The Papal Encyclical and Climate Change Policy

On June 18, 2015, Coral Davenport, writing in the New York Times, was the first in the press to note that the encyclical on the environment, Laudato Si’, released by Pope Francis that same day, with tremendous praise from diverse quarters, “is as much an indictment of the global economic order as it is an argument for the world to confront climate change.”

The New York Times and a Couple of Asia Trips

The Times article included the following: “…environmental economists criticized the encyclical’s condemnation of carbon trading, seeing it as part of a radical critique of market economies. ‘I respect what the pope says about the need for action, but this is out of step with the thinking and the work of informed policy analysts around the world, who recognize that we can do more, faster, and better with the use of market-based policy instruments — carbon taxes and/or cap-and-trade systems,’ Robert N. Stavins, the director of the environmental economics program at Harvard, said in an email. The approach by the pope, an Argentine who is the first pontiff from the developing world, is similar to that of a ‘small set of socialist Latin American countries that are opposed to the world economic order, fearful of free markets, and have been utterly dismissive and uncooperative in the international climate negotiations, Dr. Stavins said.”

Those are accurate quotes from an email I sent to Coral Davenport in response to her inquiry the same day. The reason why I sent an email, rather than calling was that I was, at that moment, approximately 37,000 feet over the Pacific Ocean, flying from Seoul (where I had spoken at the third annual Future Energy Forum) to San Francisco, on my way home to Boston.

The following week, I was flying back to Asia (this time to Beijing for a workshop jointly sponsored by the Harvard Project on Climate Agreements and China’s National Development and Reform Commission – a topic for a future blog post, but not for today). As I sat in the departure lounge at Chicago’s O’Hare International, I began to see on my iPhone a small flood of hostile commentary from the blogosphere, indicating that I had unfairly “attacked the Pope.”

Well, writing an email rather than chatting on the phone with a reporter may eliminate some spontaneity, but it does have the advantage of preserving a record. So, I’m pleased to be able to share with readers today the views I offered on June 18th, long before the Pope’s recent visit to Cuba and the United States. My views have not changed.

Why Write About This Now?

That’s a reasonable question. In part, I’m inspired by a marvelous essay by Yale professor William Nordhaus, “The Pope & the Market,” which appears in the October 8, 2015 issue of The New York Review of Books. However, my thoughts are completely independent from his, and so he should not be indicted for anything I have to say. But I do heartily recommend his essay, and urge readers to take a look at his commentary (as well as mine).

With that preamble out of the way, here are the reactions of one environmental economist, yours truly, to Laudato Si’, nearly verbatim from my June 18th message from 37,000 feet over the Pacific Ocean, with some additional text and links for this blog essay.

An Environmental Economist Reflects on the Papal Encyclical

The Pope is to be commended for taking global climate change seriously, and for drawing more world attention to the issue. There is much about the encyclical that is commendable, but where it drifts into matters of public policy, I fear that it is – unfortunately – not helpful.

The long encyclical ignores the causes of global climate change: it is an externality, an unintended negative consequence of otherwise meritorious activity by producers producing the goods and services people want, and consumers using those goods and services. That’s why the problem exists in the first place. There may well be ethical dimensions of the problem, but it is much more than a simple consequence of some immoral actions by corrupt capitalists.

The document also ignores the global commons nature of the problem, which is why international cooperation is necessary. If the causes of the problem are not recognized, it is very difficult – or impossible – to come up with truly meaningful and feasible policy solutions.

So, yes, the problem is indeed caused by a failure of markets, as the Pope might say, or – in the language of economics – a “market failure”. But that is precisely why sound economic analysis of the problem is important and can be very helpful. Such analysis points the way to working through the market for solutions, rather than condemning global capitalism per se.

Should Carbon Markets be Condemned?

In surprisingly specific and unambiguous language, the encyclical rejects outright “carbon credits” as part of a solution to the problem. It says they “could give rise to a new form of speculation and would not help to reduce the overall emission of polluting gases”. The encyclical asserts that such an approach would help “support the super-consumption of certain countries and sectors”.

