June 10, 2019 9:17AM

EPA Co‐​benefits Are Fine, But the Agency Must Tell the Whole Story

Should you be worried about mercury emitted from power plants?

Sure, but only if you are a pregnant woman, who during gestation consumes about 220 pounds of fish caught from exclusively the top ten percent most polluted fresh waters of the United States, despite all the signs along these rivers and lakes warning “DO NOT EAT THE FISH!

Don’t take my word for it. I’m simply relaying EPA science. And not the ‘bad” kind produced by the Trump administration; rather, I’m talking about virtuous EPA science as practiced by the Obama administration.

A little background: mercury emissions aren’t a direct threat to humans, but instead settle onto water bodies, and then make their way up the aquatic food chain. Because mercury is a neurotoxin, the fear is that pregnant women can engender developmental disorders in their offspring by eating fish that have bio-accumulated the toxin.

In the course of promulgating the Obama-era Mercury and Air Toxics Standards for power plants, the EPA stated that it considers “IQ loss estimates of 1-2 points as being clearly of public health significance,” even though this low a number rests comfortably within the error of measurement inherent to an IQ test. According to the EPA’s analysis, the Mercury Rule was necessary to prevent an IQ loss of 1.1 points supposedly suffered by children born to a putative population of pregnant women from substance families, who during their pregnancies eat 220 pounds of self-caught fish reeled in from the most polluted bodies of fresh water. Notably, the EPA failed to identify a single member of this supposed population. Instead, these women were modeled to exist.

Even under EPA’s ultra-accommodating analysis of its rules’ benefits, the agency pegged the benefits of the Mercury Rule at a mere $6 million. In stark contrast, the agency estimated that the rule would cost about $10 billion annually, making it one of the most expensive regulations ever.

On its face, such an imbalanced cost-benefit ratio is plainly unreasonable. But the EPA pointed to the rule’s “co-benefits,” which were estimated to be dwarf the rule’s costs.

So, what are these “co-benefits”?

Retrofitted air pollution controls employ either a filter or a chemical reaction to capture pollutants from the power plant exhaust flue. Though these controls are optimized for the specific pollutants they are designed to reduce, other pollutants also are captured. With the Mercury Rule, the EPA claimed that “co-benefits” attendant to the required mercury controls would amount to $37 billion annually.

On the one hand, I agree with Prof. Cass Sunstein, who has argued that it would be foolish to ignore readily evident costs and benefits, regardless whether they are direct or indirect. On the other hand, there’s an element of duplicity behind the EPA’s co-benefits, to which I object.

Co-benefit pollutants are known as “criteria pollutants,” and they are regulated by the Clean Air Act. Indeed, criteria pollutants are regulated at a level that is “requisite to protect the public health” with “an adequate margin of safety.” That is, these pollutants are regulated by an entire statutory program at standards that go beyond what is necessary to protect public health.

The EPA, moreover, is not allowed to consider costs when it regulates “criteria” pollutants. It is somewhat ironic that the agency is attributing billions of dollars worth of benefits to the reduction of a pollutant beyond stringent public health limits set by EPA without considering costs.

The other problem with EPA’s “co-benefits” is the likelihood of double-counting. Since the George W. Bush administration, the EPA has justified most of its major rules by relying on “co-benefits.” Yet the agency isn’t keeping a running tab of its claimed “co-benefits.” As a result, it’s almost certain that the agency has counted the same benefits twice or more.   

Recently, EPA Administrator Andrew Wheeler initiated reforms regarding the agency’s use of of costs and benefits in the rule-making process. While there’s no reason for the agency to categorically ban the use of co-benefits, the EPA should render their use reasonable. To this end, the EPA should refine its analysis to account for doubly-counted co-benefits. The agency also must inform the public how much of the co-benefits valuation can be ascribed to pollution reductions below a level that the agency already had determined to be “requisite to protect the public health” with “an adequate margin of safety.”

July 11, 2018 5:12PM

Climate Change: What Would Kavanaugh Do?

