In the Pipeline: 4/15/13

You know it’s bad when… Columbia Journalism Review (4/12/13) reports: “Journalists and the GOP called for more transparency at the Environmental Protection Agency (EPA) this week, as Gina McCarthy, the Obama administration’s pick to succeed Lisa Jackson as head of the agency, entered congressional confirmation hearings… The day before McCarthy, who now heads the EPA’s air pollution division, faced off with the Senate Committee on Environmental and Public Works, a group of Republicans on the committee and the Society of Environmental Journalists (SEJ) released separate statements, with different motivations, accusing the agency of secrecy and calling for more openness.”

 

This must have been painful for Seth to write. Which is, of course, part of the fun. Energy Guardian (4/12/13) reports: “Last year’s huge drought was a freak of nature that wasn’t caused by man-made global warming, a new federal science study finds.”

 

The playbook for green energy cronyism: A wink and a nod, legalized theft, twisted economics, and a splash of PR-infused rhetoric to keep everyone happy until the roof caves in. WSJ(4/11/13) reports: “Turn over any green-energy rock, and wiggling underneath will be the usual creepy mix of political favoritism and taxpayer-funded handouts. Add to this the Clintons, Mississippi and a murky visa program, and you’ve got a particularly ripe political embarrassment for Terry McAuliffe… Everyone remember The Macker? Best Friend of Bill. Chairman of Hillary’s 2008 presidential campaign. Famed money-tree shaker. Former Democratic Party chief. Failed 2009 contender for the Virginia governorship but now back as the party’s nominee for that position in this fall’s election. Oh—and in Mr. McAuliffe’s words—‘a Virginia businessman’ intent on ‘creating jobs.’”

 

The candle of the wicked shall be put out: “Quotations of the day on ethanol. What’s to like? Absolutely nothing, unless you’re a rent-seeking corn farmer”. AEI (4/12/13) reports: “1. Ken Green (2008): ‘Contrary to popular belief, ethanol fuel will do little or nothing to increase our energy security or stabilize fuel prices. Instead, it will increase greenhouse gas emissions, local air pollutant emissions, fresh water scarcity, water pollution (both riparian and oceanic), land and ecosystem consumption, and food prices.’”

 

It can look desperate when you come on this strong. You’ve got to play a little hard-to-get. E&ENews (4/12/13) reports: “Organizing for America yesterday deployed one of the most hackneyed pleas in social media in hopes of shaming House GOP leaders into holding hearings on climate change policy… ‘RT if you agree: It’s time to stop the denial on climate change,’ President Obama’s nonprofit advocacy organization wrote on its Twitter account, urging the nearly 30 million followers of @BarackObama to repeat the message.”

 

This is the kind of change we can believe in: 

Prius_

Free Market Coalition to U.S. Governors: Oppose Wind PTC

WASHINGTON D.C. — American Energy Alliance President Thomas Pyle was joined today by eight other free market organizations in a joint letter to governors of 21 U.S. states that do not force their citizens to purchase unaffordable, intermittent electricity from renewable sources. The letter urges these governors to oppose any further extension of the wind Production Tax Credit (PTC) that unfairly forces their states to subsidize such mandates in other states. The coalition chose to send the letter on Tax Day, a day when Americans have a heightened awareness of the direct cost that bad government policy imposes on them and their families.

“Your constituents pay disproportionately for a lavish tax credit that does not benefit them,” the letter states. “Instead of helping your constituents, the PTC leads to energy production in other states that is unsustainable without the mandates and federal subsidies. Under the wind PTC, non-renewable mandate states like yours — which has wisely chosen to allow the most affordable and reliable forms of energy to be purchased by consumers and industries — are penalized for the political decisions of states like California, Massachusetts, and New York.

“By taking a principled stand against the PTC, you help taxpayers in your own state and ensure more cost-effective electricity generation over all. We urge you to call for an end to this wasteful, inequitable subsidy immediately.”

The other signatories of the letter are:

Myron Ebell, Freedom Action
Marlo Lewis, Competitive Enterprise Institute
Eli Lehrer, R Street Institute
Sabrina Schaeffer, Independent Women’s Forum
Michael Needham, Heritage Action
Wayne Brough, Freedom Works
David Ridenour, The National Center for Public Policy Research
Phil Kerpen, American Commitment

To read the full text of the letter, click here.

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Federal Regulations Drive Up Gasoline Prices


Lately an argument has broken out over the Renewable Fuel Standard (RFS) and whether it drives up gasoline prices. The recent controversy was sparked by a WSJ article discussing the shocking fact that Renewable Identification Number (RIN) credits—which are one way of complying with the federal standard—had shot up in prices from about 7 cents in January to more than $1 in March. The WSJ article argued that—duh!—massively increasing a cost component would drive up gas prices.

In response, the Renewable Fuels Association (RFA) commissioned a quantitative study by “informa economics,” which concluded (surprise?) that the impact of the skyrocketing price of RIN credits had virtually no measureable impact on pump prices. In fact, the study said that the RFS mandate made it cheaper for American motorists to drive their vehicles.

Here at American Products. American Power. an earlier blog post has already documented the numerous flaws in the study. For example, the study ignores the fact that ethanol has less energy content per volume than conventional gasoline, making the RFA study’s price comparisons misleading. But more fundamentally, our blog post argued that even taking the RFA study at face value, it would mean that there is no need for a federal Renewable Fuel Standard. To repeat our point: If the people at RFA actually believe that using ethanol instead of conventional gasoline is good for the refining industry and will lower prices at the pump, then why do we need a federal mandate? Why wouldn’t natural market forces give us this outcome?

In the present post, we want to supplement our earlier critique with one additional point. One of the ways that the RFA-commissioned study tries to exonerate RIN prices from the spike in gas prices, is to say that the seasonal pattern in early 2013 was not noticeably different from that in 2011 and 2012. Looking at the “crack spread,” for example, doesn’t show us anything unusual in early 2013. Here’s how they put it:

There is a distinct seasonal pattern to gasoline prices and crack spreads, slumping during the last quarter of the calendar year and then strengthening considerably through the first quarter of the following year.  The increase in gasoline prices and crack spreads during the first quarter of 2013 has been generally consistent with increases experienced in 2011 and 2012, despite the fact that conventional ethanol RIN prices averaged $0.03 during the first quarter of 2011 and $0.02 during the first quarter of 2012.