That misleading and fundamentally misguided rhetoric is straight out of the playbook of the ALBA countries, the small set of socialist Latin American countries that are opposed to the world economic order, fearful of free markets, and have been utterly dismissive and uncooperative in the international climate negotiations. Those countries have been strongly opposed to any market-based approaches to climate change, including carbon taxes, cap-and-trade, and offset systems, as well as any approaches that would allow – through appropriate linkage – the financing by one country of emissions reductions in another country (see my previous essay at this blog on A Key Element for the Forthcoming Paris Climate Agreement).

If the references to “carbon credits” were intended to refer only to offset systems (such as the Clean Development Mechanism) and not to cap-and-trade systems, then I would be much less concerned about the Pope’s complaints. However, the encyclical does not make the distinction. Indeed, I doubt that the authors of the encyclical recognize the difference, and unfortunately, readers of the encyclical will likewise lump together all carbon markets, which is what some policy makers also do, unfortunately.

Out of Step

I respect what the Pope says about the need for action, but his unfortunate attack on the use of the market to address climate change is out of step with the thinking and the work of informed policy analysts and policy makers around the world, who recognize that we can do more, faster, and better with the use of market-based policy instruments – carbon taxes and/or cap-and-trade systems. UN Secretary General Ban Ki-moon has been outspoken in precisely this regard.

Furthermore, the United Nations Framework Convention on Climate Change itself (Article 3.3) explicitly states that “policies and measures to deal with climate change should be cost-effective so as to ensure global benefits at the lowest possible cost” and thereby be more ambitious. That is why market-based climate policy instruments are an important option for many countries. Keeping costs down will help inspire greater action.

Concluding Thoughts

The Papacy is to be commended for having drawn attention to climate change as a major issue. But, sadly, the encyclical fails to recognize that because externalities (such as CO2 emissions) are a type of market failure and because the global commons nature of the problem and consequent free riding are also a profound market failure, it is for these reasons that working through the market is absolutely necessary – in order to address the climate problem in ways that are scientifically meaningful, economically sensible, and ultimately politically pragmatic.

By incorporating the anti-market rhetoric of the ALBA countries, the encyclical unfortunately goes beyond these errors of omission to incorporate significant errors of commission by emphasizing a perspective that is not progressive and enlightened, and would – I fear – ultimately work against meaningful climate policy at the international, regional, national, and sub-national levels.

That is why I said that although there is much about the encyclical that is commendable, where it drifts into matters of public policy it is – unfortunately – not helpful.


What to Expect at COP-20 in Lima

On Monday, December 1st, the Twentieth Conference of the Parties (COP-20) of the United Nations Framework Convention on Climate Change (UNFCCC) commences in Lima, Peru. Over the next two weeks, delegations from 195 countries will discuss and debate the next major international climate agreement, which – under the auspices of the Durban Platform for Enhanced Action – is to be finalized and signed one year from now at COP-21 in Paris, France.

What to Expect in Lima

Because of the promise made in the Durban Platform to include all parties (countries) under a common legal framework, this is a significant departure from the past two decades of international climate policy, which – since the 1995 Berlin Mandate and the 1997 Kyoto Protocol – have featured coverage of only a small subset of countries, namely the so-called Annex I countries (more or less the industrialized nations, as of twenty years ago).

The expanded geographic scope of the incipient Paris agreement – combined with its emerging architecture in the form of a pragmatic hybrid of bottom-up nationally determined contributions (NDCs) plus top-down elements for monitoring, reporting, verification, and comparison of contributions – represents the greatest promise in many years of a future international climate agreement that is truly meaningful.

A Diplomatic Breakthrough:  The Key Role of the China-USA Announcement

If that confluence of policy developments offers the promise, then it is fair to say that the recent joint announcement of national targets by China and the United States (under the future Paris agreement) represents the beginning of the realization of that promise. From the 14% of global CO2 emissions covered by nations participating (a subset of the Annex I countries) in the Kyoto Protocol’s current commitment period, the future Paris agreement with the announced China and USA NDCs covers more than 40% of global CO2 emissions. With Europe, already on board, the total amounts to more than 50% of emissions.