In a 2012 dissent from a District of Columbia Appellate Court opinion, Supreme Court nominee Brett Kavanaugh acknowledged that “dealing with global warming is urgent and important” but that any sweeping regulatory program would require an act of Congress:

But as in so many cases, the question here is: Who Decides? The short answer is that Congress (with the President) sets the policy through statutes, agencies implement that policy within statutory limits, and courts in justiciable cases ensure that agencies stay within the statutory limits set by Congress.

Here he sounds much like the late justice Antonin Scalia, speaking for the majority in the 2014 case Utility Air Regulatory Group v. EPA:

When an agency claims to discover in a long-extant statute an unheralded power to regulate “a significant portion of the American economy” we [the Court] typically greet its announcement with a measure of skepticism.  We expect Congress to speak clearly if it wishes to assign to an agency decisions of vast “economic and political significance.”

Scalia held this opinion so strongly that, in his last public judicial act, he wrote the order (passed 5-4) to stay the Obama Administration’s sweeping “Clean Power Plan.” Such actions occur when it appears the court is likely to vote in a similar fashion in a related case.

This all devolves to the 2007 landmark ruling, 5-4, in Massachusetts v. EPA, that the EPA indeed was empowered by the 1990 Clean Air Act Amendments to regulate emissions of carbon dioxide if the agency found that they endangered human health and welfare (which they subsequently did, in 2009). Justice Kennedy, Kavanaugh’s predecessor, voted with the majority.

Will Kavanaugh have a chance to reverse that vote? That depends on what the new Acting Administrator of the EPA plans to do about carbon dioxide emissions. If the agency simply stops any regulation of carbon dioxide, there will surely be some type of petition to compel the agency to continue regulation because of the 2009 endangerment finding. Alternatively, those already opposed to it might petition based upon the notion that the science has changed markedly since 2009, with increasing evidence that the computer models that were the sole basis for the finding have demonstrably overestimated warming in the current era. It’s also possible that Congress could compel EPA to reconsider its finding, and that a watered-down version might find itself at the center of a court-adjudicated policy fight.

Whatever happens, though, it is clear that Brett Kavanaugh clearly prefers Congressional statutes to agency fiat. Assuming that he is confirmed, he will surely exert his presence and preferences on the Court, including that global warming is “urgent and important,” but it is the job of Congress to define the regulatory statutes.

March 2, 2017 2:27PM

How Does One Justify One of the Most Expensive Regulations in American History?

In an effort to justify its massive global warming regulations, the Obama Administration had to estimate how much global warming would cost, and therefore how much money their plans would “save.” This is called the “social cost of carbon” (SCC). Calculating the SCC requires knowledge of how much it will warm as well as the net effects of that warming. Needless to say, the more it warms, the more it costs, justifying the greatest regulations. 

Obviously this is a gargantuan task requiring expertise a large number of agencies and cabinet departments. Consequently, the Administration cobbled a large “Interagency Working Group” (IWG) that ran three combination climate and economic models. A reliable cost estimate requires a confident understanding of both future climate and economic conditions. The Obama Administration decided it could calculate this to the year 2300, a complete fantasy when it comes to the way the world produces and consumes energy. It’s an easy demonstration that we have a hard enough time getting the next 15 years right, let alone the next 300.

Consider the case of domestic natural gas. In 2001, everyone knew that we were running out. A person who opined that we actually would soon be able to exploit hundreds of years’ worth, simply by smashing rocks underlying vast areas of the country, would have been laughed out of polite company. But the previous Administration thought it could tell us the energy technology of 2300. As a thought experiment, could anyone in 1717 foresee cars (maybe), nuclear fission (nope), or the internet (never)? 

On the climate side alone, there’s obviously some range of expected warming, often expressed as the probabilities surrounding some “equilibrium climate sensitivity” (ECS), or the mean amount of warming ultimately predicted for a doubling of atmospheric carbon dioxide. In the UN’s last (2013) climate compendium, their 100+ computer runs calculated an average of 3.2°C (5.8°F). A rough rule of thumb would be that this is also an estimate of the total temperature change predicted from the late 20th century to the year 2100.

