Last week, I noted that public comments on what should be called the "necessarily bankrupt" regulation from EPA will close on June 25. There, the EPA proposes standards on new power plants that are so stringent that, indeed, anyone who tries to build a new one might as well burn dollars in it instead of coal.
I noted there that the EPA's regulation, when it comes to climate and climate change in the U.S. was based on the 2009 document Global Climate Change Impacts in the United States, by the U.S. Global Change Research Program (USGCRP), and that the Center for the Study of Public Science and Public Policy at the Cato Institute was preparing an Addendum to that document that would tell, as they say, "the rest of the story."
Downloading both and looking side-by-side can be very amusing. Note that the Cato report is in draft form and there is a big fat disclaimer on it that says you can expect to find spelling, typographical, and grammatical errors in this version, but future revisions are likely to be more minor than major.
So, the bomb has now been dropped into EPA's court. The accompanying comments to them note that, with regard to the "necessarily bankrupt" proposal, EPA contends:
There is no reason to revisit the 2009 Endangerment Finding given recent scientific findings that strengthen the scientific conclusion that GHG (greenhouse-gas) air pollution endangers human health and welfare.
Our comments note that the original USGCRP report is "clearly slanted towards negative impacts from climate change when there is a large body of scientific evidence…that argues for the contrary."
The comments assert that many papers published since the 2009 document show that the likelihood of extreme climate change is much lower than assumed in that report. This alone challenges EPA's assertion that things are just hunky-dory in Apocalypse Land, and requires them to reassess their Endangerment Finding.
In addition, the rapid evolution of climate science — for better or worse, for warmer or cooler — mandates that the EPA reassess their Endangerment Finding at least on an annual basis.
As the comments note, relying on dated and incomplete science is a recipe for bad regulations.
Admittedly, the Addendum is perfectly cheeky. In many cases it uses the USGCRP's own words, followed by what they somehow forgot to mention. In others, it borrows directly from their format. Finally, it commits the cardinal Washington sin of dissing bureaucracy.
The last section of the USGCRP report is called "An Agenda for Climate Impacts Science," which is nothing more than a wish list for more and more $$$ to go to the USGCRP. How predictable.
On the other hand, the Executive Summary of the Addendum concludes:
This report does not end with a self-serving list of areas from which its authors can generate even more federal taxpayer funding for their own projects. For an example of that, see the original USGCRP volume.
The Addendum ends, as did the original USGCRP report, with a section on future U.S. climate assessments. It has both bad news and good news:
Future assessments of climate change are likely to be as poor in quality as Climate Change Impacts in the United States. Regardless of who is President, the same figures will remain in the civil service, with every incentive to expand their turf and further their careers. It is a sad fact of American life that such unelected officials can impose such enormous costs on the citizenry without being subject to recall.
However, if this Addendum has significant impact, each new federal assessment is likely to be answered like the USGCRP report was — with more science than our federal government chooses to recognize.
Harrumph! I'm done now.