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.
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.