This article will be focusing on the changes and decisions made by the Trump administration throughout his 4-year reign, focusing on the subject of Air. This includes partnerships, plans, rules, standards and targets relating to air quality in the United States.
The Trump Administration & Climate Change
Throughout the 4 year term that Donald J. Trump has held the position of President of the United States, he made a series of decisions that have significantly impacted the environmental integrity of the county, and a number of their national and global commitments.
Over the last 4 years, the Trump administration systematically dismantled a series of core environmental protections and policies, some of which have been in place for decades. Numerous experts agree that the manifestations of the climate crisis that have occurred over the past year in America have been minimal in relation to the catastrophes expected still to come. Even still, President Trump remained unconcerned about the enormous wildfires, devastating natural disasters, widespread water concerns, and persistent air pollution – which all also unequally impacted BIPOC communities. The administration has scrapped climate regulations, rolled back clean water rules, and loosened pollution standards. Additionally, protections for public lands and threatened or endangered species have been lessened, while new oil pipelines and coal mining processes have been encouraged.
In conjunction to the structural and legislative changes made by the Trump administration, Donald Trump has personally steered the conversation surrounding climate change and its associated impacts towards one rooted in disbelief.
On September 29, 2020, President Donald Trump and President-elect Joe Biden had their first presidential debate. After a history of dismissing climate change claims, when moderator Chris Wallace asked Trump about his beliefs in climate change science, the president had the following to say:
I want crystal clean water and air. I want beautiful clean air. We now have the lowest carbon, if you look at our numbers right now, we are doing phenomenally. But I have’t destroyed our businesses, our businesses are out out of commission. If you look at the Paris Accord, it was a disaster from our standpoint.
Donald Trump (2020)
While Donald Trump may believe that the United States has the lowest carbon levels, or that they are in fact, “doing phenomenally” when it comes to carbon emissions, he is only telling half the story. While the Trump administration may have experienced a small decline in the nation’s emission, his claim to have the “lowest carbon” is false by most measures of the term. The truth is that the United States’ data suggests that the country is polluting marginally less at present than when Trump came into power, which is a pretty low bar.
While America’s emissions may be in decline, they have declined at a slower pace during Trump’s term as president than when former president, Barack Obama was in the White House. As well, the country continues to be the world’s 2nd largest emitter, and the #1 historical emitter.
According to the US Energy Information Administration, America’s CO2 emissions in 2019 were the lowest they’ve been since 1992, with per capita emissions being lower in 2019 than they’ve been at any time since 1950. However, other figures are less impressive. America has historically been responsible for more CO2 emissions than any other country, having been the largest emitter between the mid-19th century and 2005, when it was surpassed by China.
At present, the United States is the 2nd biggest carbon polluter in absolute terms. Per capita, it is the 10th biggest polluter, with the average American emitting 16.56 tonnes of CO2 per year, over 2x as much as the average European, or 8x the average of someone living in India. However, these figures do not take into account the emissions embedded in traded goods; emissions from the production of goods which are made in China and consumed in America count towards China’s emissions tally. If the number were adjusted for emissions from consumption rather than production, the per capita gap between the United States and China would widen.
Throughout the 2 terms that Barack Obama was the President of the United States, CO2 emissions from burning fossil fuels and cement production was down by 11%. As well, the amount of coal used for primary energy production decreased by 38%, while renewable energy generation increased by 44%. CO2 emissions reportedly fell in 2017, then rebounded in 2018, before declining again in 2019. CO2 emissions are also expected to fall again in 2020, reflecting the reduction in economic activity relating to the pandemic. The International Energy Agency (IEA) stated that the 2019 reduction for America was mainly a result of coal being replaced by cleaner-burning fossil gas, as mild summer and winter seasons led to lower air conditioning and heating usage.
Kevin Kennedy of the World Resources Institute, stated that any emission reductions that occurred over the past few years were not a result of United States government policy or initiatives, but because coal is becoming increasingly uneconomic in comparison to gas and renewable energy. As well, there is a coalition of US states and cities called ‘We’re Still In’, continuing to take climate action in spite of Donald Trump.
