To Landmark Legal Foundation re: Microwave, 'Social Cost of Carbon' (CO2) petition: On 9/20/13 EPA freely stated its ban on new coal plants will have no effect on CO2 emissions, page 346, Fed. Register

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Re: On 12/24/13, DOE rejected Landmark Legal Foundation's petition to reconsider Microwave Rule and "Social Cost of Carbon." (The word "carbon" refers to carbon dioxide, CO2, p.2):

1/2/14, "Social Cost of Carbon: DOE Rejects Petition to Reconsider Microwave Rule," GlobalWarming.org, Marlo Lewis (posted below)

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However, on 9/20/13 (pp 343, 346) the US government said its rule limiting CO2 emissions in new coal plants will have no effect on CO2 emissions. Doesn't this render meaningless or fraudulent its regulation of  "social cost of carbon" (CO2) if not all "carbon" regulation including the "microwave" rule?

Sept. 20, 2013, Environmental Protection Agency, “Standards of Performance for Greenhouse Gas Emissions from New Stationary Sources: Electric Utility Generating Units Proposed Rule.” Submitted “for publication in the Federal Register” (p. 1)

page 343, “X. “Impacts of the Proposed Action”
scroll to page 346, item E.:

E. “What are the economic and employment impacts?”

“The EPA does not anticipate that this proposed rule will
result in notable CO2 emission changes, energy impacts,
monetized benefits, costs, or economic impacts by 2022.
The owners of newly built electric generating units
will likely choose technologies that meet these standards
even in the absence of this proposal due to existing economic
conditions as normal business practice. Likewise, the EPA
believes this rule will not have any impacts on the price
of electricity, employment or labor markets, or the U.S. economy.

• F. What are the benefits of the proposed standards?

As previously stated, the EPA does not anticipate that the
power industry will incur compliance costs as a result of this
proposal and we do not anticipate any notable
CO2 emission changes resulting from the rule.
Therefore, there are no direct monetized climate
benefits in terms of CO2 emission reductions
associated with this rulemaking. However, by clarifying
that in the future, new coal-fired power plants will be
required to meet a particular performance standard, this
rulemaking reduces uncertainty and may enhance the prospects
for new coal-fired generation and the deployment of CCS,
and thereby promote energy diversity.” (end page 346)

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Marlo Lewis describes Landmark Legal Foundation petition about the Microwave Rule:

1/2/14, "Social Cost of Carbon: DOE Rejects Petition to Reconsider Microwave Rule," GlobalWarming.org, Marlo Lewis

"On Christmas eve, the Department of Energy (DOE) rejected the Landmark Legal Foundation’s petition to reconsider the agency’s final rule establishing first-ever energy-efficiency standards for microwave ovens.  

The final rule’s cost-benefit analysis incorporates the Obama administration’s revised (higher) 2013 social cost of carbon (SCC) estimates. Those estimates were not in the proposed rule, so the public had no opportunity to comment on them. In addition, LLF warns, with this “unilateral change,” all agency cost-benefit analyses “will be drastically affected,” potentially influencing administration policy on “everything from power plants to the Keystone XL pipeline.”

Whether or not the microwave rule itself has such wide-ranging implications, SCC analysis is a potent weapon in the war on coal and other fossil fuels. As a pretext for expanding government control of the economy, redistributing wealth, and rigging energy markets, nothing beats the social cost of carbon. 

The SCC (Social Cost of Carbon) is an estimate of damages allegedly inflicted on society by a ton of carbon dioxide (CO2) emissions in a given year. Ratchet up carbon’s estimated social cost by about 50%, as the administration did in 2013, and every mandated or proposed reduction in CO2 emissions suddenly appears to be 50% more valuable – i.e., 50% less costly....

Perhaps most importantly, DOE does not address the prior legal question: Where exactly in the Energy Policy Conservation Act, or any other statute, did Congress authorize the use of SCC analysis in regulatory development?...

SCC analysis is computer-aided sophistry. Its political function is to make uneconomic renewable energy look like a bargain at any price and make fossil energy look unaffordable no matter how cheap.

By fiddling with speculative inputs and discount rates, SCC analysts can get just about any result they desire. Raise the SCC estimate high enough, and it can appear to justify almost any carbon reduction scheme, however damaging to the economy or perilous to public health and welfare."...via Tom Nelson 

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Ed. note: Sorry if text from gov. pdf is choppy. I wasn't able to fix it to be more readable.