Why does any sensible person even bother submitting comment letters to the Obama administration about any matter relating to climate change? I find myself asking that question again and again, because the only ‘error’ the administration will ever admit is that climate change is ‘worse than we thought’ — an implicit boast that ‘we were more right than we knew.’
The administration has a party line and no agency is allowed to deviate from it on any matter of climate science, economics, or policy, no matter how speculative or minor the point at issue.
Nonetheless, I continue to submit comments — as other skeptics and free marketers do — just to ensure that the administration’s groupthink does not go unchallenged on the record.
What brings such thoughts to mind is the Office of Management and Budget’s response to comments, posted just before the July 4th weekend, on the Interagency Working Group’s May 2013 Technical Support Document (TSD) on the social cost of carbon. The social cost of carbon (SCC) is the cumulative damage to society allegedly inflicted by an incremental ton of carbon dioxide (CO2) emissions over an immense span of time (typically out to the year 2300).
Obama officials routinely use SCC estimates to calculate the putative benefits of CO2-reducing regulations. The higher the estimated SCC, the bigger the projected value of CO2 reductions becomes. For example, the 2013 TSD increased the SCC values of an earlier 2010 TSD by roughly 60%. So in just four short years, while climate models increasingly overshot observed global temperatures, climate change somehow got 60% worse and climate regulations 60% more valuable. Your government at work!
OMB reports it received 39,000 form letters and about 150 “substantive comments” on the 2013 TSD. The latter pile includes the comment letter I submitted on behalf of eleven pro-market organizations.
Along with its response to comments, OMB has also posted a revised TSD. True to form, the revised document does not accept any of the “substantive comments.” The only changes are minor technical corrections in how agencies are to run the integrated assessment models (IAMs) they use to estimate carbon’s social cost.
As explained in a recent post and accompanying Power Point, SCC analysis is computer-aided sophistry, an attempt by would-be central planners to hide raw political preferences behind a pretense of knowledge and precision.
Today’s post will briefly identify weaknesses in OMB’s response to our comments.