“What we’ve been seeing from the Trump administration is very serious attempts to rollback the sorts of policies the Obama administration put in place, which are going to be incredibly important if we want to see serious emissions reductions continuing.”
KEVIN KENNEDY (2019)
The legacy of these changes will undoubtably stretch well beyond Trump’s presidency, well into the future. Some of the key rollbacks of the Trump reign relating to Air include the following:
The Paris Climate Agreement
After a 3-year delay, the United States has become the first nation in the world to formally withdraw from the Paris Climate Agreement. President Trump announced America’s withdrawal in June 2017, but UN regulations meant that the decision would not take effect until November 4, 2020. The United States has the option to re-join in the future, should a future President choose to do so – meaning that President-elect Joe Biden could choose to rejoin this global agreement.
The original agreement was drafted in 2015, and was signed by 197 countries, as a way to strengthen the global response to the ever increasing threat of climate change. The aim is to keep the global temperature rise this century well below 2C above pre-industrial levels and to pursue efforts to limit the temperature increase even further to 1.5C.
America’s withdrawal from the agreement is an abdication of American leadership on climate as the world’s largest historical greenhouse gas emitter. Having withdrawn, the country is now a ‘climate loner’ on the global stage (see Figure 3). This decision of removal has been condemned as a reckless failure of leadership by fellow signatories, environmental experts, and activists. However, one signatory is finding opportunity in America’s withdrawal – China. This is because China is legitimately interested in leading the world into the deployment and investment of renewable energy. China is presently the world’s largest producer of both wind and solar energy, and the largest investor in green energy initiatives. As of 2020, 5 of the world’s 6 largest solar manufacturing companies are located in China, in addition to the world’s largest wind turbine manufacturer. With a lack of American leadership, Beijing has the opportunity to dictate policies and standards in the transition to renewables.
Additionally, Russia did not miss an opportunity to criticize the White House on their removal from the agreement, stating that America’s withdrawal from the Paris Climate Accord seriously undermined the agreement. In 2019, Putin’s spokesman Dmitry Peskov stated, “without the largest economy in the world, it’s very, very hard to talk about any kind of climate agreement.”
Whatever Donald Trump believes about the climate agreement and about climate change in general, the majority of the world’s institutions, climate scientists, and professionals do not agree. The UNFCCC, Pentagon, NASA, and the World Bank have voiced their support for the science behind climate change. As well, the impacts of climate change has been illustrated throughout various states over the past few years. With a nonstop surge of severe storms, wildfires and hurricanes, 2020 has been a difficult year for weather in the United States. As of October 2020, there had been 16 separate weather disasters across the country, each causing approximately $1 billion in damages, according to the National Oceanic and Atmospheric Administration (NOAA).
As of October 7, 2020, there have been 16 weather/climate disaster events with losses exceeding $1 billion in the United States. These events have included 1 drought, 11 severe storms, 3 tropical cyclones, and 1 wildlife that resulted in the deaths of 188 people overall, with significant economic effects on the impacted areas. According to NOAA, the 1980-2019 annual average was 6.6. events; however the annual average for the past 5 years has been closer to 13.8 events.
The Clean Power Plan & the Affordable Clean Energy Rule
The Clean Power Plan (CPP) was the Obama administration’s defining climate rule. The rule was finalized in 2015, and directed states to reduce their electricity sector emissions. It aimed to slash carbon pollution from power plants by 32% from 2005 levels by 2030. Even though the Supreme Court halted the rule back in 2016, and States were never compelled to comply, carbon dioxide emissions from the US power sector still managed to fall by more than the rule’s goal – by at least 1/3. Cheaper natural gas and renewable power, in conjunction with local policies to move away from fossil fuels, sped the transition. However, despite this progress within electricity, Trump’s other rollbacks threaten to disrupt the United States’ overall pollution reduction targets.
The CPP was swiftly replaced when Donald Trump entered the White House. The Environmental Protection Agency (EPA) effectively repealed the policy and drafted a replacement policy in 2018, which according to the EPA’s own analysis, could result in 1,400 premature deaths from air pollution and $30 billion in health damages per year, in comparison with the original CPP. As well, the most dire effects are expected to be felt in the Midwest.