That forecast is simply not working out. Since 1979, when global temperature-sensing satellites became operational, both satellite and weather balloon data show that the lower atmosphere is warming at about half the rate that was predicted. And in the area that is supposed to show the most integrated warming, in the tropics from about 15,000 to 45,000 feet, there’s two to three times less warming being observed than would be “forecast” by the UN’s models if they are run backwards from today. At the top of the active weather zone there, the forecast warming is a stunning seven times more than has been observed.

Since around the time that the last UN report was being written, a spate of scientific papers has been published showing that the ECS is quite a bit lower than the UN’s number, by 40-60 percent, depending upon the study.

It seems like there’s quite a conspiracy of nature when it comes to observed versus predicted warming, with various measures all telling us that we’re seeing about half as much warming as we are supposed to in the bulk atmosphere. Further, the Obama Administration assumed a distribution of possible warming that was way to hot at the extreme end, 7. 1°C or 12.9°F, a number that Science magazine recently said was “implausibly high” in a different model.

On the economic side, how much something will cost by the year 2300 requires some estimate of economic growth between now and then. It’s called the discount rate, and there are actually guidelines for how to do this put out in 2003 by the Office of Management and Budget. The higher the discount rate, the less that warming costs that far out into the future. OMB says that “you should provide estimates of net benefits using both 3 percent and 7 percent.”

(Understanding discount rates: Imagine someone is going to give you $100 today (which you can invest), or a year from now, when that original $100 hasn’t been able to “work” for a year. If you’re OK either with $100 today, or $105 a year from now, your discount rate is 5 percent; you’re really expecting that much macroeconomic growth in a year. Over the long haul, average inflation-adjusted returns on equity investments are around the OMB’s 7 percent.)

The latter figure drove the cost of warming down too far for the Obama Administration’s liking, and the cost actually went below zero assuming 7 percent and an ECS not far from what may be the most realistic value. That means it could be a net benefit, something the Netherlands’s Richard Tol has been saying for decades, as long as it doesn’t warm too much. The Administration wouldn’t go near that, so, in contravention of the OMB guidance, they simply did not use the 7 percent rate, as Kevin Dayaratna of the Heritage Foundation notes.  

For more information on the social cost of carbon, take a look at my testimony from earlier this week before the House subcommittees on the environment and on oversight. A lot came to light in the hearing, which will go a long way towards an EPA justification to cease and desist on its onerous Clean Power Plan and other Obama Administration climate regulations. 

December 30, 2016 11:11AM

You Ought to Have a Look: Panic Among Alarmists

You Ought to Have a Look is a regular feature from the Center for the Study of Science. While this section will feature all of the areas of interest that we are emphasizing, the prominence of the climate issue is driving a tremendous amount of web traffic. Here we post a few of the best in recent days, along with our color commentary.

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As the time towards Trump’s inauguration closes, panic mounts in the climate change-agenda community as evinced by their hyperventilation about what a Trump Administration might unleash on President Obama’s Climate Action Plan. This includes ventilation about blocking access to climate data, data manipulation, investigating climate scientists, squashing dissent, selective science, end runs around Congressional intent, etc...sort of like a catalog of what they have been doing since climate change went prime time in 1988.

Many of these bloviations are completely unfounded—for example, a particular favorite of the press during recent weeks has been that “Scientists [are] Rac[ing] To Preserve Climate Change Data Before Trump Takes Office.” This is nonsense—despite the hand-wringing and (faux) concern raised by some folks. And while we, like everyone else should be, are opposed to deleting government datasets (paid for with our tax dollars), there is simply no evidence that such an action is in the works or even being contemplated.

Many of the other fears are overblown as well, but there are, in fact, some things that should bother climate campaigners (and no one else). These include efforts to retract the Clean Power Plan, to eliminate the use of the social cost of carbon as currently constituted in federal cost/benefit analyses, and acknowledgement the current generation of climate models has no utility with regard to policy.