It will not be long before the other industrialized countries announce their own contributions – some quite possibly in Lima over the next two weeks. More importantly, the pressure is now on the other large, emerging economies – India, Brazil, Korea, South Africa, Mexico, and Indonesia – to step up. Some (Brazil, Korea, Mexico?) may well announce their contributions in Lima, but all countries are due to announce their NDCs by the end of the first quarter of 2015.

The announced China-USA quantitative contributions are themselves significant. For China, capping its emissions by 2030 (at the latest) plus increasing its non-fossil energy generation to 20% by the same year will require very aggressive measures, according to a recent MIT analysis. For the USA, cutting its emissions by 26-28% below the 2005 level by 2025 means doubling the pace of cuts under the country’s previous international commitment.

Thus, the China-USA announcement begins the fulfillment of the promise of the Durban Platform. A sufficient foundation is being established for meaningful future steps, and thereby the likelihood of a successful outcome in Paris has been greatly increased.  The talks in Lima over the next two weeks will produce at least a rough draft of the the Paris agreement, which can then be elaborated and finalized over the coming year, and signed (with abundant photo opportunities for heads of state) in Paris in December, 2015.

Keeping Our Eyes on the Prize

There will be — indeed, already have been — pronouncements of failure of the Lima/Paris talks from some green groups, primarily because the talks will not lead to an immediate decrease in emissions and will not prevent atmospheric temperatures from rising by more than 2 degrees Celsius (3.6 degrees Fahrenheit), which has become an accepted, but essentially unachievable political goal. These well-intentioned advocates mistakenly focus on the short-term change in emissions among participating countries (for example, the much-heralded 5.2% cut by the Annex I countries in the Kyoto Protocol’s first commitment period), when it is the long-term change in global emissions that matters.

In other words, they ignore the geographic scope of participation, and do not recognize that — given the stock nature of the problem — what is most important is long-term action.  Each agreement is no more than one step to be followed by others.  And most important now for ultimate success later is a sound foundation, which is precisely what may finally be provided by the China-USA announced contributions under the Durban Platform structure of a hybrid international policy architecture.

All in all, this may turn out to be among the most important moments in two decades of international climate negotiations. And this means – at a minimum – that the next two weeks in Lima should be very interesting indeed.

Upcoming Events at COP-20 in Lima

As with previous Conferences of the Parties, we – the Harvard Environmental Economics Program and the Harvard Project on Climate Agreements (HPCA) – will be at the Lima talks for their second week, December 7-12. We will be participating in a number of events, and will be holding bilateral meetings with key national delegations.

In all cases, our contributions to the discussions will draw on our compendium of knowledge from our 70 research initiatives in Argentina, Australia, China, Europe, India, Japan, and the United States. Our purpose continues to be to help identify and advance scientifically sound, economically sensible, and politically pragmatic policy options for addressing global climate change.

For those of you who will be in Lima (as well as the rest of you), here is the schedule of COP-20 events that are co-sponsored by HPCA or in which I am participating as HPCA Director. It is going to be a very busy week, but I will try to blog – or at least tweet – about these events and other developments. After I return from Lima, I will follow up with an assessment.


Monday, December 8, 4:45 – 6:15 pm, Room: Machu Picchu

Sponsors: Harvard Project on Climate Agreements, Centre for European Economic Research (ZEW), and Enel Foundation

“Implications of the energy-efficiency gap for reducing greenhouse-gas emissions”

The discussion will be based on our Duke-Harvard research project (sponsored by the Alfred P. Sloan Foundation) on the “energy-efficiency gap”—the apparent difference between predicted and measured rates of adoption of energy-efficiency technology. Panelists will explore the implications of this gap for climate-change mitigation.