Now, they actually don’t come right out and explicitly finish their argument here—probably because even their own readers would raise an eyebrow. To finish the train of thought they should add, “So the fact that RIN prices shot up to more than $1 in the first quarter of 2013, shouldn’t make us blame the spike in gas prices—over and above changes in crude oil prices—on the Renewable Fuel Standard.”

Such analysis shows the danger of naïve statistical analysis in economic matters. It’s true, there are always a million factors changing in the real world. On top of that, producers don’t mechanically set prices based on their “costs” plus some margin for “profit.” Everything is always embedded in a context of consumer demand, as well as expectations of the future. Finally, even demonstrably obvious factors might be muted in their apparent effects, because we don’t know what the path of the economy would be in the alternate timeline. For example, eating a Snickers bar is generally not a good way to lose weight, but if we just looked at a guy stranded on a desert island, we might see a correlation between him eating the candy bar in his pocket, and losing 5 pounds.

Yet let’s put aside all of these commonsense observations, and focus just on the raw numbers. Remember, the defenders of the Renewable Fuel Standard are saying that the big jump in RIN prices in early 2013 didn’t cause a spike in gas prices (relative to crude oil prices), any more than happened in 2011 or 2012. But look at a long-term chart of crude oil vs. gasoline prices to see why that “defense” is rather misleading:

 

 

As the chart above shows, gasoline prices have been much higher, relative to crude oil prices, precisely in the period the RFA-commissioned study analyzes. We can be even fancier and look at a single measure, where we take the average price of a gallon of gas, and subtract out the price of a barrel of crude divided by 42 (since that’s how many gallons of gas are produced by a barrel of oil):

 

 

Intuitively, the second chart shows that the average U.S. retail price of gasoline, relative to the adjusted crude oil cost, was much higher in the mid-2000s and then again from 2011 through today, compared to the long-term trend. For some reason, it seems as if some additional force has been pushing up prices at the pump, that was particularly pronounced in the mid-2000s and then again in the last three years. What could it be?

As we said before, it’s impossible to point to one specific factor, because market prices are based on many different elements. But on these pages we have discussed the costly mandates embedded in the Energy Policy Act of 2005, and the Tier 2 standards that insisted on a 90 percent reduction in sulfur contact by 2006, and how the recently codified Tier 3 standards will begin rising pump prices.

In short, we have been warning on these pages that the various, bipartisan interventions into the refining sector—starting under President George W. Bush and ramping up under President Obama—have been making gasoline artificially more expensive for American motorists. The world price of crude oil alone cannot explain the annual surges in gasoline prices since 2005, with the only (relative) respite occurring during the massive economic slump of 2008.

It’s true, in economics we usually can’t have a smoking gun and point to “the” reason a market price moved in a certain way. Yet economic theory—as well as common sense—tells us that increasing refiner costs will make gasoline prices higher for motorists. Further, the historical data most certain do show a strong correlation between the Bush and Obama regulations on refining, and an extra margin in gas prices.

In the Pipeline: 4/12/13

Thank goodness we have the money to spend on this sort of thing. I mean, it doesn’t seem ridiculous or pointless at all. The Hill(4/11/13) reports: “President Obama’s fiscal 2014 budget calls for using a satellite designed to track climate change that was originally pushed by former Vice President Gore… Obama proposed Wednesday spending nearly $35 million in his 2014 budget to refurbish a satellite, nicknamed GoreSat by critics, that’s been sitting in storage after it was shelved in 2001, months after Bush took office. It cost about $100 million by then with NASA’s internal auditors faulting its cost increases.”

 

Welcome to the party: “Wind power kills jobs and increases electricity costs”. Toronto Sun (4/11/13) reports: Ontario’s pursuit of wind power has driven up electricity prices, is killing jobs and might even lead to more smog, a new Fraser Institute report says… Ross McKitrick, author of Environmental and Economic Consequences of Ontario’s Green Energy Act (GEA), says the Ontario government’s electricity plan is now 10 times more costly than installing pollution-control equipment on existing coal plants — an option he argues would have produced similar improvements in air quality.”

 

So can we assume the Blazers will ride bikes between the cities where they play? Or, will they wear unis and shoes made only from non-carbon based products like hemp? Or, more likely, their billionaire owner will buy carbon offset credits and all will be fine. Oregon Live (4/11/13) reports: “Businesses with strong Northwest ties, including the Portland Trail Blazers, Nike, Intel, Adidas and Starbucks, are among 33 companies signing a “climate declaration” that urges U.S. policymakers to take action to curb global warming… The Trail Blazers are the only sports franchise on the list.”

 

So easy to see even NPR understands it. We are, however, still bullish on wood. NPR (4/10/13) reports: “Until well into the 19th century, if you lived in the U.S. and wanted to heat your house, fire your forge, or whatever, you did what people had done for thousands of years: You chopped down a tree and burned it… Though renewables have risen sharply in the past few years, they still represent a tiny fraction of the energy used in this country.”
Not all news is bad news: “State Government Tax Revenue Hits All-Time High”. WSJ (4/11/13) reports: “North Dakota and Alaska, in particular, showed the strongest tax revenue gains, (47% and 27%, respectively), mostly because of higher collections from companies using state resources, the Census Bureau said. Overall, tax revenue collected from companies using natural resources was up almost 39%, or $4.2 billion, from 2011.”

 

The following think tank chiefs are opposed to a carbon tax. Please contact us at [email protected] if you wish to join our growing ranks. We are thinking about starting a new list – trade association heads. We fear, however, it will be pretty small.


Tom Pyle, American Energy Alliance / Institute for Energy Research
Myron Ebell, Freedom Action
Phil Kerpen, American Commitment
William O’Keefe, George C. Marshall Institute
Lawson Bader, Competitive Enterprise Institute
Andrew Quinlan, Center for Freedom and Prosperity
Tim Phillips, Americans for Prosperity
Joe Bast, Heartland Institute
David Ridenour, National Center for Public Policy Research
Michael Needham, Heritage Action for America
Tom Schatz, Citizens Against Government Waste
Grover Norquist, Americans for Tax Reform
Sabrina Schaeffer, Independent Women’s Forum
Barrett E. Kidner, Caesar Rodney Institute
George Landrith, Frontiers of Freedom
Thomas A. Schatz, Citizens Against Government Waste
Bill Wilson, Americans for Limited Government
Wayne Brough, FreedomWorks
Rich Collins, Positive Growth Alliance

One last thing. The crew at the Pipeline wishes Cathy Anne a very Happy Birthday! 

