Read TPPF’s comments on the repeal of the new Clean Power Plan here.
Key Points
- Section 111 of the Clean Air Act requires the EPA to find that emissions of a pollutant from a source category “contributes significantly” to air pollution that endangers the public health.
- Because carbon dioxide (CO2) is not directly harmful to humans and only impacts the public health by changing global temperatures, a threshold for significance must be set based on a source category’s contribution to global temperature increase.
- The measurement error in the average global surface temperature is approximately ±0.1 °C, so any contribution that is smaller than this “noise” in the data cannot be considered measurable, much less significant.
- At most, future U.S. power plant CO2 emissions will increase global temperatures by 0.015 °C by 2050, and all U.S. CO2 emissions will cause a 0.052 °C increase by 2050.
Therefore, no source category of U.S. CO2 emissions currently meets the 0.1 °C threshold to qualify as “contribut[ing] significantly” to global temperatures.
Read “The Materiality of of U.S. CO2 Emissions on Global Climate, full paper here.