This new plan is called the Affordable Clean Energy (ACE) rule, and was issued to replace the Clean Power Plan in 2019 by the EPA. According to an EPA Press Office release on June 19, 2019, “Today, the U.S. Environmental Protection Agency (EPA) issued the final Affordable Clean Energy (ACE) rule – replacing the prior administration’s overreaching Clean Power Plan (CPP) with a rule that restores the rule of law and empowers states to continue to reduce emissions while providing affordable and reliable energy for all Americans.” While the CPP established state-specific targets for emissions reduction for the electric power sector, and required states to develop plans for achieving those targets, ACE takes a different approach. This new plan will direct states to set standards of performance for individual power plants, allowing them to decide how much to cut emissions.
These actions are difficult for many to understand, as the costs of wind and solar energy are falling, making it more cost-effective to close 3/4 of the country’s remaining coal plants, and replace them instead with a renewable power source. In order to defend this particular rollback, the Trump administration downplayed the adverse economic impacts of the. change by using flawed data analysis when assessing the damages climate change would cause the US. The EPA utilized mainstream economics when estimating the benefits of avoiding human-related climate change, while the original assessment accounted for the social cost of carbon by considering global damages. Transversely, the Trump administration chose to adopt a narrow, domestic lens – disregarding any other impacts. As well, this administration used higher discount rates to undervalue the cost to future generations.
Fuel Economy Standards
In 1975 the National Highway Traffic Safety Administration (NHTSA) in the Department of Transportation, has set the fuel efficiency standards for both cars and light trucks. In a different, but related process, the EPA has issued GHG emissions standards for vehicles since 2010. Since the federal government began setting national standards in the 1970s, the fuel efficiency of of vehicles has steadily improved, with the Obama administration taking it a step further by requiring that vehicles manage approximately 54 miles a gallon of fuel by 2025. This move was viewed as the biggest national rule to combat the climate crisis at the time, with transportation accounting for over 1/3 of America’s emissions.
However, with the Trump administration came changes to these newly implemented targets – weakening climate standards for new vehicles with Trump’s new fuel economy standards. Under this new rule, auto manufacturers will have to increase the average fuel economy of their vehicle fleets by 1.5% each year until their 2026 model year lineup, ultimately arriving at an average of approximately 40 miles per gallon (see Figure 7). Alternatively, under the previous rule, manufacturers had to increase the average fuel economy of their fleets by 5%, with the goal of hitting 54 miles per gallon in the 2026 model year vehicles.
Not only did the Trump administration scrap the rule, decreasing the standard back to 40 miles a gallon (see Figure 7), but also attempted to keep the state of California from setting their own, stricter standards. On September 19, 2019 the EPA and NHTSA released a final rule, the Safer Affordable Fuel-Efficient (SAFE) Vehicles Rules Part One: One National Program, which challenged California’s GHG standards and Zero Emissions Vehicle program. Both the NHTSA and the EPA proposed to treat California’s GHG standards as ‘preempted’ by the Energy Policy & Conservation Act (EPCA). EPA proposed the withdrawal of the waiver they granted to California in 2013 to implement its standards, by arguing that the standards preempted by the EPCA can’t be allowed a valid waiver under the Clean Air Act.
The EPCA governs the Corporate Average Fuel Economy (CAFE) standards, and preempts state laws or regulations relating to fuel economy standards or average fuel economy standards. Both NHTSA and EPA argue that California’s Advanced Clean Cars program regulations are related to fuel economy standards, and as thus, are preempted. Two federal courts decisions found no EPCA preemption of California’s standards – stating for differing reasons that the EPCA does not preempt California’s pollution standards, and that fuel economy standards can co-exist with pollution standards. Additionally, the Supreme Court has held that pollution standards and fuel economy standards are legally distinct, as they are aimed at fulfilling 2 different purposes, stating that there is no reason why the 2 agencies can’t both administer their obligations and avoid inconsistencies. The EPA and NHTSA continue to disagree with these rulings. To continue the argument, EPA and NHTSA stated California’s Advanced Clean Cars program:
- Conflicted with their past practices & legal determinations;
- Relied on novel interpretations of the legal limitations placed on the agencies & the state by the EPCA and the Clean Air Act;
- Required finding that 2 federal district court judges incorrectly interpreted EPCA, and the relationship with the standards adopted under both the EPCA and the Clean Air Act; and
- Raised questions about how NHTSA could alter course after historically adopting standards in conjunction with the EPA and California, and how the EPA can alter course after approving waivers for California’s vehicle standards after doing so for so many years.
