is the EPA trying to accomplish? It is trying to close every coal plant in America.
Admittedly that’s a harsh assertion, but it is borne out by the rule itself. To appreciate its vindictiveness, consider the following: EPA’s permissible limit of 1,100 pounds of CO2 per megawatt hour of electricity produced isn’t based upon the performance of the best and most modern plants in the country today — which one could argue would be rational. Instead, it’s a full 700 pounds less. That’s correct. No commercial plant currently operating, no matter how advanced, can meet this arbitrary new limit. The rule simply represents the standard that regulators wish that plants could somehow achieve.
Allowing regulators to establish policy based on hopes and dreams sets a dangerous precedent.
When industry analysts and media observers discuss the implementation of the new rule, they inevitably refer to the “carbon capture technology” required for compliance. Yet this technology isn’t just prohibitively expensive — it doesn’t exist today. In its press announcement, the EPA cited two experimental plants as models for its grand carbon capture vision. Neither has even begun construction.
Clearly, we should set fair standards for pollution; but allowing regulators to establish policy based on hopes and dreams sets a dangerous precedent. No Congress authorized the EPA to regulate CO2, and no legislation authorized the termination of the coal industry — with or without “extreme prejudice.” But that’s exactly what the EPA has chosen to do.
The White House bristles at the term “regulatory uncertainty,” and scoffs at the idea that America’s economic growth remains hobbled by this type of bureaucratic behavior. But business owners and managers across the country see one thing: an industry targeted for elimination, not by an act of Congress, but by a bureaucracy that simply dislikes them. Today the target may be new coal plants. The EPA has already announced the next target will be existing plants. Who can say where the path leads? Refineries, steel plants, and gas terminals could all be shut down by the same callous approach.
Anyone who doesn’t understand how such an arbitrary and aggressive use of power would discourage investment has never worked in the private sector. Unfortunately, that description fits most everyone involved in this decision, from the West Wing to the EPA. And just like Martin Sheen’s character in “Apocalypse,” they don’t seem to care about the collateral damage — they just want to take down the target and go home.John E. Sununu, a former Republican senator from New Hampshire, writes regularly for the Globe.