Trump’s Reckless Delays Will Drive up Climate Damages

The need to take swift and decisive action to combat dangerous climate change has never been more compelling. Yet the Trump administration is embarking on a series of actions that would accelerate emissions of the carbon pollution that is driving the world toward catastrophic warming.

In so doing, the president is blatantly ignoring the overwhelming consensus of the world’s leading climate scientists -- who’ve just issued dire warnings in a major report – as well as the views of a strong majority of the American public – who want action on climate. Two events in the coming days highlight President Trump’s recklessly in the face of this mounting threat.

Public comment periods are closing on a pair of Trump administration proposals to roll back pollution standards designed to cut the carbon pollution from the nation’s two biggest climate polluters – our cars and trucks, and our power plants.

At a time when our government should be strengthening those safeguards, Trump’s officials are dedicated to weakening them.  If these rollbacks succeed, they will further contribute to the pollution that is driving up global temperatures, raising the seas, and supercharging hurricanes and other extreme weather -- putting us and our children at rising risk.

Today comments are due on Trump’s proposal to freeze carbon pollution and fuel economy standards for cars and light trucks at 2020 levels, canceling the current clean car standards that gradually strengthen to 51 mpg by model year 2025.

Separately, comments are due on October 31st  on Trump’s proposal to repeal the landmark Clean Power Plan and replace it with a worse-than-nothing alternative. 

NRDC will submit legal analysis and technical comments opposing both rollbacks. For the cars rollback, we’ll show how the administration has relied on a technical analysis so deeply flawed that even its own experts do not support it. Their proposal would achieve zero improvement in vehicle emissions reductions or fuel economy between 2020 and 2026. You don’t have to be an automotive engineer to recognize that zero improvement cannot be the “maximum feasible” fuel economy level required by the law. Indeed, when you eliminate the errors in the National Highway Traffic Safety Administration’s analysis – an analysis which EPA leadership blindly followed – the benefits of the existing clean car standards come clear -- they cut pollution, lower the cost of transportation for customers and maintain jobs in the automotive sector.

Addressing power plant carbon pollution, NRDC will call for strengthening, not abandoning, the Clean Power Plan. 
Our comments will include analysis showing that much deeper carbon pollution reductions can be achieved at reasonable cost from the nation’s coal-and-gas-fired power plants.



Key points follow. Our full comments will be available by the comment period deadlines on our website.

The proposed “SAFE” Vehicles Rule

The proposed SAFE Vehicles Rule radically departs from prior determinations.  Contrary to its prior analysis, the Trump-era National Highway Traffic Safety Administration (NHTSA) now asserts that it is not feasible for manufacturers to make any improvement in average fuel economy for any of six future model years, 2021-2026.  And for its part, EPA – relying entirely on NHTSA’s analysis and ignoring its own analysis tools – now asserts that full consideration of the public health and welfare warrant rolling back emission standards for each of those years.


But there is absolutely no basis for halting efforts to reduce emissions this way. Neither NHTSA nor EPA argue that achieving further emission reductions is not technically feasible. Such a claim is not possible as s multiple automakers are already deploying the technologies – like better internal combustion engines – needed to meet the standards.


The only way that NHTSA and EPA can justify their proposed weakening is by relying on arbitrary models in which automakers are forced to choose the most expensive compliance path and bizarre claims about how the fleet may change. NHTSA admits that cleaner and more efficient cars are just as safe as current vehicles but introduces untested analysis to claim that there will be a huge increase in how much we drive and as a result more people may get into accidents.

But the experts whose analysis NHTSA relied upon have weighed in and told the agency it got its calculations wrong. NHTSA’s analysis is “at odds with basic economic logic and intuition,” wrote the University of California's Mark Jacobsen and Wharton School's Arthur van Benthem in their comments on this flawed proposal. While NHTSA claims the economic benefit of the rollback would be $90 billion, Jacobsen and van Benthem show that if just the flawed vehicle fleet size error were corrected, the benefits of the rollback “likely to fall to near zero.”

Back to basics: Congress directed NHTSA to set fuel economy standards at the “maximum feasible” level for each model year and directed EPA to reduce emissions of dangerous air pollution like carbon dioxide. The current leadership at each agency implausibly contends that the best that can be done is no improvement at all. Yet at the same time, the agencies claim that even without standards new vehicle fuel economy will improve (modestly) over the same period. The agencies’ proposal to raise standards not at all cannot reflect the maximum feasible level if they also say manufacturers will make improvements on their own.

In fact, manufacturers have not historically improved fuel economy by themselves. Improvements happen when we set standards that drive technology innovation and ensure that all manufacturers are playing on a level playing field. This is what Congress mandated and what we will demand from NHTSA and EPA – in our comments and through the Courts if the agencies do not change course.


The Proposed Dirty Power Plan 

Finalized in 2015, the Clean Power Plan set the first national limits on emissions of dangerous carbon pollution from the nation’s power plants. It was the biggest step yet to rein in the key driver of climate change from the power sector – then our largest source of this dangerous pollution. These sensible standards limiting power sector pollution are a critical step to curb the threat of climate change to our communities, our health, and our future.


Ignoring the reality of climate change, the Trump administration has proposed to repeal the Clean Power Plan and replace it with a do-nothing replacement they call the “Affordable Clean Energy” Rule but which is neither affordable nor clean. It’s a dirty power plan.  EPA itself admits that the replacement would result in up to 1,400 fatalities per year in 2030.


My colleague Lissa Lynch itemized many of the replacement plan’s flaws shortly after the announcement. Our comments will address all of these points.


In our comments, we will also present modeling results that show what EPA should have done if it wanted to replace the Clean Power Plan. In other words, ways to strengthen the Plan so that we can cut pollution even further.


As our modeling will show, there are multiple ways to achieve much deeper reductions in carbon emissions. Thanks to the falling cost of renewables and energy efficiency and competitive gas prices, we can go even further than we thought when EPA put the Clean Power Plan in place. In fact, power sector emissions are on track to drop 36 percent below 2005 levels in 2030.  That isn’t as much as the 39 percent the Clean Power Plan requires, but it much better than expected.


The best option is to strengthen the Clean Power Plan to reflect that we can go further than we thought in 2015. For example, we show that an updated CPP can achieve a roughly 55% reduction. But we also present options that achieve significant reductions even assuming the constrained types of emission reduction tools the Trump EPA prefers. For example, by using on-site measures like co-firing of natural gas or carbon capture and sequestration, EPA could establish a plan that achieves significant emission reductions – not just the measly 1 percent EPA predicts from its replacement.  We’ll report on the final results next week.


There’s still time, but the window is closing


On clean cars and clean power, the Trump administration is driving our country in the wrong direction, and we’ll all pay the price of dirtier, unhealthy air that fuels only polluter’s profits.


This administration shouldn’t continue on this reckless course. As our comments will show, there are key solutions already on the shelf that can cut pollution from cars and power plants.


This administration claims that the best we can do to tackle climate change is nothing – no pollution reductions at all. Fortunately, our laws require that the administration respond to our comments and defend their proposal. And this pair of do-nothing proposals are indefensible in the face of the urgent warnings like those from the recently released IPCC report. If they do not change course, we will use the courts to enforce our bedrock environmental laws and ensure that we curb the pollution that is imperiling the planet and our children’s future.