ICYMI: White House Favors Green Energy

WASHINGTON D.C. — AEA President Thomas Pyle was cited in an E&E News Greenwire article today on the energy provisions in President Obama’s FY2014 budget proposal. Pyle’s comments target President Obama’s continued pursuit of discriminatory energy policies:

greenwire-logo

Clean energy favored, fossil fuel programs cut under fiscal 2014 budget
E&E News, Greenwire
By Nick Juliano, Hannah Northey and Katherine Ling, E&E Reporters
4/10/2013

President Obama’s fiscal 2014 budget request would boost funding for a variety of clean energy initiatives while reducing spending on fossil fuel programs and repealing oil and gas tax breaks.

The clean energy increases would come in research and development, state-based competition to enhance energy efficiency and the electric grid, a new trust fund designed to find alternatives to oil in transportation, and a permanent extension of the renewable energy production tax credit.

The falling fossil budget and resurrection of a long-standing call to eliminate tax breaks led to complaints from industry groups and Republicans that the president’s claimed “all of the above” energy strategy does not adequately account for coal, gas and oil.

The Department of Energy would see its overall budget grow to $28.4 billion next year, an 8 percent increase from fiscal 2012 levels. That also would reverse the effects of sequestration and a subsequent cut in the recently passed continuing resolution, which dropped DOE’s current appropriations to about $26 billion.

Obama’s budget emerged this morning, two months overdue and after the House and Senate each adopted their own starkly different budgets for fiscal 2014. The document already has been pronounced dead on arrival on Capitol Hill, but it outlines the administration’s priorities as the fiscal 2014 appropriations process ramps up and ahead of tax-and-spending battles likely to dominate Washington through the summer.

Within DOE, the biggest winners are efficiency and renewable energy programs. The budget would provide $615 million for solar, wind, geothermal and hydro energy as part of an overall increase of 40 percent above fiscal 2012 levels for clean technology activities, according to a summary.

The budget resurrects Obama’s long-standing proposal to eliminate a suite of tax deductions and other incentives for the oil and gas industry, including allowing exploration and production companies to deduct intangible drilling costs and a domestic manufacturing deduction. The proposal, which the administration says would save more than $40 billion over the next decade, has been roundly rejected by nearly all Republicans and most oil-state Democrats in Congress.

Obama’s budget also proposes eliminating various tax incentives for the coal industry, which it says would save nearly $3.3 billion over the next decade.

Revenue from closing the fossil fuel and other tax “loopholes” would go to a variety of new or extended tax supports for clean energy, efficiency, domestic manufacturing, and research and development totaling $53.4 billion over the next decade. That includes a permanent extension of the production tax credit, which would cost $17 billion over 10 years, as well as several incentives for advanced technology vehicles and efficient buildings.

Conservatives were quick to dismiss the proposed trade-off.

“He continues his effort to incorporate punitive and discriminatory tax measures for oil and gas producers into the tax code, while renewing his effort to poach mineral royalties owed to U.S. taxpayers to fund his green energy schemes without opening new lands for exploration and development,” said Tom Pyle, president of the American Energy Alliance, a conservative think tank.

The president’s defenders, meanwhile, said his budget provided a welcome contrast to the one adopted by House Republicans last month.

“By eliminating nearly $40 billion in unnecessary special tax breaks for Big Oil over the next 10 years, President Obama’s proposed budget makes the tax code more fair while investing additional revenue to support the middle class,” said Daniel Weiss, director of climate strategy for the liberal Center for American Progress. “Meanwhile, the Republican-controlled House continues to ignore the needs of Americans by passing Rep. Paul Ryan’s (R-WI) budget, which would pour $20 billion in new tax breaks into Big Oil’s already full revenue barrel while draining funding from vital health programs and investments in economic growth.”

Obama’s budget also formalizes several proposals that have been gaining traction among administration members and in energy policy circles, including an interstate clean energy competition program modeled on the popular “Race to the Top” education initiative. The budget proposes a one-time $200 million pool of money from which states would receive competitive grants for a variety of efficiency and grid improvements.

“Key opportunities for States include: modernizing utility regulations to encourage cost-effective investments in efficiency, including combined heat and power and demand response resources, and in clean distributed generation; enhancing customer access to data; investments that improve the reliability, security and resilience of the grid; and enhancing the sharing of information regarding grid conditions,” the budget summary says.

The budget also formalizes Obama’s call for an Energy Security Trust Fund that would grow to $200 million per year to fund research into alternative transportation fuels; the budget envisions the fund receiving $60 million next year. The idea has some bipartisan support, but there is a split between the White House and congressional Republicans over whether additional coastal areas should be open to drilling in order to fund it, dampening its chances of becoming a reality.

Efficiency up, fossil energy down

DOE’s Office of Energy Efficiency and Renewable Energy would receive a substantial boost under the budget, growing to nearly $2.8 billion, a nearly 62 percent increase over its current, sequester-adjusted level of about $1.7 billion.

Some of the largest proposed increases are concentrated in EERE efforts to make buildings more efficient, develop cleaner vehicles and promote domestic manufacturing of clean energy products. Vehicle programs would grow to $575 million from an estimated $340 million in the current fiscal year. The advanced manufacturing program would grow to $365 million from $146 million. And EERE’s weatherization and intergovernmental activities account would grow to $248 million from $145 million under the budget.

Meanwhile, the Fossil Energy Research and Development program would see its budget fall to $420 million from its current level of about $470 million.

The fossil budget would boost funding for carbon capture — from an estimated $69 million in fiscal 2013 to $112 million for next year — while cutting the carbon storage budget from $115 million to $61 million. The only other fossil line item proposed to receive an increase is spending on natural gas technologies, which would grow from $15 million to $17 million.

The Energy Information Administration, which provides a wealth of data on energy commodity prices and supplies as well as projections of future trends, would see its budget set at $117 million, up from about $101 million currently.

Nuclear, Yucca Mountain

The administration’s request for nuclear power dipped to slightly more than $735 million, down from $771 million under current sequestered spending levels, and didn’t include a request for any new authority for loan guarantees for new nuclear projects.

The White House also asked for $70 million to support the licensing of small modular reactors, which the Obama administration hopes will bolster domestic job creation, cut carbon emissions and provide a solution for replacing aging coal-fired power plants. The funds would go toward the Energy Department’s five-year, $452 million total cost-share program aimed at licensing small modular reactors.

Congress appropriated $67 million for the grant program in fiscal 2012, and DOE asked for an additional $65 million in fiscal 2013.