Together these actions would go a long way to dismantling much of the overreaction inherent in Obama’s Climate Action Plan and also form a strong case for reversing the EPA’s “endangerment finding” for carbon dioxide. Should any/all of this come to pass, the climate campaigners will go bonkers, while the rest of us will be freed from burdensome regulations and have greater economic ability to address/adapt to what climate changes may come our way.

Here’s what’s afoot. First is well-designed dismantling of Obama’s Clean Power Plan, described in a letter sent to Mike Pence, Paul Ryan, and Mitch McConnell (and copied to Myron Ebell, head of Trump’s EPA transition team), by a coalition of 24 state Attorneys General. It builds upon their belief that the Clean Power Plan goes far beyond what is allowed under the Clean Air Act and that it unlawfully commands states to “fundamentally alter electricity generation in their States by shifting from existing fossil-fueled power plants to other methods of generation preferred by EPA.”

Basically, the plan that they’d like to see President Trump put into motion starts with an immediate executive order making it clear that “it is the Administration's view that the Rule is unlawful and that EPA lacks authority to enforce it.” From there, they’d like the Trump Administration to work closely with the States on ways to withdraw the rule and with Congress to make sure that no such rule gets promulgated in the future, i.e., that any “legislation should recognize the rights of States to develop their own energy strategies, so that energy can be generated in a cost effective and environmentally responsible manner.”

This course of action sounds a lot like the strategy that David Rivkin Jr. and Cato Adjunct Scholar Andrew Grossman laid out in an op-ed published in the Wall Street Journal two weeks after Trump was elected. It will be good to see their sound advice taken to heart and put into action.

Next up are signs that federal government’s love affair with the social cost of carbon is going to come to an abrupt and welcome end. The social cost of carbon, or SCC, is the Obama Administration’s determination of the monetary cost (tallied as the modelled damages resulting from climate changes that occurs between now and the year 2300) from every new ton of carbon dioxide that is emitted by human activities. Yes, not only does this sound ludicrous, but you can come up with nearly any number you want (including negative values—which indicate a net benefit from carbon dioxide emissions) based on how you treat certain parameters—like the future discount rate, the climate sensitivity, global vs. domestic impacts, the damage functions, adaptations, etc. Currently, in 2015 dollars, the Obama Administration’s SCC is about $40/ton. Alternative calculations produce numbers that range from near zero to several hundreds of dollars—basically, anybody’s guess.

But, while you may think that this huge uncertainty would pretty much render reliance on the SCC in federal rulemaking moot—you’d be wrong. In fact, just the opposite is the case—the Obama Administration requires the inclusion of its determination of the SCC in all cost/benefits analyses for federal decision-making that may result carbon dioxide emissions (which is nearly everything).

We have been strongly pushing back against this practice for several years now through all avenues available to us, and it now seems that the Trump Administration will take much of what we have written into consideration.

A recent article in Bloomberg explores many of the problems with the SCC and the avenues that the new Administration would have to defang the SCC. You ought to have a look.

And to this, we add an avenue that was not explored in the Bloomberg article, but which was discussed in a recent Vox article about the White House Office of Information and Regulatory Affairs (OIRA). According to Jody Freeman, a former climate advisor to President Obama:

OIRA is the location in the White House where they oversee agency rulemaking. This office oversees the methodology that agencies use to count up costs and benefits for new rules. That can be changed with the stroke of a pen. And it sounds weedy, but it’s the kind of thing that can make it harder to issue new regulations.

So for instance, right now the Obama administration currently uses a “global social cost of carbon” for its climate rules — that means if you have any rule that reduces greenhouse gases, the benefits counted for that rule include the [climate] benefits globally. You could imagine a Trump OIRA saying, “We don’t want to do that anymore. We’re not going to count the social cost of carbon as a benefit.” That changes the calculus for which rules are cost-beneficial.

This seems intriguing—we really ought to have more of a look!

And finally, the grand prize of all would be overturning the EPA’s finding that greenhouse gases “endanger both the public health and the public welfare of current and future generations.” From this “endangerment finding” stems the EPA’s imperative to regulate carbon dioxide emissions and unleashes all manner of regulations large and small. 

