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?

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.