Daniele Agostini, Head of Low Carbon Policies and Carbon Regulation, Enel Group

Andreas Löschel, Chair of Microeconomics, and Energy and Resource Economics, University of Münster, and Research Associate, ZEW

Richard Newell, Gendell Professor of Energy and Environmental Economics, Nicholas School of the Environment, Duke University, and Director, Duke University Energy Initiative

Robert Stavins, Director, Harvard Project on Climate Agreements and Albert Pratt Professor of Business and Government, Harvard Kennedy School

Jesus Tamayo Pacheco, President of the Supervisory Body for investment in energy and mines of Peru

See also background paper


Tuesday, December 9, 12:00 – 2:00 pm, China Pavilion

Sponsors: National Center for Climate Change Strategy and International Cooperation (NCSC), National Development and Reform Commission (NDRC), People’s Republic of China

“International Cooperation: Towards the 2015 Agreement –A perspective from international think tanks”

This event aims at exchanging ideas from various international think tanks on the design of the 2015 Agreement with consideration of interaction and cooperation of parties on bilateral and multilateral basis, with a view to provide for inputs to the debates of the negotiation of the 2015 Agreement.


H.E. Minister Xie Zhenhua, Head of Chinese Delegation to COP-20 and Vice Chairman, NDRC

Li Junfeng, Director General, NCSC

Zou Ji, Deputy Director, NCSC

Robert Stavins, Director, Harvard Project on Climate Agreements

Du Xiangwan, Former Vice President, Chinese Academy of Engineering

Martin Kohl, President, South Center

Jennifer Morgan, Global Director of Climate Program, World Resources Institute

Teresa Ribera, President, Institute for Sustainable Development and International Relations


Tuesday, December 9, 4:30 – 6:10 pm, International Emissions Trading Association (IETA) Pavilion

“What Role will Markets Play in the 2015 Climate Agreement? How can the Agreement Facilitate Linkage of Carbon Pricing Policies?”


Dirk Forrister, President & CEO, IETA

Robert Stavins, Director, Harvard Project on Climate Agreements

David Hone, Chief Climate Change Adviser, Shell Research

Anna Lindstedt, Ambassador for Climate Change, Government of Sweden

Mary Nichols, Chair, California Air Resources Board

Amber Rudd, Parliamentary Under Secretary of State, Department of Energy and Climate Change, Government of the United Kingdom

See also background paper


Thursday, December 11, 11:30 am – 1:00 pm, Room: Caral

Sponsors: International Emissions Trading Association, Arizona State University, Harvard Project on Climate Agreements

“Linkage among climate policies in the 2015 Paris agreement”

Panelists will discuss how the Paris agreement might facilitate or impede linkage among cap-and-trade, carbon tax, and non-market regulatory systems. Panelists will also address related issues involving market mechanisms in the new agreement.


Daniel Bodansky, Foundation Professor of Law, Sandra Day O’Connor College of Law, Arizona State University

Dirk Forrister, President & CEO, IETA

Robert Stavins, Director, Harvard Project on Climate Agreements

Alexia Kelley, Senior Climate Change Advisor, U.S. Department of State

Nathaniel Keohane, Vice President for International Climate, Environmental Defense Fund

Ulrika Raab, Senior Advisor Climate Change, Swedish Energy Agency

See also background paper



What are the Benefits and Costs of EPA’s Proposed CO2 Regulation?

­On June 2nd, the Obama Administration’s Environmental Protection Agency (EPA) released its long-awaited proposed regulation to reduce carbon dioxide (CO2) emissions from existing sources in the electricity-generating sector.  The regulatory (rule) proposal calls for cutting CO2 emissions from the power sector by 30 percent below 2005 levels by 2030.  This is potentially significant, because electricity generation is responsible for about 38 percent of U.S. CO2 emissions (about 32 percent of U.S. greenhouse gas (GHG) emissions).

On June 18th, EPA published the proposed rule in the Federal Register, initiating a 120-day public comment period.  In my previous essay at this blog, I wrote about the fundamentals and the politics of this proposed rule (EPA’s Proposed Greenhouse Gas Regulation: Why are Conservatives Attacking its Market-Based Options?).  Today I take a look at the economics.

