Cooler Heads Digest

by William Yeatman on December 7, 2008

In the News

Money Being Made from the Global Warming Scare: A Review of Chris Horner’s Red Hot Lies
Larry Thornberry, Washington Times, 2 December 2008

Green Jobs Don’t Work in New Jersey, or Anywhere Else

William Yeatman, Press of Atlantic City, 2 December 2008

Obama Drops Windfall Profits Tax
Ronald Bailey, Reason Online, 3 December 2008

CA Cooks the Books To Get Desired Result
Mark Landsbaum, Orange Punch, 2 December 2008

Cooling Down
Investor’s Business Daily, 2 December 2008

News You Can Use

Even Alarmists Know that Cap-and-Trade Is a Boondoggle

Even global warming alarmists know that cap-and-trade schemes are a boondoggle. According to The Times, Dr. James Hansen, director of NASA’s Goddard Institute for Space Studies and one of the most extreme global warming alarmists, believes cap-and-trade is a “terrible” approach. “Carbon trading does not solve the emission problem at all,” he says. “In fact it gives industries a way to avoid reducing their emissions. The rules are too complex and it creates an entirely new class of lobbyists and fat cats.”

Inside the Beltway


Marlo Lewis

The day after Thanksgiving was the deadline for submitting comments to the Environmental Protection Agency (EPA) on its Advance Notice of Proposed Rulemaking (ANPR), “Regulation of Greenhouse Gases under the Clean Air Act.” The ANPR is EPA’s preliminary response to the Supreme Court global warming case, Massachusetts v EPA (April 2, 2007). EPA invited public comment on literally hundreds of issues but the main issue in dispute is whether EPA should issue a finding under Section 202 of the Clean Air Act (CAA) that greenhouse gas (GHG) emissions from new motor vehicles “cause or contribute to air pollution” that “may reasonably be anticipated to endanger public health or welfare.”

In two separate detailed comments (see here and here) and a more general comment co-signed by 31 other free-market and conservative organizations, the Competitive Enterprise Institute (CEI) explains that an endangerment finding would trigger a regulatory cascade throughout the Clean Air Act, imposing potentially crushing burdens on regulated entities, environmental agencies, and the economy. For example, tens of thousands of previously unregulated buildings and facilities could face new regulation, monitoring, controls, and penalties under the Act’s Prevention of Significant Deterioration (PSD) pre-construction permitting program, creating a massive roadblock to new construction and economic development.

In Massachusetts, the Court said that EPA does not have to make an endangerment finding if it provides a “reasonable explanation” why it cannot or will not do so. CEI’s comments present several compelling reasons:

  • An endangerment finding would set the stage for multiple policy disasters no Congress would ever approve.
  • The only way EPA can regulate GHG emissions under the CAA without risk of administrative chaos and economic devastation is to flout statutory language and effectively amend the Act.
  • Had the Justices known in 2006 and early 2007 what the ANPR and other analyses have since brought to light about the irrational and destructive burdens an endangerment finding would trigger, they likely would have decided the case differently.
  • EPA cannot establish GHG emission standards for new motor vehicles yet “avoid inconsistency” with the fuel economy standards enacted by Congress in the 2007 Energy Independence and Security Act.
  • EPA cannot coherently define the “air pollution” related to GHG emissions, hence lacks the requisite subject matter on which to make an endangerment finding.
  • Persistent uncertainties regarding climate sensitivity to rising GHG concentrations, the implausibility of climate disaster scenarios, the divergence between model predictions and actual temperature data, and historic declines in U.S. mortality due to extreme weather, air pollution, heat waves, and malaria despite increases in global temperatures make it unreasonable at this time to anticipate endangerment of public health and welfare from global warming.

The U.S. Chamber of Commerce has a Web site with links to the ANPR, EPA’s regulatory docket, the U.S. Chamber’s PSD compliance burden study, industry-specific impact assessments, legal research, and a page featuring comments by almost two dozen organizations. President-elect Obama’s would be well advised to spend several days reviewing the information and analyses on this site.

