Yesterday was the deadline for filing comments with the Office of Management and Budget (OMB) on the Obama administration’s social cost of carbon (SCC) estimates. I submitted a comment letter on behalf of the Competitive Enterprise Institute, Americans for Tax Reform, CFACT, Freedom Action, FreedomWorks Foundation, Frontiers of Freedom, George C. Marshall Institute, Heartland Institute, Rio Grande Foundation, Science & Environmental Policy Project, and Small Business & Entrepreneurship Council.
We argue that carbon’s social cost is an unknown quantity; that SCC analysts can get just about any result they desire by fiddling with non-validated climate parameters, made-up damage functions, and below-market discount rates; and that SCC analysis is computer-aided sophistry, its political function being to make renewable energy look like a bargain at any price and fossil energy look unaffordable no matter how cheap.
One point we emphasize that may come as a complete shock to OMB is that there are potentially very large social costs of carbon mitigation.
- The public health and welfare risks of policies that raise business and household energy costs.
- The economic, fiscal, and energy security risks of policies that endanger the shale revolution.
- The economic development risks of policies that limit poor countries’ access to affordable energy.
- The risks to international peace and stability of impeding developing country economic growth through carbon caps or taxes and carbon-tariff protectionism.
- The proliferation risks of policies that increase developing country demand for fissile materials and nuclear technology.
- The risks to scientific integrity when government is both chief funder of climate research and chief beneficiary of “consensus” science supporting a bigger role for government in economic decisions.
- The risk to the democratic process when governments promote “consensus” climatology to justify bypassing legislatures and marginalizing opponents as “anti-science.”
Here I will excerpt* the discussion addressing point 7 — the risks climate policy poses to democratic self-government.
“Perhaps the biggest casualty [of the global warming movement] is science,” author Rupert Darwall opines. Climate models produce long-term forecasts that cannot be validated in our lifetimes. Inevitably, “consensus” and “expert judgment” displace reproducibility as tests of scientific validity. Government grants and appointments reward researchers whose findings support the consensus. Since the politicians and agencies funding the research and invoking “consensus” are the same ones seeking greater control over energy markets and energy production, researchers face continual pressure or temptation to cross the line between policy relevance and policy advocacy. Groupthink becomes the norm.
A related casualty is the democratic process. The Obama administration’s M.O. is to “enact” climate policies through regulations Congress has not approved and would reject if introduced as legislation and put to a vote. Such policies include the 54 mpg fuel-economy standard, application of best available control technology standards to major stationary greenhouse gas emitters, and a “carbon pollution rule” that effectively bans construction of new commercial coal generation. Administration officials and their allies invoke the “consensus of scientists” to explain why they “can’t wait” for the people’s representatives to act.
In his farewell address, President Dwight D. Eisenhower warned not only of a military-industrial complex, but also of the capture of public policy by a “scientific-technological elite.”
Observing that a “steadily increasing share” of scientific research “is conducted for, by, or at the direction of, the Federal government,” Eisenhower stated that the “prospect of domination of the nation’s scholars by Federal employment, project allocations, and the power of money is ever present and is gravely to be regarded.” While holding scientific research and discovery in respect, “we must also be alert to the equal and opposite danger that public policy could itself become the captive of a scientific-technological elite.”
Science is a mode of inquiry, not a font of practical wisdom, and still less a set of moral imperatives. But in the Age of Global Warming, activist scientists and their allies hype small increases in average global temperaure into an impending catastrophe and, thus, into a mandate to suppress carbon energy use before commercially-viable alternatives are available. Government-funded science becomes a political bludgeon for discrediting opponents and dictating policy. Anyone who doubts the narrative of a planet in peril or who opposes centralized eco-energy planning is instantly dismissed as a “shoddy scientist,” “extreme ideologue,” or member of the “Flat Earth Society.” Not just actual scientific expertise but mere conformity to a government-approved scientific “consensus” becomes a claim to rule. The spread of this elitist mentality is not healthy in a democracy.
The pseudo-science of SCC estimation gives regulators, NGOs, and other politically-unaccountable experts a new rhetorical tool for claiming special knowledge about climate risks and solutions, and for lording it over the public and their representatives. We think Eisenhower would be appalled.
Some good may come of it, though. The skeptic movement is partly a reaction to the scientism of those who have hyped “consensus” into a claim to rule. With SCC analysis, the anti-carbon faction’s pretense of knowledge and precision ceases to be artful and becomes blatant. Skeptics are bound to have a field day debunking SCC analysis. In fact, they already are.
* With some additional words for clarity.