The E-mail Commentary from Eco-Justice Ministries
An Unforgiveable Order
While Jesus was dying on the cross -- according to some versions of Luke's gospel -- he said "Father, forgive them; for they do not know what they are doing." (23:34)
Those words of forgiveness can never be applied to those who drafted this week's Presidential Executive Order on Promoting Energy Independence and Economic Growth. That order is an intentional, wide-ranging attack on US climate policies. Effectively, the order will stop all US initiatives to reduce greenhouse gas emissions.
They know perfectly well what they are doing. And what they are doing is despicable.
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A White House press release on the executive order quotes the President: "I am going to lift the restrictions on American energy, and allow this wealth to pour into our communities." He certainly is lifting restrictions. Wealth will pour as a result, but I have serious questions about how much of it will pour into local communities. I do know that, because of this executive order, vastly increased pollution will pour into Earth's atmosphere.
The order -- in section 1(c) -- instructs federal agencies to "immediately review existing regulations that potentially burden the development or use of domestically produced energy resources". Section 2(b) lets us know that "For purposes of this order, 'burden' means to unnecessarily obstruct, delay, curtail, or otherwise impose significant costs on the siting, permitting, production, utilization, transmission, or delivery of energy resources."
Those reviews will take some time, up to 180 days. But other actions in the order take effect immediately. Section 3 lists numerous Obama-era actions that are revoked, such as power sector carbon pollution standards from 2013, and a 2016 memorandum on climate change and national security. Several reports on the Climate Action Plan have been rescinded. There's a broad ripple effect from those immediate steps. All federal agencies "shall, as soon as practicable, suspend, revise, or rescind, or publish for notice and comment proposed rules suspending, revising, or rescinding any such actions" that are based on the now-revoked actions and rescinded reports.
Section 4 of the order initiates processes to do away with the Clean Power Plan and related rules. Sections 6 and 7 open up coal leasing and oil and gas development.
But it is section 5 of the executive order that demolishes the foundation for any federal action on climate change. That section profoundly changes the way that the economic impacts of carbon emissions are calculated. Those calculations use the Social Cost of Carbon -- "the most important number you've never heard of."
The Environmental Defense Fund says that "The social cost of carbon is a measure of the economic harm from those impacts, expressed as the dollar value of the total damages from emitting one ton of carbon dioxide into the atmosphere. ... By properly accounting for the damages caused by carbon pollution, agencies can properly evaluate policies that affect greenhouse gas emissions."
I've discovered that the methods for determining that cost have been controversial. There are long-standing arguments about whether the US should consider the global impacts of our carbon emissions, or look only at the domestic costs of that pollution. (The Obama administration used the global approach.) Another point of dispute deals with discount rates -- an assessment of how much current pollution will cost future generations. The size of the discount (ranging from 2.5% to 7%) is immensely important.
The American Enterprise Institute -- which supports the Trump actions -- names what happens when the largest discount rate is used. "At 7 percent, the social cost of carbon becomes small or negative." At the 7 percent rate, the absurd economic claim is made that unlimited amounts of climate-warping pollution will have no cost for future generations.
In section 5 of the executive order, The Interagency Working Group on Social Cost of Greenhouse Gases is disbanded. The documents used by that working group through the last six years are "withdrawn as no longer representative of governmental policy." And, "Effective immediately, when monetizing the value of changes in greenhouse gas emissions resulting from regulations," an Office of Management and Budget circular from 2003 will be used. OMB Circular A-4 looks only at domestic costs, and allows discount rates up to 7 percent.
From now on, the benefit-cost analysis for federal regulations on carbon pollution will be done in such a way that the costs of regulation will be seen as very high, and the benefits (the reduction in future costs) are very low. By these standards, it will be virtually impossible to make an economic case for regulations that reduce carbon emissions.
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Is there any good news?
Well, it is helpful that undoing current regulations will take time. Bloomberg reports, "Generally, regulations can't be killed with the stroke of the president's pen. Instead the administration must undertake the same rulemaking process used to create regulations to undo them." That process could, in some cases, take years.
And it is guaranteed that many of the proposed changes in regulations will be contested in court. Some challenges have already been filed. Certainly, the methods used to calculate the social cost of carbon will be part of those lawsuits. And, Bloomberg notes, "Courts also have held that federal decisions can be disqualified if they were driven by regulators who have an 'unalterably closed mind' on an issue."
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What can we do?
On one level, we can broaden our strategic range. Not everything happens in Washington, DC. In the coming years, local and state climate initiatives will be especially important, and need our active support.
We can act at the national level, too. As agencies make proposals to revise or rescind regulations, those new rules will be open to public comments. In the coming months and years, we will all become more adept at filing statements that insist on strong regulation. I'll keep you posted on the most important opportunities to comment.
In the near term, the most significant way to act is to make it clear that we, the people, demand that the real and increasing threat climate change be taken seriously. In every available way, we need to speak up -- in conversations at work and with friends, in letters to the editor and with Facebook posts, in sermons and classes at church.
Especially in light of the unconscionable executive order, we need to turn out for major public actions in the coming weeks. Two huge events are planned in Washington, DC, with satellite actions in other cities. If there is any way that you can take part, do so.
The far-right policies of this new administration are creating an unforgivable threat to Earth's climate, and to future generations. The ethical failures of their approach must be named clearly and repeatedly. And we must exercise our political strength at every opportunity.
We have our work cut out for us. It is good work, and we join with multitudes of conscientious people around the world as we fight for the health of God's creation.
Eco-Justice Ministries * 400 S Williams St, Denver, CO 80209 * 303.715.3873
Home Page: www.eco-justice.org * E-mail: firstname.lastname@example.org