The president’s budget proposes a number of reforms for how the government pays for storing and disposing of nuclear waste, an issue that’s triggered multimillion-dollar lawsuits against DOE. Although the White House asked for no money to continue working on the Yucca Mountain nuclear repository in Nevada, which Obama abandoned years ago, the budget did call for the establishment of a new program.

The proposed program, which would cost $5.6 billion during the first decade, would allow the government to tap into appropriated funds and the Nuclear Waste Fund, a pot of money utilities pay into for waste disposal. The program would be a “very long-term, flexible, multi-faceted approach to dispose of the nation’s commercial and defense waste” that assumes DOE is making progress on building and operating a pilot interim storage project, as well as a permanent repository.

The White House said the proposal is aimed at curbing a growing number of lawsuits against the federal government for failing to take waste from utilities that generate nuclear power. The government signed contracts in the 1980s to take the waste but failed to do so. “The sooner that legislation enables progress on implementing a nuclear waste management program, the lower the ultimate cost will be to the taxpayers,” the administration wrote.

The administration is seeking about $1 billion for the Nuclear Regulatory Commission, the bulk of which the agency would recover through fees from applicants that are seeking or hold licenses. The NRC did not seek additional funds to review the Yucca Mountain project. The agency is arguing in federal court that a lack of appropriated funds is preventing a review of DOE’s application to build the Nevada facility (Greenwire, March 28).

Funding for the Federal Energy Regulatory Commission would remain at about $305 million.

But the president’s budget proposal called for an investment of $153 million in research and development of “smart grid” technology to modernize the country’s aging electric grid, site and plan new power lines, and secure the system against cyberattacks. An additional $80 million would be directed to the Office of Energy Efficiency and Renewable Energy to help usher in more renewables onto the grid.

R&D

Obama’s proposed budget continues his strong support for clean energy research and development, focusing on accelerating breakthrough technology to the marketplace. Most funding requests remain at about the same level as Obama’s fiscal 2013 budget proposal.

“To compete in the 21st century economy and make America a magnet for jobs, the budget invests in American innovation, reviving our manufacturing base and keeping our Nation at the forefront of technological advancement,” a summary of the budget said.

The budget would advance the administration’s strong focus on innovation and R&D for advanced vehicles and biofuels. The budget would provide $575 million for advanced vehicles technologies, a 75 percent boost over the 2012 enacted level, including efforts to reduce the price of electric vehicles. Biofuels and biorefineries would receive a 42 percent increase to $282 million to develop and demonstrate conversion technologies to produce cellulosic ethanol and other advanced biofuels, such as algae-derived biofuels. Overall solar, wind and other renewable energy budget levels would each receive about a 50 percent budget increase from current enacted levels under the proposed budget.

Advanced manufacturing is an important focus of the Obama administration, and the budget would provide $365 million in overall DOE funding to expand innovative manufacturing processes and advanced industrial materials, plus an additional $5 billion in tax credits and a one-time $1 billion investment to launch a network of up to 15 manufacturing innovation institutes.

DOE’s agency charged with developing “game-changing” energy technology, the Advanced Research Projects Agency-Energy (ARPA-E), would receive $379 million under the proposed budget, a 35 percent increase from current levels under sequestration and slightly higher than last year’s administration request.

The Office of Science, the lead agency for fundamental scientific research for energy and the physical sciences, also would see a 5.7 percent increase to its budget from 2012 levels under sequestration to $5 billion. That is level with Obama’s fiscal 2013 request. The budget would boost research on all fronts, particularly for advanced computing and fusion energy with about 10 percent budget increases, but slightly cuts laboratory infrastructure. The budget also includes funding for new Energy Frontier Research Centers, which will undergo a recompetition of current grants in 2014, and Energy Innovation Hubs.

The budget would cancel the ultra-deepwater and unconventional natural gas and petroleum research fund again, although Congress continues to show support for the program.

Overall, Obama’s proposed budget would increase nondefense research and development investment by 9 percent above 2012 levels.

The budget would also make permanent important tax incentives for research and development, along with renewable energy and energy efficiency.

AEA Statement on White House Budget Proposal

President Barack Obama released his FY 2014 budget on Wednesday, a $3.77 trillion plan with a $744 billion deficit. AEA President Tom Pyle released the following statement in response to the energy provisions included in the White House budget:

“Now months overdue, President Obama’s budget represents the administration’s desire to double down on bad energy policy. The same week that the U.S. Comptroller General identified scores of fragmented, duplicative and wasteful renewable energy programs, the Obama budget calls for even more spending on these and other initiatives, including permanent taxpayer-funded subsidies for century-old industries like wind and solar. He continues his effort to incorporate punitive and discriminatory tax measures for oil and gas producers into the tax code, while renewing his effort to poach mineral royalties owed to U.S. taxpayers to fund his green energy schemes without opening new lands for exploration and development.

“Conspicuously absent from the White House budget is any mention of the Keystone XL pipeline. Now on a four-year delay despite numerous environmental impact studies and a new route that avoids sensitive areas, the failure to permit this critical infrastructure project is a daily reminder of the administration’s rejection of commonsense solutions to meet America’s energy needs.  Meanwhile, the President calls for fast-track permitting for renewables, ostensibly to hasten deployment of electricity generating facilities that don’t produce energy when Americans need it most. It’s a late budget full of lousy ideas, recycled to appear fresh and sensible in hopes that the American people will forget the failures of the past four years, higher gasoline prices, skyrocketing electricity rates, bankrupt renewable firms, and billions in wasted taxpayer money on politically connected industries.”

 

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In the Pipeline: 4/10/13

Now that would be a mandate we could all get behind. Denver Post (4/8/13) reports: “The officials from rural cooperatives and rural counties called the bill ‘a war on rural Colorado.’…’I own a bar. I’d like you to pass a law that everyone has to drink 25 percent more. Everyone is feathering their own nest,’ Moffat County Commissioner Tom Mathers said.” 

Homer 

 

Well gosh, we didn’t realize anyone was willing to have a reasonable debate about Keystone. Bloomberg (4/9/13) reports: “The evidence is so overwhelming that railroads are far less safe than pipelines, that it would be a serious mistake to use these recent spills to say that Keystone is unsafe,” he said. Brookings is a Washington-based nonprofit that says it supports economic and social welfare and a strong American democracy.

 

Maybe we’ve been wrong about Keystone. Maybe the Canadians really do deserve what the Obama crew has been giving them. International Climate Science Coalition (4/9/13) reports: “But promoting climate alarm in Canada’s most important trading partner, as Alberta Premier Alison Redford did this afternoon at the Washington DC-based Brookings Institute, is a public relations blunder of the first order.”…“The ultimate aim of climate activists is no less than to entirely terminate our use of hydrocarbon fuels such as coal, oil and natural gas,” explained Harris. “So, it is a disastrous strategy for a province that derives most of its income from those resources to support a movement that is trying to kill the market for the same resources.”

