We Helped Write the Clean Power Plan, and Trump's Do-Nothing Replacement Is an Outrage | Opinion

We were part of the senior team at the Environmental Protection Agency (EPA) during the Obama administration, when the agency's mission truly was to protect the health of American families from dangerous pollution and act on perhaps the greatest challenge of our time: climate change.

Our work was built on laws passed by Congress, like the Clean Air Act, which created the tools we needed to carry out the mission; the tireless work of legions of our gifted and dedicated EPA career colleagues; and a president who was as committed to the mission as we were.

To us, success was the Clean Power Plan (CPP), a rule we and our colleagues wrote and President Barack Obama announced in August 2015. The CPP established the first-ever federal regulations to limit carbon dioxide—one of the chief pollutants causing climate change—from power plants. It's the same rule the Trump EPA repealed last week when it announced the Affordable Clean Energy (ACE) rule.

Had the CPP gone into effect, the EPA's 2015 analysis showed that by 2030 power plant CO2 emissions would have fallen by 32 percent below 2005 levels and the pollutants that cause life-threatening smog and soot would have been reduced significantly. The CPP pollution cuts would have saved thousands of lives and prevented tens of thousands of pollution-related illnesses.

In sharp contrast, the Trump administration's ACE will achieve virtually no reductions in CO2 emissions and next to no cuts in soot and smog pollution. It will prevent next to none of the premature deaths, cardiac problems, lung damage or asthma attacks suffered by the most vulnerable among us—our kids, seniors and poor families—that the CPP would have prevented.

The CPP was set to achieve these benefits because we looked at the entire energy system across the U.S. and embraced the Clean Air Act's directive to identify the "best system of emission reduction" when setting pollution standards. Because power plants operate as part of an interconnected grid, the best way to cut emissions is to shift electricity generation from the dirtiest plants, which happen to use coal, to lower-emitting sources such as natural gas, renewables or nuclear power.

Our approach took advantage of market forces and state and local policies that were already driving down CO2 emissions by an estimated 12 to 15 percent below 2005 levels by 2030, locked in those reductions and then went far beyond to set pollution standards that doubled the amount of reductions electric utilities were already planning.

Gina McCarthy CPP
Gina McCarthy, as U.S. Environmental Protection Agency administrator, signs new regulations for power plants on June 2, 2014, in Washington, D.C. Chip Somodevilla/Getty

But when the Trump EPA released its do-nothing rule, it disregarded the Clean Air Act and instead required the worst system of emission reduction. The agency relied on an extraordinarily narrow interpretation of the law to tie its own hands, limiting its authority to do anything more than require utilities to consider a small list of minimal technology fixes at power plants—and in some situations allow plants to forego reductions altogether.

Should states require plant operators to invest in minimal technology fixes, more efficient plants could be called upon to run longer each day and operate over an extended lifetime, emitting cumulatively more CO2. Worse still, when the agency makes good on its promise to relax a separate set of pollution control requirements that have operated under Clean Air Act rules for decades, the ACE could very well increase not only CO2 emissions but also conventional air pollutants that contribute to the smog and soot that pose direct threats to our health and wellbeing.

Making matters worse still, events in the four years since the CPP was finalized only highlight the gross dereliction of the do-nothing approach of the Trump administration:

First, wildfires that leave entire towns homeless and increase breathing issues in downwind cities, storms with extraordinary destructive capacity, floods that wreck people's homes and disrupt crops across the Midwest have become increasingly commonplace. They give us a taste of the multiple threats posed by runaway climate change and underscore the urgency of vigorous EPA action to reduce CO2 emissions well beyond the Trump plan.

Second, since 2015, the transition to clean energy has picked up speed, and it will likely continue to accelerate in the next 10 years.

The EPA could have and should have updated the CPP both to lock in the pollution reductions of this clean energy transition and take advantage of every reasonable, cost-effective opportunity to deepen and accelerate CO2 reductions on a pace that reflects the sense of urgency that climate science now dictates.

In contrast, the Trump EPA turned the ACE into an opportunity to confirm its determination to do nothing to reduce the pollution that is causing dangerous climate change, while boosting the coal industry and shielding it from regulation.

The real purpose of the rule, it appears, is to cement severe limits on the EPA's authority to ever require meaningful CO2 reductions from power plants, which will keep us on a path toward devastating climate and health consequences.

Even if the Trump EPA believes that the specific approach of the CPP was illegal, it could still have required substantial reductions beyond the barely 1 percent reduction in CO2 it claims for the ACE. For example, adding natural gas to coal at power plants where that can be done effectively, while encouraging states to use flexible compliance options to augment the rule's requirements, would yield additional emissions reductions.

The Trump administration hasn't just embraced new policy positions, as most new administrations do. It has chosen to unravel, defang or delay 84 rules finalized during the Obama administration. It is dismantling the EPA's core science, regulation and enforcement functions.

coal plant ohio
The stacks from the Gavin coal burning power plant tower over the landscape on February 4, 2012, in Cheshire, Ohio. Benjamin Lowy/Getty

Now, the administration's words and deeds demonstrate its callous disregard for the EPA's mission to protect public health and our precious natural resources in favor of its singular quest to save polluters money even at the expense of our children's future. And in the meantime, we are running out of time to meet our moral obligation to prevent the most harmful impacts of climate change.

The three of us will continue to work with those who are fighting the climate crisis. Policy makers in many states, corporate boards and even some private investors are re-doubling their efforts to promote clean, low-carbon energy and respond to the Trump administration's actions. By doing so, they are already laying the groundwork for future national policies committed to sensible actions to stem this climate crisis.

Gina McCarthy is the current director of the Center for Climate, Health and the Global Environment at the Harvard T.H. Chan School of Public Health and was administrator of the U.S. EPA from 2013 to 2017.

Janet McCabe is professor of practice at the Indiana University McKinney School of Law and was acting assistant administrator for the EPA's Office of Air and Radiation between 2013 and 2017.

Joseph Goffman is the executive director of the Environmental and Energy Law Program at Harvard Law School and was associate assistant administrator and senior counsel in the EPA's Office of Air and Radiation between 2009 and 2017.

The views expressed in this article are the writers' own.

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