Across the States

CARB’s Economic Voo-doo

In September the California Air Resources Board (CARB) released an economic analysis claiming that California’s landmark climate change bill, AB 32, would simultaneously increase economic growth while reducing emissions to 1990 levels by 2020. Proponents of energy-rationing policies to fight climate change quickly seized upon CARB’s study as proof that “doing something” about global warming would be easy.

CARB solicited peer review comments from professional economists, which were published this week. They are a powerful indictment of CARB’s analysis.

“Unfortunately, the Economic Analysis Supplement [CARB’s economic analysis], in its current form, gives the appearance of justifying the chosen package of regulatory measures rather than evaluating it or looking at policy options,” wrote Janet Peace and Liwayway Adkins of the Pew Center on Global Climate Change.

Harvard economics professor Robert Stavins wrote, “I have come to the inescapable conclusion that the economic analysis is terribly deficient in critical ways and should not be used by the state government or the public for the purpose of assessing the likely costs of CARB’s plans.”

Matthew Kahn, an economics professor at UCLA wrote, “While I support the governor’s broad AB 32 goals, I am troubled by the economic modeling analysis that I have been asked to read. AB 32 is presented as a riskless ‘free lunch’ for Californians.”

These economists, moreover, make it clear in their comments that they support policies to fight climate change. They could not, however, endorse CARB’s voo-doo economics.

It should be noted that the Cooler Heads Digest repeatedly challenged CARB on its analytic advocacy even before the peer review comments were made available (see here and here).

Around the World

COP 14

Negotiators from more than 190 countries began meeting in Poznan, Poland this week for the fourteenth Conference of the Parties to the United Nations Framework Convention on Climate Change, a 12 day conference to hammer out a “shared vision” on climate policy. So far, the delegates have been unable to agree on anything.

Despite pressure from the Europe Union and developing countries, the Bush administration remains unwilling to commit to binding emissions targets that would harm the American economy. Ambassador Harlan Watson, the chief U.S. delegate, said Monday he expected no agreement at Poznan on specific global targets for emissions cuts by 2020.

President-elect Barack Obama has won praise for promising to engage the international community on climate change, but the Chinese and Indian delegations to Poznan are unimpressed. They said that Obama’s goal to reduce U.S. emissions to 1990 levels by 2020 is inadequate. They would prefer emissions reductions of 30%-40% by 2020.

All developing countries agree that the developed countries should spend 1% of their annual GDP—about $300 billion—transferring clean energy technology to developing countries. But these same developing countries disagree on the need to set firm emissions targets for themselves. The disagreement stems from the fact that unabated emissions from developing countries would ensure atmospheric concentrations of carbon dioxide raced passed thresholds that scientists say are likely to cause irreversible, “catastrophic” climate change, even if rich countries somehow reduced their collective carbon footprint to zero by 2050 (an unlikely occurrence). This gives pause to countries such as China, which are wary of committing to stringent a target that could prove ruinously expensive.

The European Union has already agreed to reduce emissions 20% below 1990 levels by 2020, but as the Cooler Heads Digest has reported, the EU’s commitment to its climate goal is wavering as the costs become clearer (see here and here).  It should also be noted that emissions have increased substantially in the EU since Kyoto was negotiated in 1997.

Despite these difficulties, the EU received no sympathy from the 90 nation Alliance of Small Island States, which claimed in Poznan that the EU’s climate targets are too weak. The island states are trying to limit warming to 1.5 degrees Celsius, while the EU wants to limit warming to 2 degrees Celsius. EU delegate Artur Runge-Metzger told reporters that the small island states’ target “is very hard,” and “probably very costly.”

By the end of next week, the delegates no doubt will produce some sort of agreement that they will claim is a historic achievement. It will no doubt be just as significant as the historic achievements claimed by each of the previous 13 Conference of the Parties.

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