 

It makes you realize those ads for California tourism on TV are really just a pathetic, last-ditch effort to have a single positive trend in their economy. Daily Caller (4/9/13) reports: “A federal judge sided with environmental groups on Monday and ruled that the Obama administration wrongfully issued oil leases in Monterey County, Calif., by not considering the environmental impacts of hydraulic fracturing.”

 

No good way to put this: the Navy has given a star to the wrong man. Real Science (4/10/13) reports: “The military officer charged with monitoring North Korea at a time when the rogue nation is threatening to unleash missile attacks worldwide has used a Senate hearing to double down on his claim that it is global warming that is the real danger… Navy Adm. Samuel Locklear III originally caused a stir just weeks ago when in a speech to scholars at Harvard and Tufts universities in Cambridge, Mass., he said the climate change factor should be the focus of American concern.”

 

You heard him, folks. Start to budget for energy prices that are triple what they are now. And you can’t print and borrow your way out of this; those privileges are reserved for Beltway Royalty. ThinkProgress(4/8/13) reports: “If we start really squeezing down on carbon dioxide over the next few decades, well, that could double; it could eventually triple…. I think inevitably if we squeeze down on carbon, we squeeze up on the cost, it brings along with it a push toward efficiency; it brings along with it a push towards clean technologies in a conventional pollution sense; it brings along with it a push towards security. Because after all, the security issues revolve around carbon-bearing fuels.”

 

We run this under the assumption that you’re already seated in a safe place. GAO (4/9/13) reports: “We found that federal support for renewable energy is fragmented, as 23 agencies and their 130 subagencies implemented hundreds of initiatives in fiscal year 2010.5 We could not comprehensively assess the potential for overlap or duplication among these nearly 700 renewable energy initiatives, because existing agency information was not sufficiently complete to allow for such an assessment.”

 

Sally’s a boss. She puts crude oil on her Cheerios in the morning. However, we’ve yet to see the press release from Sierra Club announcing a “Beyond Jewells” campaign. 

Jewell_Hearing

In the Pipeline: 4/8/13

It must be stressful for President Obama to empathize with such a backwards way of thinking. WSJ (4/5/13) reports: “At the home of hedge-fund billionaire Thomas Steyer, Mr. Obama was at pains to explain how the proletariat think. “You may be concerned about the temperature of the planet, but it’s probably not rising to your number one concern,” Mr. Obama said. “And if people think, well, that’s shortsighted, that’s what happens when you’re struggling to get by.” In other words, it’s easier to reach a higher state of liberal consciousness when you can afford a home overlooking the Golden Gate Bridge.”

 

Who was it that the President said is shortsighted? Twitchy (4/5/13) reports: “Not even ABC News could overlook the obvious parallels between layoffs today at Fisker Automotive and another spectacular, high-profile failure of the Obama administration’s “green energy” push. Solyndra, which received a $535 million loan guarantee from the government, wasn’t a total loss; someone found a way to salvage the company’s inventory for an art exhibit. Fisker isn’t a museum piece yet, but things aren’t looking good.”

 

It is not just about natural gas. It is about manufacturing. It is about prosperity. It is about economic growth. Reuters (3/28/13) reports: “Such is the impact of the shale gas revolution in the United States that it’s quite possible that babies born today will no longer play with plastic dolls and cars made in China… It’s almost become a fait accompli that China is the world’s factory, but the early warning signs that this may be changing are starting to show.”

 

What’s really fun is that the masks worn by these eco-occupy-thugs are made from petrochemicals. We wonder what they’ll shield their cowardly lives with once they’ve rid the world of fossil fuels. National Review (4/4/13) reports: “In all my years of reporting on campus conflicts, this is the most appalling instance of political correctness I can recall. That students would advocate paying an articulate libertarian conservative not to speak on campus signifies the near-collapse of the ethos of classic liberal education. If Epstein’s views were as indefensible as Serio claims, questioning him in person would be precisely the way to expose that. Any way you slice it, students would learn from the talk. Yet Serio would prefer to spend thousands in student funds to prevent the dreaded Epstein from speaking.”

 

Yes, George, we should consider the impact of energy sources on human health and well-being. Like lifting billions of people out of poverty, lowering infant mortality rates, and increasing life-expectancy, thereby allowing people to advocate for nonsense like the carbon tax well into their 90’s. WSJ (4/7/13) reports: “We think this idea should be applied to energy producers. They all should bear the full costs of the use of the energy they provide. Most of these costs are included in what it takes to produce the energy in the first place, but they vary greatly in the price imposed on society by the pollution they emit and its impact on human health and well-being, the air we breathe and the climate we create. We should identify these costs and see that they are attributed to the form of energy that causes them.”

 

Here’s what you need to know about Bill Burton. First, he is very good at what he does. Second, he does nothing for free. All Risk No Reward (4/13) reports: “The cost-benefit analysis of this risky venture makes it clear that the pipeline is not in our national interest… The lengthy laundry list of risks—to water1, public health2, and climate3, not to mention the fine print4—is not worth a pipeline that exports oil to foreign countries like China and Venezuela, does nothing to reduce our dependence on Middle Eastern oil, and creates only 35 permanent jobs.”

 

Okay, so we know that wind and solar come up short, but how about Piezolectric Energy? ThinkProgress (4/7/13) reports: “People move. All the time. Wouldn’t it be great to harness that movement and help power our cities with the movement of people living in them? The Paris Marathon will happen on Sunday, and the organizers are going to lay down some special tiles across the course. While runners are concerned with charging their internal batteries with carbs and sustaining them with goo, their footsteps will charge other batteries:”

The Biofuel Mandate and EPA’s Costly Tall Tale

 

The Energy Policy Act of 2005 requires the Environmental Protection Agency (EPA) to set mandatory levels of cellulosic biofuel for refiners to blend into transportation fuels.  In order to restrain EPA, the law requires that the mandate be based on an estimate from the Energy Information Administration (EIA) as to how much cellulosic biofuel would be produced in the given year.

In 2010 and 2011, EPA mandated refiners to blend millions of gallon of cellulosic biofuel.  However, in both years, no cellulosic biofuel was produced.  Refiners were nevertheless forced to pay millions in penalties to EPA for failing to purchase the nonexistent fuel.