There are many approaches that a Trump Administration can take. They could convince Congress to act by explicitly stating that regulating carbon dioxide is not within the purview of the Clean Air Act. Alternatively, the EPA could overturn its own endangerment finding, which, according to the Supreme Court, compels the agency to regulate carbon dioxide.

The EPA has just been handed a loaded gun to accomplish just that.

It is all laid out in a forthcoming paper in the Bulletin of the American Meteorological Society that was released online in August. The paper “The art and science of climate model tuning” is written by Frederic Hourdin and 15 co-authors. It details the phenomenal amount of adjustment that has been applied to the GCMs in order to get them to simulate the 20th Century or just the present climate. 

Recently, it was summarized by Paul Voosen in Science, who said the modelers have heretofore have clammed up about all of this, fearing when it became public, “skeptics” would have a field day. Specifically, he wrote this doozey:

For years, climate scientists had been mum in public about their “secret sauce”: What happened in the models stayed in the models. The taboo reflected fears that climate contrarians would use the practice of tuning to seed doubt about models—and, by extension, the reality of human driven warming.

Yes, in fact, we will. And we should, with the caveat that carbon dioxide does cause some warming, but far, far less than what is in these models.

What comes out of the paper is that each fiddling of the models—which includes adjusting everything from the earth’s reflectivity to the mixing of heat in the ocean—gives a different answer for how much the earth will warm for doubling atmospheric carbon dioxide. 

This figure, known as the “equilibrium climate sensitivity” (ECS) is the bottom line when it comes to climate change. If it can be moved to any value depending upon the “tuning” of the model, then it is the modeler and not the physics that decides this critical number. Hourdin et al. put it rather artfully when they said, that it’s important when fiddling with the models to keep the ECS within an “anticipated acceptable range.”

What’s “acceptable” is therefore entirely subjective and, outside of ridiculous values that don’t comport with reality (such as one that would imply a greenhouse runaway), we are now regulating carbon dioxide by arbitrary caprice. That knowledge dooms EPA’s Endangerment Finding.

The Endangerment Finding is itself based upon a massive compendium, EPA’s “Technical Support Document,” which is a literature review of the causes and effects of global warming based, of course, on the GCMs. There is nothing to keep the EPA from modifying that document with this new (and universal) finding, and concluding that the technical support for an Endangerment Finding no longer exists.

Our greener friends will take that to court, to absolutely no avail. Courts do not intervene over the scientific determinations of agencies, a doctrine called “Chevron Deference” to their technical expertise. This was originally decided in the 1984 Supreme Court case Chevron, Inc. v. Natural Resources Defense Council

Georgia Tech atmospheric scientist Judy Curry wrote this about the Hourdin paper:

“If ever in your life you are to read one paper on climate modeling, this is the paper that you should read. Besides being a very important paper, it is very well written and readable by a non-specialist audience.”

We agree completely.

November 11, 2016 5:36PM

Some Climate Realities for the Incoming Administration to Consider

While the twitterverse is chirping with concern over Donald Trump’s handling of the global warming science, we offer a few realities that should be key parts of any transitional team’s synthesis.

1. Carbon dioxide is a greenhouse gas that by itself will result in a slight warming of the lower atmosphere and surface temperatures, as well as a cooling of the stratosphere.

     a. All of these have been observed.

 2. Additional warming is provided by a complicated feedback with water vapor. If it were large and positive, so would be future warming.

     a. The observed warming is far below values consistent with a high temperature sensitivity. Therefore future warming will run considerably below any high-sensitivity estimate.

     b. The disparity between observed and forecast warming continues to grow.

3. Any attempts to mitigate significant future warming with the current suite of politically acceptable technologies are doomed to failure. The Paris Agreement, according the EPA’s own models, only prevents 0.1 to 0.2⁰C of warming by 2100.

     a. The Paris Agreement is meaningless, unenforceable, and compels developed nations to tender funds to the developing world. That makes it a treaty that should be submitted to the Senate for ratification, where it will be soundly rejected.

