SD15 - Analysis of Projected Health Co-Benefits in EPA’s Proposed Clean Power Plan: Report in Response to Virginia Senate Joint Resolution No. 273 (2015 Session)


Executive Summary:
On June 18, 2014, the U. S. Environmental Protection Agency (EPA) published a proposed rule for “Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units” to reduce the impact of climate change from this emission source sector. Also known as the proposed Clean Power Plan (the “Plan”), this rule would require an overall 30% reduction in carbon dioxide (CO2) from existing electricity generating units before 2030 by establishing state?specific emission rate and reduction goals.

The focus of the Plan is on achieving CO2 reductions specifically to reduce potential future effects from climate change. In its regulatory impact analysis (RIA) of the estimated costs and benefits of the Plan, however, the EPA also included health benefits associated with the expected reduction of criteria pollutant emissions and ambient air pollution levels that are expected as a co?benefit of the Plan. For decades, the EPA has separately promulgated a number of national ambient air quality standards (NAAQS) for criteria pollutants and associated control programs that identify similar, and perhaps some of the same, emission reductions and resulting benefits. This situation could result in the “double counting” of these benefits by the EPA in the Plan and one or more of these other rules. The EPA in fact acknowledges this possibility in the Plan’s RIA stating, “…it is possible that some costs and benefits estimated in this RIA may account for the same air quality improvements as estimated in the illustrative NAAQS RIAs.”

During the 2015 Session of the Virginia General Assembly, Senate Joint Resolution No. 273 (SJR 273) was passed that directs the Virginia Department of Environmental Quality (VDEQ) to study the health benefits of the proposed federal Plan in comparison with the projected health benefits from other air quality regulations. VDEQ entered into an agreement with the Virginia Center for Coal and Energy Research (VCCER) at Virginia Tech to conduct this study and provide a report to the VDEQ allowing them to comply with SJR 273. To this end, the VCCER engaged the services of National Economic Research Associates, Inc. (NERA) to conduct primary research and analysis and report its findings.