EPA set the cellulosic biofuel mandate for 2012 at 8.65 million gallons.  Unfortunately, by year’s end, only 20,000 gallons had actually been produced.  In January, the DC Circuit Court of Appeals struck down the 2012 mandate because the agency’s estimate was based, in part, on the their admitted “objective of promoting growth in the [biofuel] industry” instead of a neutral analysis of projected production.

Less than one week after the 2012 mandate was thrown out, EPA issued an even higher mandate for 2013 – 14 million gallons.  Despite its wildly inaccurate track record and the intervention of the DC Circuit, EPA seems unwilling to change its ways.

IER was the only free market public policy group to submit comments to EPA demanding that the agency reconsider this costly mandate.  Our full comment can be found here and is also reposted below:

2013 Renewable Fuel Standard: Cellulosic Biofuel

I.               Industry Statements Have Proven Untrustworthy For EPA’s Predictions

In the Proposed Rule, EPA states that its projection of cellulosic biofuel production in 2013 is based both on EIA’s estimate and “individual projections that emerged from” meetings with senior level representatives of companies involved in the process.[1]  While the biofuel industry may have confidence in its ability to produce 14 million gallons ethanol-equivalent of cellulosic biofuel, the actual results in 2010, 2011, and 2012 show that the industry’s statements have little or nothing to do with reality.

The two companies that EPA believes will produce cellulosic biofuel in 2013 – KiOR and INEOS Bio – have a history of making incorrect projections about their abilities to produce fuel.

INEOS Bio

In November 2011, Ethanol Producer Magazine conducted an interview with INEOS Bio CEO Peter Williams.  The article stated:

The project is on schedule and on budget so far, and if things continue to go as planned, the plant will be mechanically complete in April and will be continuously churning out waste-based ethanol by the second half of next year [2012].[2]

The facilities were not completed by April.  INEOS Bio did not issue a news release on the project until July 23rd, stating:

Construction of Ineos’ $130 million biorefinery joint venture project in the US has been completed, with production expected to begin in the second half of 2012, said Peter Williams, CEO of Ineos Bio, the Switzerland-based company’s bioenergy business.[3]

INEOS Bio did not produce any cellulosic ethanol in the second half of 2012.  In a subsequent news release on August 9, 2012, the company stated:

The Center is scheduled to begin production in the 3rd Quarter of this year.[4]

In an October 31, 2012 news release, INEOS Bio stated

Construction on the Center was completed in June 2012, and production of advanced cellulosic bioethanol is scheduled to begin in the 4th Quarter.[5]

As EPA is aware, INEOS Bio produced 0 gallons of cellulosic biofuel from it Florida plant in 2012.  As of the date of this comment, the company still has not produced any cellulosic biofuel in 2013.

KiOR

KiOR President and CEO stated on March 26, 2012 that

…we remain on target to meet our goal of first production in the second half of the year [2012].[6]

Mr. Cannon went further in a July 24, 2012 article in Biomass Magezine, stating KiOR

will be fueling cars of American consumers this year [2012].[7]

On a November 8, 2012 Earnings Call, Mr. Cannon announced that KiOR had “started production at the Columbus facility in October.”  He also stated

we are confident we will start commercial shipments from Columbus later this month.[8]

Even though KiOR is registered to issue RINs for the cellulosic biofuel it produces at its Columbus facility, EPA’s database shows that no cellulosic biofuel RINs were generated in November or December.[9]

Just last week, KiOR announced the first shipment of cellulosic biofuel from its Columbus facilities.  However, KiOR did not announce the quantity of the shipment in its news release or earnings call.

The statements of KiOR and INEOS Bio, as well as other companies in the cellulosic biofuel industry, have influenced EPA’s prior projections of production.  As the chart below shows, reliance on these types of statements has led to wildly inaccurate projections:

 

In fact, the closest EPA has ever come to successfully projecting the actual volume of cellulosic biofuel was in 2010 because that was EPA’s smallest projection.

Recommendation: IER recommends that EPA place very little weight on statements from the cellulosic biofuel industry, at least until the industry demonstrates that their statements are based on real-world data. Instead, EPA should incorporate previous year production levels as a basis for realistic projections.

II.              The First-of-a-Kind Technologies Being Used Are Not Yet Proven At Commercial Scale

As EPA is aware, many companies have produced cellulosic biofuels in the past.  The difficulty is with producing these fuels at a commercial scale.  No company in America has steadily produced cellulosic biofuel in commercial volumes, even though during World War I and II there were cellulosic ethanol plants in the United States.  KiOR and INEOS Bio are operating first-of-a-kind technology that has not yet been proven on a commercial scale.

If these facilities are unable to prove their proprietary process for commercial production, then they will produce far less cellulosic biofuel than their nameplate capacity.

The INEOS Bio facility was completed in June 2012 and began the start-up phase in November 2012.  Four months after start-up, the company still has not made a public announcement of any RIN generation at the facility or any commercial shipments of cellulosic biofuel.

Similarly, the KiOR facility was structurally completed in September 2012.  Despite the company’s statements that it would be shipping cellulosic biofuel by the end of 2012, KiOR just made its first announcement of shipped cellulosic biofuel.  However, the company has not revealed the quantity that was shipped and no RIN information is yet available.

EPA’s projection that both INEOS Bio and KiOR will be producing cellulosic biofuel at their respective facilities’ nameplate capacity by the end of 2013 is enormously aspirational, given that neither company has shown that their first-of-a-kind technology is capable of such a feat.  Until these companies show that their facilities are capable of producing at nameplate capacity, EPA seems to be relying solely on these companies’ advertising, not their proven capability.  As seen in Section I of this comment, these two companies have a history of being unable to produce fuel in accordance with their own public statements.

Recommendation: In order to allow time for the companies to prove their proprietary technologies, we recommend projecting that KiOR and INEOS Bio will not produce cellulosic ethanol in 2013 in commercial quantities.  Until these companies prove their technologies, EPA is making a risky assumption that they will work as planned.

III.            KiOR Has Made A Lower Projection Than EPA

EPA projects that in 2013 KiOR will produce 8 million ethanol-equivalent gallons of cellulosic biofuel, “which is about 5 million gallons of actual pure hydrocarbon fuel.”[10]  However, on its most recent earnings call on March 18, 2013, KiOR President and CEO Fred Cannon stated that “we believe our volume expectations to be approximately 3 to 5 million gallons for the balance of the year.”[11]

This revelation should inform EPA that its estimates are at the very highest end of the estimates made by KiOR itself, which has a history of public statements of overly-ambitious production levels.