4. Having the government mandate politically correct and inefficient technologies such as solar energy and wind inevitably squanders resources that would better be used for investments in a much more efficient future. Unfortunately, this is what President Obama’s Clean Power Plan does.

     a. Voiding the Clean Power Plan will therefore ultimately lead more quickly to competitive, more efficient technologies.

5. Affluent societies have the resources for private investment in novel and efficient technologies, and inevitably are more protective of their environment than are poor ones.

     a. Environmental protection is a priority in a vibrant economy. Promoting economic development is the key to a cleaner planet.

6. There is no evidence that government funding of most science is better than a more diversified base of private support. The current dependency of the academy on this funding is creating perverse incentives that are demonstrably harming science.

     a. All government-funded science outside of the clandestine realm must be perfectly transparent with data, research methods and results available to any party.

We’ve recently taken a look to see how these comport with the views of Myron Ebell of the Competitive Enterprise Institute, who was recently named to head the transitional team for the new administration’s EPA. We think he agrees with this us on this synthesis—something no one ever in any previous administration has done!

November 11, 2016 5:33PM

You Ought to Have a Look: Advice for Trump’s Transition Team

You Ought to Have a Look is a regular feature from the Center for the Study of Science.  While this section will feature all of the areas of interest that we are emphasizing, the prominence of the climate issue is driving a tremendous amount of web traffic.  Here we post a few of the best in recent days, along with our color commentary.

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In this You Ought to Have a Look, we hope that some of the “You” are members of, or influencers of, President-elect Trump’s transition teams.

With so much talk about the Trump’s plans on killing the Clean Power Plan, withdrawing from the Paris Climate Agreement, reversing the Keystone XL pipeline rejection, removing energy subsidies and reigning in the EPA (all good ideas in our opinion), we want to make sure the transition team doesn’t overlook other, invasive, burdensome, costly, and climatologically-meaningless regulations that were put in place in President Obama’s Climate Action Plan.

Here’s a rundown of some of the more significant of them.

Energy Efficiency Regulations from the Department of Energy. 

The DoE and put forth a seemingly endless string of regulations governing the energy efficiency of all manner of power-consuming appliances large and small, from industrial boilers and refrigeration systems, to microwave ovens, and ceiling fans (and most things in between). The reason?

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We have repeatedly submitted public comments as to why the climate change angle should be a non-starter (our latest in this long line is here). But besides that, the DoE standards result in appliances that work less well, cost more, and reduce consumer choice. Our big brother government thinks it’s doing us all a favor because we aren’t savvy enough to value long-term cost saving from energy consumption over other values. Not everyone agrees. Sofie Miller, senior policy analyst at the George Washington University Regulatory Studies Center, recently wrote:

This line of reasoning overlooks the possibility that consumers may have legitimate preferences for less-efficient appliances based on household characteristics or other observable product qualities (such as size, durability, reliability, or noise level). Also, the assumptions underpinning the DOE’s analyses may not be accurate; for instance, some consumers may have high discount rates, making future energy savings less important than immediate purchase savings. By regulating away the option for consumers to purchase less efficient appliances, the DOE claims to be improving consumers’ choice structure by removing choices. These rules aren’t technology-forcing, they’re consumer-forcing.

…the fact that consumers choose not to purchase efficient appliances indicates only that they do not value these attributes as much as the DOE does. As a result, these rules impose huge net costs on consumers, rather than benefits.

Yet the DoE has a lot more of these efficiency standard regulations in the offing (the public comment period is currently open for two more proposed regulations—governing walk-in refrigerators and residential furnaces).

One member of Congress, Representative Michael Burgess (R-TX) has previously sponsored legislation aimed at striking “all government-mandated energy efficiency standards currently required on a variety of consumer products found in millions of American homes.”

We suggest that similar efforts—either taking place within the DoE or through Congressional action—be pursued by the incoming Administration.

Greenhouse Gas Emissions Assessments Required Under the National Environmental Policy Act

According to the EPA, the National Environmental Policy Act of 1970 (NEPA), directs that:

 “all branches of government give proper consideration to the environment prior to undertaking any major federal action that significantly affects the environment.” 