Cost-Effective, Perhaps – but Efficient?

The proposed rule grants freedom to implementing states to achieve their specified emissions-reduction targets in virtually any way they choose, including the use of market-based instruments (the White House has referenced cap-and-trade in this context, although somewhat obliquely as “market-based programs,” and state-level carbon taxes might also be acceptable – if any states were to include them in their plans to implement the regualtion).  Also, the proposal allows for multistate proposals and for states and regions to establish linkages among their state and multi-state market-based instruments.  Some questions remain regarding the temporal flexibility (banking and borrowing) that the proposed rule will allow, but it’s reasonable to conclude at this point that although EPA may not be guaranteeing cost-effectiveness, it is allowing for it, indeed facilitating it.  As Dallas Burtraw of Resources for the Future has said, the proposed rule ought to be judged to be potentially cost-effective.

Cost-effectiveness (achieving a given target at the lowest possible aggregate cost) is one thing, but economists – and possibly some other policy wonks – may wonder if the proposal is likely to be efficient (maximizing the difference between benefits and costs).  This is a much higher mountain to climb, and a particularly challenging one for a regional, national, or sub-national climate-change policy, given the global commons nature of the problem.

The Challenge of this Global Commons Problem

GHGs mix globally in the atmosphere, and so damages are spread around the world and are unaffected by the location of emissions.  This means that any jurisdiction taking action – a region, a country, a state, or a city – will incur the direct costs of its actions, but the direct benefits (averted climate change) will be distributed globally.  Hence, the direct climate benefits a jurisdiction reaps from its actions will inevitably be less than the costs it incurs, despite the fact that global climate benefits may be greater – possibly much greater – than global costs.

(An Aside:  This presents the classic free-rider problem of this ultimate global commons problem:  It is in the interest of no country to take action, but each can reap the benefits of any countries that do take action.  This is why international, if not global, cooperation is essential.  See the extensive work of the Harvard Project on Climate Agreements.)

On June 2nd, EPA released its 376-page Regulatory Impact Analysis (RIA) of the proposed “Clean Power Plan” rule, the same day it released the 645-page proposed rule itselfAn RIA is essentially a benefit-cost analysis, required for significant new Federal rules by a series of Executive Orders going back to the presidency of Jimmy Carter, and reaffirmed by every President since, including most recently President Obama.

Given the fundamental economic arithmetic of a global commons problem, it would be surprising – to say the least – if EPA were to find that the expected benefits of the proposed rule would exceed its expected costs, but this is precisely what EPA has found.  Indeed, its central estimate is of positive net benefits (benefits minus costs) of $67 billion annually in the year 2030 (employing a mid-range 3% discount rate).  How can this be?

Two Answers to the Conundrum

First, EPA does not limit its estimate of climate benefits to those received by the United States (or its citizens), but uses an estimate of global climate benefits.

Second, in addition to quantifying the benefits of climate change impacts associated with CO2 emissions reductions, EPA quantifies and includes (the much larger) benefits of human-health impacts associated with reductions in other (correlated) air pollutants.

Of course, even if benefits exceed costs at the given level of stringency of the proposed rule, it does not mean that the rule is economically efficient, because it could be the case that benefits would exceed costs by an even greater amount with a more stringent or with a less stringent rule.  However, if benefits are not greater than costs (negative net benefits), then the rule cannot possibly be efficient, so I will stick with the all-too-common Washington practice and simply ask whether the analysis indicates a winner or a loser at the proposed rule’s given level of stringency.  In other words, the question becomes, “Is the proposed rule welfare-enhancing (even if it is not welfare-maximizing)?”

Now, let’s take a look at the numbers from these two key aspects of EPA’s economic analysis and the issues surrounding the calculations.

U.S. versus Global Damages

There are surely ethical arguments (and possibly legal arguments) for employing a global damage estimate, as opposed to a U.S. damage estimate, in a benefit-cost analysis of a U.S. climate policy, but until recently all Regulatory Impact Analyses over several decades had focused exclusively on U.S. impacts.

