You're a savvy political appointee. You're bringing out a new regulation that will raise electricity rates all over the country, particularly in battleground states of Illinois, Ohio, Indiana, Florida and Michigan. What's your PR strategy?
You choose the Wednesday before Christmas, when most people aren't paying attention.
You schedule the announcement at a place designed to tug at the heartstrings, the National Children's Hospital in Washington, D.C. The hospital's CEO and the national volunteer chairman of the American Lung Association deliver remarks.
You say this costly initiative is for the children, and that millions of children will be protected. You talk about how 15 years ago your son spent his first Christmas in a hospital, suffering from asthma.
Of course, you say nothing about the costs. Your state-by-state interactive map shows benefits for each state, but no costs. (These you bury in a 510-page Regulatory Impact Analysis.)
And you throw in some job creation for good measure, 46,000 new construction jobs and 8,000 utility jobs -- without mentioning lost jobs from higher electricity rates.
Environmental Protection Agency Administrator Lisa Jackson is one smart politician, and that's what she did on Wednesday with the Mercury and Air Toxic Standards for Power Plants rule.
The MATS rule would restrict power plants' and boilers' emissions of heavy metals, including mercury, arsenic, chromium and nickel, and acid gases, such as hydrogen chloride and hydrogen fluoride.
This would make electricity generation far more complex and expensive, especially in the eastern half of the United States. It would require the closure of many coal and oil-fired power plants, and placement of emissions control equipment on others. Forty-five percent of American electricity is produced by coal.
Jackson's EPA estimates its new rules would cost households and businesses $10 billion a year in 2016. Benefits, calculated at $33 billion to $81 billion each year, starting from 2016, supposedly come from improvements in Americans' health, mostly from decreases in asthma.