Recommendation: In order to “reflect[] EPA’s best estimate of what will actually happen in 2013,”[12] EPA should revise downward KiOR’s projected production for 2013.

IV.          EIA Now Expects Only 5 Million Gallons of Cellulosic Biofuel Production

EPA based its projection, in part, on EIA’s estimate that 9.6 million gallons of cellulosic biofuel would be produced in 2013.  This projection was stated in a letter dated October 18, 2012.  The letter estimated that the KiOR plant alone would produce 5.5 million gallons of cellulosic biofuel, with the INEOS Bio facility producing an additional 4 million gallons.

However, in a February 26, 2013 memo, EIA stated that “output [of cellulosic biofuel] could grow to more than 5 million gallons in 2013.”[13]

EIA has apparently reduced its projection of cellulosic biofuel production that will occur in 2013 to approximately 5 million gallons.  Because EIA’s decreased production estimate comes four months after the initial projection to EPA, EIA must be taking into consideration more recent information.

Recommendation: EPA should use EIA’s most recent estimate as a basis to project how much cellulosic biofuel will actually be produced in 2013.  If EPA does not use this most recent estimate, EPA should at least consult with EIA to determine the reasons why it decreased its estimate.

Conclusion

EPA’s method of analysis has resulted in extremely inaccurate predictions for the past two years.  The Proposed Rule for 2013 mandates an amount of cellulosic biofuel that, once again, surely will not exist by the end of the year.

IER recommends that EPA set the mandated level of cellulosic biofuel at 20,000 gallons for 2013 so as to reflect the most recent proven capabilities of the domestic cellulosic biofuel industry and allow for time to show whether the first-of-a-kind technologies being used by KiOR and INEOS Bio are capable of producing cellulosic biofuel at a commercial scale.



[1] 78 Fed. Reg. 9290.

[2] http://ethanolproducer.com/articles/8327/outlook-2012-patience-is-a-virtue

[3] http://www.platts.com/RSSFeedDetailedNews/RSSFeed/Petrochemicals/8550137

[4] http://www.ineos.com/businesses/INEOS-Bio/News/~/INEOS-Bio-Facility-Receives-Registrations-from-US-EPA-for-Production-and-Sale-of-Next-Generation-Cellulosic-Ethanol1/

[5] http://www.ineos.com/businesses/INEOS-Bio/News/~/INEOS-Bio-Facility-in-Florida-Begins-Producing-Renewable-Power/?items=10&businesses=1428&year=&page=1

[6] http://www.biofuelsdigest.com/bdigest/2012/03/27/kior-on-budget-on-track-for-opening-first-commercial-biofuels-plant-in-2012/

[7] http://biomassmagazine.com/articles/7886/kior-renewable-gasoline-will-fuel-cars-this-year

[8] http://seekingalpha.com/article/992101-kior-s-ceo-discusses-q3-2012-results-earnings-call-transcript

[9] http://www.epa.gov/otaq/fuels/rfsdata/2012emts.htm

[10] http://seekingalpha.com/article/1283971-kior-s-ceo-discusses-q4-2012-results-earnings-call-transcript?part=single

[11] http://seekingalpha.com/article/1283971-kior-s-ceo-discusses-q4-2012-results-earnings-call-transcript?part=single

[12] 78 Fed. Reg. 9294.

[13] http://www.eia.gov/todayinenergy/detail.cfm?id=10131

Prepare for Higher Gas Prices

 

EPA Will Increase Gasoline Prices and Reduce Fuel Economy with Its Bid to Further Reduce Sulfur in Gasoline

The U.S. Environmental Protection Agency (EPA) has decided that the sulfur content of gasoline must be further reduced from 30 parts per million to 10 parts per million on an annual average basis by January 1, 2017.  This will bequeath to President Obama’s successor the immediate economic problem of higher gasoline prices for consumers upon assuming office. Refiners are currently meeting the Tier 2 vehicle standards that reduced sulfur in gasoline from 300 parts per million to 30 parts per million, a 90-percent reduction.  Refiners estimate that the proposed new rules will cost the American motorist as much as an additional 9 cents per gallon because it would require additional hydrotreating equipment to remove sulfur as well as revamps and expansions to existing hydrotreaters to achieve the reduction.

However, not only will the rule increase the price of gasoline, but it changes the “vehicle certification fuel” to E15 (gasoline that is 15 percent ethanol). This change will lead to lower fuel economy in automobiles and it will cause even more problems for small engines such as boat engines, lawn mowers and weed eaters.

Tier 2 and Proposed Tier 3 Vehicle Standards

In 1999, the EPA announced its Tier 2 regulatory framework, which tightened emission standards for the first time on all passenger vehicles, including light-duty trucks and SUVs. Also in 1999, EPA introduced the concept of treating “vehicles and fuels as a system.” As a result, the Tier 2 standards not only dealt with passenger vehicles, but also placed mandates on the refinery industry because certain emission reduction technologies work better with lower sulfur content in gasoline. The Tier 2 vehicle standards lowered the vehicle standard for sulfur in motor gasoline in stages down to an average of 30 parts per million with an absolute cap of 80 parts per million[i] in 2006, from a previous standard of 300 parts per million, a 90 percent reduction.

The EPA recently announced its next level of controls, called Tier 3, with sulfur levels down to 10 parts per million. EPA’s proposed Tier 3 standards would significantly tighten the constraints on both passenger vehicles and the refining sector. A study by Baker & O’Brien, a consulting company, finds that the new Tier 3 proposal would impose upfront compliance costs of almost $10 billion on the refinery industry, resulting in a permanent increase in refining costs of 6 to 9 cents per gallon of gasoline. It will also increase the cost of vehicles. Thus, the proposed Tier 3 standard would increase both the price of gasoline and the cost of buying a new car.

Further, it is unlikely that the increased costs that Tier 3 would impose on vehicle manufacturers and refiners would add much benefit to the environment. Existing regulations will continue to make improvements into the future without the need for more stringent Tier 3 constraints. Because the existing Tier 2 standards have achieved significant gains in lowering the sulfur content of gasoline, further reductions become exponentially more difficult to achieve while upping the cost of compliance that motorists would have to pay.