Following months of lawsuits, complaints, and petitions, in May 2020, the following coalitions filed separate motions relating to the SAFE Vehicles Rule in the DC Circuit Court of Appeals:
- On May 27, 2020 California led a coalition of 23 states, cities & local entities in filing a challenge against SAFE;
- On May 27, 2020 a coalition of 12 environmental groups including the NRDC, Sierra Club & the Environmental Defence Fund filed for challenge against SAFE;
- On May 28 a coalition of power companies including Calpie, Consolidated Edison, National Grid USA, New York Power Authority, Power Companies Climate Coalition & the National Coalition for Advanced Transportation filed for challenge against SAFE; and
- On May 29, 2020 a group of 20 states, 2 cities, & 3 local air quality regulators requested to intervene in the case filed by the Competitive Enterprise Institute, in support for the EPA and NHTSA’s authority in fuel economy and GHG emission regulation.
The most recent update was on September 23, 2020 when California Governor, Gavin Newsom, signed an executive order directing California Air Resource Board to create regulations “requiring increasing volumes of new zero-emission vehicles sold in the State towards the target of 100% of in-state sales by 2035.”
Whether California can implement these regulations successfully in the future will depend on the outcome of the series of pending litigations, or hopefully will be easily remedied when the Biden administration takes office.
Toxic Air Pollution
In the United States, toxic air pollution regulation revolved around a rather complicated rule referred to as “once in, always in” or OIAI. The EPA first created the OIAI policy in 1995 as a way to close a loophole in the regulation of hazardous air pollutants (HAPs). The EPA regulates 187 HAPs (e.g. benzene, formaldehyde, and acroloein, which are strongly linked to cancer, respiratory illness, and other health issues. OIAI meant that once an industrial facility was determined to be a major source of HAPs, it would always be required to employ strong pollution control techniques through a measure called the Maximum Achievable Control Technology (MACT) to reduce HAP emissions. The requirement under OIAI was for MACT to reduce HAP emissions if they emitted more than 10 tonnes per year for a single hazardous chemical or 25 tonnes per year for combined hazardous chemicals known to have major health impacts.
MACT has been a very effective technique, with an estimated 70% of all major sources using MACT to emit at or below the 10 or 25 tonnes per year threshold for HAPs in 2014. Unfortunately, in 2018, the EPA withdrew the OIAI policy, allowing major sources to be reclassified as “area sources” if it can illustrate its potential to emit hazardous air pollutants falls below the standard. However, if a plant’s emission falls below the threshold for major sources, it doesn’t imply safe levels of emissions. The EPA stated that pollutants controlled by MACT are hazardous even in low concentrations. Instead, the thresholds are intended to classify larger and smaller emitters.
While area source are also required to meet pollution standards, they aren’t regulated or inspected as carefully as major sources. Since major sources aren’t required to use MACT, their pollution reduction will not be as effective; in fact, HAPs could increase for major sources that are reclassified as area sources. As well, reporting and monitoring requirements are also different for area sources, leaving many questions unanswered, and both the public and industry in the dark. Without establishing effective enforcement, pollution may be increasing, exposing people to unsafe levels of HAPs.
According to the Union of Concerned Scientists, most major sources subject to MACT controls could see their emissions increase significantly after the removal of the OIAI policy (see Figure 9).
Note: The size of the dot indicates the difference between that facility’s current emissions and the threshold of 25 tons per year, which represents the increase permitted by this rule change.
By dropping OIAI, the Trump administration’s EPA requires companies to innovate ways to decrease their emissions, but once lower their targets have been met, they are no longer required to continue utilizing those innovations. While this change in policy is meant to relieve a regulatory burden for facilities, the potential air quality implications are unknown.
Keep tuned for the next post in the series coming soon on the Trump administration’s impacts on the environmental progress that had been made in America prior to his inauguration in January 2017.
The Sustainable Switch 
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