And that:

“NEPA requirements are invoked when airports, buildings, military complexes, highways, parkland purchases, and other federal activities are proposed. Environmental Assessments (EAs) and Environmental Impact Statements (EISs), which are assessments of the likelihood of impacts from alternative courses of action, are required from all Federal agencies and are the most visible NEPA requirements.”

Under the Obama Administration, NEPA, which is administered by the Council on Environmental Quality, was modified to include requirements that the greenhouse gas emissions (acting as a proxy for climate change) that may result from all new projects be estimated and that information considered when assessing the feasibility/acceptability of the project.

This is ludicrous, as we explained in our Comment in opposition:

This aspect of the CEQ guidance is internally inconsistent, contrary to the intentions of NEPA, and ultimately misdirects policymakers and the general public alike. 

Additionally, it illustrates a lack of understanding and comprehension of environmental science—yet this guidance is supposedly being developed to provide direction to federal agencies in their reporting of science-based environmental impacts.

Instead, the draft guidance appears to have been created to elevate policy initiatives over actual science. This is inappropriate. In its current form, the guidelines should be rescinded and redeveloped with a more appropriate emphasis on environmental and climate science.

…To best serve policymakers and the general public, the CEQ should state that all but the largest federal actions have an undetectable and inconsequential impact on the environment through changes in the climate. And for the largest federal actions, an analysis of the explicit environmental impacts resulting from greenhouse gas emissions arising from the action should be detailed, with the impacts assessment not limited to climate change but also to include other environmental effects such as impacts on overall vegetative health (including crop yield and production).

As called for in the guidelines described in this current draft—substituting greenhouse gas emissions for climate change and other environmental impacts—is not only insufficient, but is scientifically inadequate and potentially misleading. As such, these CEQ guidelines should be rescinded and discarded.

Obama’s CEQ didn’t favorably consider our objection. We urge Trump’s to reconsider.

Social Cost of Carbon

The Obama Administration’s favorite tool to produce monetary justification for its actions on climate change is the social cost of carbon (SCC). The SCC is supposed to be a representation of all the future damages (extending globally out about 300 years(!)) caused by each additional ton of carbon dioxide emissions from human activities, expressed in current dollars. The Administration currently considers that elimination a ton of CO2 that would otherwise be emitted results in a savings of about $40 in future damages. It’s the “climate benefit” of their rulemaking.

But, the SCC is so highly malleable that you can pretty much game it to produce any value desired—the perfect characteristic for an all-purpose economic cost/benefit tool wielded by an opportunistic and activist government.

We’ve described in great detail the hows and whys of the SCC and why the Obama Administration’s determination of it is so badly biased (a recent example is here).

A critical re-examination of the SCC is badly needed (the one conducted a few years back by Obama’s OMB was but a whitewash).

We suggest that the new administration follows the explicit Office of Management and Budget (OMB) guidelines in calculating the SCC, including guidance on how to select discount rates, as well as requirements for reporting domestic (vs. global) costs. Additionally, the new SCC determinations should fully incorporate the latest scientific estimates of the sensitivity of the earth’s temperature to carbon dioxide increases and adequately incorporate the overwhelming scientific evidence of the positive effects of carbon dioxide on global food production and vegetation growth. At some higher discount rates (associated with a vibrant economy) and low climate sensitivities the SCC becomes negative, meaning that the emissions are beneficial.

In doing so, the new Administration will find that the value of the SCC will approach zero and even go below in some cases—eliminating the justification for federal actions explicitly directed a reducing carbon dioxide emission from energy use and production.

There are many more Obama climate actions that the Trump Administration should reconsider, but these three, along with the ones explicitly mentioned in Trump’s new transition website, should feature prominently on the list of things to accomplish in the near term.