The Baker & O’Brien study modeled the tightening of gasoline sulfur standards and finds the upfront compliance costs to refiners at $9.8 billion with the total annual compliance cost, including capital recovery, to be $2.4 billion. Spread out over the range of projected gasoline production, the higher operating cost would add to 6 to 9 cents per gallon in increased gasoline costs for the American motorist.[ii]

According to the EPA, which solicited each refinery, 16 U.S. refineries would need a major overhaul, while 66 refineries would need modification to existing hydrotreating equipment.[iii] Unfortunately, for U.S. motorists, the United States does not have excess refinery capacity and major overhauls to existing refineries could result in higher prices if adequate capacity does not exist to replace supplies.

Environmental Implications

The sulfur in gasoline itself does not pose a public health problem. Rather, it lowers the effectiveness of catalytic converters, which in turn can lead to greater tailpipe emissions. These emissions (nitrogen oxides, volatile organic compounds, carbon monoxide and fine particles) contribute to smog and soot, which can cause respiratory and heart disease. However, according to the EPA, these pollutants have declined by 68 percent since 1970 due to actions already undertaken by refiners and utilities. (See graph below.)

Decline in Aggregate Emissions (Criteria Pollutants)

The Baker & O’Brien study also found that the additional energy-intensive hydrotreating required would result in an increase in carbon dioxide emissions due to the number of refineries running hydrotreating operations and the severity of the needed operations.

EPA claims that massive amounts (79 to 92 percent) of the benefits from this rule will come from particulate matter reductions. [iv] The problem with this claim is that it is based on EPA’s belief that over 40 percent of the deaths in parts of the United States between 1979 and 1983 were due to PM2.5[v]and 25 percent of all deaths nationwide were due to ambient PM2.5.[vi]  This finding by EPA strains credibility and cannot be replicated because EPA has refused to release the underlying databases (the “Cancer Prevention Study” and the “Harvard Six Cities Study”) to the public,[vii] even though these datasets were funded by the public. One of the tenets of science is replication of data, but this is impossible without EPA allowing the public access. The secret reports EPA has used to justify its regulatory agenda are increasingly gaining the attention of Congress, and demands are escalating for EPA to become more transparent with the documents it uses to regulate.

Fuel Economy Implications

One overlooked part of this proposed rule is that it changes the “vehicle certification fuel” to E15 (gasoline that is 15 percent ethanol). This is a stealthy way for EPA to get much more wide-spread adoption of E15 fuel at gas stations. Currently, EPA has approved E15 for cars of recent model years, but the automakers disagree and are worried that cars might have mechanical or other problems with E15 for which manufacturers will be liable. Despite ordering the fuel’s use, EPA would not pay for E15–related engine damages to consumers’ vehicles. By changing the vehicle certification fuel, new cars would be certified to run on E15, eliminating complaints from automakers.

But there are two major problems with this. First, E15 will contain less energy than current fuel because a gallon of gasoline contains 47 percent more energy than a gallon of ethanol (a gallon of ethanol has 76,100 BTUs, while a gallon of reformulated gasoline has 111,836 BTUs). Increasing the amount of ethanol reduces the energy and reduces fuel economy.  A second problem with E15 is that, as Consumer Reports has reported, ethanol in gasoline (E10) already causes problems for small engine owners. Increasing the amount of ethanol in motor fuel will further harm small engines.

Conclusion

EPA is again burdening consumers and the energy industry that makes their fuel with a new regulation when that industry is already struggling to meet other federal environmental requirements, including renewable fuel mandates. The new Tier 3 regulation is discretionary, not mandated, and its need has not been demonstrated. It will add to the cost of motor gasoline and add to the cost of a new vehicle at a time when the American public is awash in new taxes and regulations increasing the cost of living. With little or no excess refinery capacity, the American consumer is likely to see an upturn in gasoline prices as refineries undertake the retooling and then a permanent increase in the price of gasoline to pay for the additional equipment and increased cost of operation. To top it all off, the EPA has advocated the sale of fuel that may destroy consumers’ engines or lead to costly repairs.

According to Senator David Vitter, “The EPA again seeks to advance a political agenda, disregarding the facts and potential economic costs. The price of gasoline at the pump spiked upwards in the last few weeks, and EPA’s Tier 3 proposal – if implemented – could drive prices up even further without explanation.”[viii]

EPA is spending taxpayers’ dollars on an expensive and harmful new regulation justified with secret evidence they refuse to share with congress or the public, and they’re doing it not because the law requires them to do so, but because they want to.  The new regulation fails on many tests, including transparency and open government, and it uses a questionable cost benefit analysis.  Consumers, as with all EPA regulations, will pay higher prices for their fuel and their vehicles, making personal transportation just that much more expensive when President Obama’s successor is sworn into office.



[i] Fuel Fix, Feds to unveil new sulfur standard for gasoline, March 28, 2013, http://fuelfix.com/blog/2013/03/28/feds-to-unveil-tier-3-sulfur-standards-for-gasoline/

[ii] Baker & O’Brien, Addendum to Potential Supply and Cost Impacts Lower Sulfur, Lower RVP Gasoline, March 2012, http://api.org/news-and-media/news/newsitems/2012/mar-2012/~/media/Files/News/2012/12-March/Addendum-Potential-Impacts-of-Lower-Sulfur-Lower-RVP-Gasoline-Report.ashx

[iv] See Table 8-4: Estimated 2030 Monetized PM-and Ozone Related Health Benefits in the Regulatory Impact Analysis, http://www.epa.gov/otaq/documents/tier3/420d13002.pdf .

[v] Anne E. Smith, Technical Comments on the Regulatory Impact Analysis Supporting EPA’s Proposed Rule for Utility MACT and Revised NSPS (76 FR 24976), http://www.nera.com/nera-files/PUB_Smith_EPA_report_0811.pdf .

[vi] Anne E. Smith, Technical Comments on the Regulatory Impact Analysis Supporting EPA’s Proposed Rule for Utility MACT and Revised NSPS (76 FR 24976), http://www.nera.com/nera-files/PUB_Smith_EPA_report_0811.pdf.

[vii] See Sen. David Vitter & Rep. Lamar Smith, March 4, 2013 letter to the Honorable Gina McCarthy, http://science.house.gov/sites/republicans.science.house.gov/files/documents/EPA%20Ltr%20Smith%20Vitter%20Signed%203-4-13.pdf

[viii] U.S. Senate Committee on Environment and Public Works, Vitter, Bipartisan Group of Senators Oppose EPA’s Tier 3 Gasoline Regulations, February 4, 2013, http://epw.senate.gov/public/index.cfm?FuseAction=PressRoom.PressReleases&ContentRecord_id=a70c480c-ce1b-5ee7-430b-ae4f2e5230d9&CFID=47662043&CFTOKEN=51118700