The Human Cost of America’s Coal Revival
Nothing better captures the Trump administration’s energy strategy than the Environmental Protection Agency’s decision to assign zero value to human life in its regulatory analysis.
How the EPA Made Deaths Invisible
For decades, the EPA relied on the Value of a Statistical Life – approximately $11 million per premature death – to evaluate the benefits of clean air rules. This figure was not arbitrary. It was grounded in decades of peer-reviewed economic research and formed the backbone of modern air quality regulation. When pollution killed people, those deaths mattered.
They no longer do under current federal policy.
The EPA has not challenged the scientific consensus linking coal pollution to heart disease, lung disease, and premature death. Instead, it changed the accounting. By eliminating the monetized value of mortality in its analysis, the agency has made those deaths effectively invisible in federal decision making.
The accounting change is a callous enabler of a broader policy shift now remaking the U.S. power system.
Forcing Coal Plants to Stay Online
The administration, working through the EPA and the Department of Energy, is either forcing or coaxing aging coal plants to remain in operation, even when utilities had already scheduled them for retirement. To facilitate this the EPA is softening, delaying, or abandoning pollution controls that would otherwise raise the cost of operating older coal plants – rules governing fine particulate matter, ozone-forming emissions, mercury, and toxic coal ash.
The combined effect is not merely to permit the continued use of coal, but to actively subsidize it through regulatory retreat.
Blocking the Clean Energy Replacement
In parallel, the administration is blocking wind projects designed to replace coal capacity. While citing a need for greater grid reliability, these stop work orders, now held up by temporary court injunctions, are occurring through procedural maneuvering, often raising objections to previous government approvals based on unfounded national security concerns.
The opposition to expanding wind power projects seems to be driven by political and procedural resistance to wind development, rather than any legitimate grid-stability concern.
Taken together, the policy has the potential to modestly expand available power capacity, but does so replacing clean power with dirty power, and at substantial human cost. The policy contrasts with that of nearly all developed countries which embrace coal replacement and renewable expansion as energy policy priorities.
“The combined effect is not merely to permit the continued use of coal, but to actively subsidize it through regulatory retreat.”
The Human Cost
Under a conservative upper bound scenario in which 25 Gigawatts of coal capacity are extended rather than replaced by wind, other renewables, or natural gas, the health consequences are severe. Based on long-established relationships between coal generated emissions, fine particulate pollution, (PM2.5), ozone formation, and mortality, this outcome would cause an additional 3,000 to 7,000 pre-mature deaths annually. These deaths would fall disproportionately on older Americans, children, and communities downwind from coal facilities.
Under the administration’s full policy intent – effectively restoring 38 Gigawatts of coal capacity – the impacts scale accordingly. At that level, the additional pollution burden could kill 5,000 to more than 10,000 Americans each year.
These are precisely the harms the EPA’s prior analytical framework was designed to capture – and that the agency has now chosen to ignore.
Climate Toll
The climate consequences are equally stark. Coal plants emit far more CO2 per unit of electricity than wind or solar. Keeping 25 Gigawatts of coal plants online, especially older plants operating in an accommodative regulatory regime, instead of replacing them with wind would add on the order of 100 million metric tons of CO2 per year. Restoring the full 38 Gigawatt capacity would push that figure closer to 150 million tons annually – similar to that of a mid-sized industrial country.
Using the government’s own Social Cost of Carbon – which ranges from $60 to more than $190 per ton of CO2, depending upon assumptions – this translates to $6.5 to $28 billion per year in additional climate damages under the upper bound scenario, and $10 to $40 billion annually under the full restoration. Social Cost of Carbon measures global damages thus some of these costs will be borne outside the United States. But the illness and premature deaths caused by air pollution will not.
An Accounting Trick with Deadly Consequences
The EPA’s decision to zero out the value of life evidences a deeply flawed policy. By eliminating mortality and health costs in its analysis, the EPA ensures that extending coal operations appears inexpensive on paper – even when devastating in reality. It lowers the apparent cost of pollution, weakens the justification for clean-energy deployment, and clears a path for precisely the outcome now unfolding.
The human costs of air pollution are real, as are the costs of climate change. Americans will pay them – in lives, in health, and from damages due to a climate made far more dangerous by a government that ignores them.
Cliff Griep
Board Member, FFI Solutions