June 17, 2016 2:02PM

You Ought to Have a Look: Paris Agreement Prospects, EPA Shenanigans, House Says No to a Carbon Tax

You Ought to Have a Look is a feature from the Center for the Study of Science posted by Patrick J. Michaels and Paul C. (“Chip”) Knappenberger.  While this section will feature all of the areas of interest that we are emphasizing, the prominence of the climate issue is driving a tremendous amount of web traffic.  Here we post a few of the best in recent days, along with our color commentary. 

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We’ll get right to it.

First up this week is an examination by the Global Warming Policy Foundation (GWPF) of the prospects of a quick ratification of the Paris Climate Agreement—something that President Obama desperately wants in order to insure that if the next president proves hostile to the Agreement, he won’t be able to derail the whole thing.

While Obama was all smiles when Indian Prime Minister Narendra Modi was in town recently discussing cooperation on the climate, Indian officials were quick to point out that we shouldn’t get the wrong idea, stating that India is “unlikely to sign the Agreement this year, or even the next.”

The GWPF analysis takes us through India’s stance was well as the opinions of other countries which are vital to the Agreement’s ratification. Some have ratified it already, while others, like India, aren’t rushing forward.  From the GWPF:

Representing the two largest greenhouse gas emitters, the joint US and Chinese commitment to early entry into force is undoubtedly significant. Nonetheless, the picture becomes significantly more complicated looking at the next two largest emitters: Russia and India. Both countries have indicated that they are prepared to wait before they ratify the Agreement, wanting a clear set of rules and a greater recognition of differentiated responsibilities. The EU process of securing unanimity between 28 member states is likely to mean a significant delay to European ratification. This means that early entry to force is dependent on building a coalition of many smaller countries, a procedure that is likely to be challenging.

Next up is a good piece by Competitive Enterprise Institute’s Marlo Lewis showing just how dodgy the EPA’s calculation of “benefits” for their recent emissions regulations really is. Turns out that in addition to double counting them, they find health benefits from reducing emissions in regions which remain below the EPA’s cut-off concentrations for deleterious effects. Marlo wonders how it is that

EPA does not explain or try to justify why associations between PM2.5 [tiny particulate matter] and health that are too weak or uncertain to be used to determine what is requisite to protect the public health with an adequate margin of safety are strong and certain enough to calculate regulatory benefits.

He concludes that the reason is that if the EPA were to remove the monetized health “benefits” from those areas which are projected remain in attainment with EPA standards (which turns out to be most of impacted regions), the “benefits” drop to near zero. This not only applies to the EPA’s Mercury and Toxic Standards (MATS) rule, but to their Clean Power Plan (CPP) as well. Such a result would, in Marlo’s words, be a “potential PR disaster for the agency.”

And we can’t have that—so we imagine that the EPA will stick with their inconsistent methodology.

But some things are looking up.

Last week, the House of Representatives passed Rep. Steve Scalise’s (R-LA) resolution “Expressing the sense of Congress that a carbon tax would be detrimental to the United States economy” by a vote of 237 to 163. Not a single Republican vote was cast against the resolution.

Seems “conservative thinkers” still have a lot of work ahead of them.

All the while, their work is being made more difficult by growing scientific evidence that the climate’s sensitivity to carbon dioxide emissions is considerably less than advertised—a situation which reduces the urgency to “do something” (like implementing a carbon tax) about global warming.

Which brings us, again, to the topic of the social cost of carbon—the monetary manifestation of the impetus to tax carbon dioxide emissions in the first place.

Before signing out this week, we wanted to point you to an article by Ross McKitrick in the Financial Post in which he explains the importance of his new analysis of the government’s social cost of carbon determination—an analysis that we highlighted in last week’s YOTHAL.  In summary, Ross writes:

The numbers produced by the [U.S. federal government] have a large and growing influence over energy and economic policy in the U.S. and Canada and elsewhere. Unfortunately, for all its claims about following the science, where it really counts it ended up peddling guesstimates based on inconsistent models. To borrow a phrase, it is time to restore science to its rightful place. Calculations behind the social cost of carbon need to reflect empirical evidence about low climate sensitivity, and when this is done, the numbers appear to be much lower than those currently in use.

You ought to have a look.