In a recent working paper, “Determining the Proper Scope of Climate Change Benefits,” Ted Gayer, Vice President and Director of Economic Studies at the Brookings Institution, and Kip Viscusi, University Distinguished Professor of Law, Economics, and Management at Vanderbilt University, review the history of RIAs, including their virtually exclusive focus on national impacts (defined by geography or U.S. citizenship) in benefit and cost estimates of regulations.

In the context of a conventional RIA, it does seem strange – at least at first blush – to use a global measure of benefits of a U.S. regulation.  If this practice were applied in a consistent manner – that is, uniformly in all RIAs – it would result in some quite bizarre findings.  For example, a Federal labor policy that increases U.S. employment while cutting employment in competitor economies might be judged to have zero benefits!

Another example, this one courtesy of Tim Taylor via Ted Gayer:  Under global accounting, if a domestic climate policy had the unintended consequence of causing emissions and economic leakage (through relocation of some manufacturing to other countries), that would not be considered a cost of the regulation (and with diminishing marginal utility of income, it might be counted as a benefit)!

On the other hand, a counter-argument to this line of thinking is that the usual narrow U.S.-only geographic scope of an RIA is simply not appropriate for a global commons problem.  Otherwise, we would simply restate in economic terms the free-rider consequences of a global commons challenge.  In other words, a domestic-only RIA of a climate policy could have the effect of “institutionalizing free riding,” to quote my Harvard Kennedy School colleague, Professor Joseph Aldy.  Of course, if global benefits are to be included in a regulatory assessment, it can be argued that global costs (such as leakage) should also be considered.

I leave it to legal scholars and lawyers to debate the law, and I defer to the philosophers among us to debate the ethics, but let’s at least ask what the consequences would be for EPA’s analysis if a U.S climate benefits number were used, rather than a global number.  For this purpose, we can start with EPA’s estimates (from Table ES-7 on page ES-19 and Table ES-10 on page ES-23 of its Regulatory Impact Analysis of the proposed rule) for 2030 benefits and costs, using a mid-range 3% real discount rate.  The estimated (global) climate benefits of the rule are $31 billion.

In order to think about what the domestic climate benefits might be, we can turn to the Obama administration’s original calculation of the Social Cost of Carbon in 2010, where the Interagency Working Group estimated a central global value for 2010 of $19 per ton of CO2, and noted (and explained in more detail in a subsequent scholarly paper by several members of the Working Group) that U.S. benefits from reducing GHG emissions would be, on average, about 7 to 10 percent of global benefits across the scenarios analyzed with the one model that permitted such geographic disaggregation.

(The Interagency Working Group also suggested that if climate damages are simply proportional to GDP, then the U.S. share would be about 23%.  However, given the IPCC’s prediction of highly unequal geographic distribution of climate change effects worldwide, combined with the exceptionally heterogeneous nature of climate sensitivity among the world’s economies, which vary from those with trivial reliance on agriculture to those dominated by their agricultural sectors, I find the argument behind this second approach unconvincing.)

Taking the midpoint of the Obama Working Group’s 7-10% range, U.S. damages (benefits) may be estimated to be 8.5% of global damages, which would reduce the $31 billion reported in the new RIA to about $2.6 billion, which is considerably less than the RIA’s estimated total annual compliance costs of $8.8 billion (assuming that the states facilitate cost-effective actions).  This validates the intuition, explained above, that for virtually any jurisdiction, the direct climate benefits it reaps from its actions will be less than the costs it incurs (again, despite the fact that global climate benefits may be much greater than global costs).

There are plenty of caveats on both sides of this simple analysis.  One of the most important is that if the proposed U.S. policy were to increase the probability of other countries taking climate policy actions (which I believe is probably the case), then the impacts on U.S. territory of such foreign policy actions would merit inclusion even in a traditional U.S.-only benefit-cost analysis.  More broadly, although it has been traditional to use a U.S.-only benefits measure in RIAs, the current guidelines for carrying out these analyses from the Office of Information and Regulatory Affairs of the U.S. Office of Management and Budget (Circular A-4) requires that geographic U.S. benefit and cost estimates be provided, but also allows for the optional inclusion of global estimates.

Pending resolution (or more likely, discussion and debate) from lawyers and philosophers regarding the legal and ethical issue of employing domestic benefits versus global benefits in a climate regulation RIA, it is essential to recognize that there is an even more important factor that explains how EPA came up with estimates of significant positive net benefits (benefits exceeding costs) for the proposed rule (and would have even if a domestic climate benefits number had been employed), namely, the inclusion of (domestic) health impacts of other air pollutants, the emissions of which are correlated with those of CO2.

Correlated Pollutants and Co-Benefits

The Obama Administration’s proposed regulation to reduce CO2 emissions from the electric power sector is intended to achieve its objectives through a combination of less electricity generated (compared with a business-as-usual trajectory), greater dispatch of electricity from less CO2-intensive sources (natural gas, nuclear, and renewable sources, instead of coal), and more investment in low CO2-intensive sources.  Hence, it is anticipated that less coal will be burned than in the absence of the regulation (and more use of natural gas, nuclear, and renewable sources of electricity).  This means not only less CO2 being emitted into the atmosphere, but also decreased emissions of correlated local air pollutants that have direct impacts on human health, including sulfur dioxide (SO2), nitrogen oxides (NOx), particulate matter (PM), and mercury (Hg).

It is well known that higher concentrations of these pollutants in the ambient air we breathe – particularly smaller particles of particulate matter (PM2.5) – have very significant human health impacts in terms of increased risk of both morbidity and mortality.  The numbers dwarf the climate impacts themselves.  Whereas the U.S. climate change impacts of CO2 reductions due to the proposed rule in 2030 are probably less than $3 billion per year (see above), the health impacts (co-benefits) of reduced concentrations of correlated (non-CO2) air pollutants are estimated by EPA to be some $45 billion/year (central estimate)!  (By the way, I assume that the co-benefits estimated by EPA are based upon a comparison with a business-as-usual baseline that includes the effects of all existing EPA and state regulations for these same local air pollutants.  If not, the RIA will need to be revised.)

The Bottom Line

The combined U.S.-only estimates of annual climate impacts of CO2 ($3 billion) and health impacts of correlated pollutants ($45 billion) greatly exceed the estimated regulatory compliance costs of $9 billion/year, for positive net benefits amounting to $39 billion/year in 2030.  This is the key argument related to the possible economic efficiency of the proposed rule from the perspective of U.S. welfare.  If EPA’s global estimate of climate benefits ($31 billion/year) is employed instead, then, of course, the rule looks even better, with total annual benefits of $76 billion, leading to EPA’s bottom-line estimate of positive net benefits of $67 billion per year.  See the summary table below.

The Obama Administration’s proposed regulation of existing power-sector sources of CO2 has the potential to be cost-effective, and if you accept these numbers, it can also be welfare-enhancing, if not welfare-maximizing.

That said, I assume that proponents of the Obama Administration’s proposed rule will take this assessment of EPA’s Regulatory Impact Analysis as evidence of the sensibility of the rule, and opponents of the Administration’s proposed actions will claim that my assessment of the RIA provides evidence of the foolishness of EPA’s proposal.  So it is in our pluralistic system (not to mention, in the context of the political polarization that has gripped Washington on this and so many other issues).


Benefits and Costs of EPA’s Proposed Clean Power Plan Rule in 2030

(Mid-Point Estimates, Billions of Dollars)

Climate Change Impacts

Health Impacts (Co-Benefits) of Correlated Pollutants plus …



Domestic Climate Impacts

Global Climate Impacts

  Climate Change

$ 3

$ 31



  Health Co-Benefits



Total Benefits

$ 3

$ 31



Total Compliance Costs

$ 9

$ 9

$ 9

$ 9

Net Benefits (Benefits – Costs)

– $ 6

$ 22

$ 39

$ 67