The Futility and Falsehoods of Climate Heroics

01 Tuesday Jun 2021

Posted by Nuetzel in Climate science, Environmental Fascism, Global Warming, Uncategorized

Tags

Atmospheric Carbon, Biden Administration, Carbon forcing, Carbon Mitigation, Climate Change, Climate Sensitivity, ExxonMobil, Fossil fuels, global warming, Green Energy, Greenhouse Gas, IPPC, John Kerry, Judith Curry, Natural Gas, Netherlands Climate Act, Nic Lewis, Nuclear power, Putty-Clay Technology, Renewables, Ross McKitrick, Royal Dutch Shell, Social Cost of Carbon, William Nordhaus

The world’s gone far astray in attempts to battle climate change through forced reductions in carbon emissions. Last Wednesday, in an outrageously stupid ruling,a Dutch court ordered Royal Dutch Shell to reduce its emissions by 45% by 2030 relative to 2019 levels. It has nothing to do with Shell’s historical record on the environment. Rather, the Court said Shell’s existing climate action plans did not meet “the company’s own responsibility for achieving a CO2 reduction.” The decision will be appealed, but it appears that “industry agreements” under the Netherlands’ Climate Act of 2019 are in dispute.

Later that same day, a shareholder dissident group supporting corporate action on climate change won at least two ExxonMobil board seats. And then we have the story of John Kerry’s effort to stop major banks from lending to the fossil fuel industry. Together with the Biden Administration’s other actions on energy policy, we are witnessing the greatest attack on conventional power sources in history, and we’ll all pay dearly for it.

The Central Planner’s Conceit

Technological advance is a great thing, and we’ve seen it in the development of safe nuclear power generation, but the environmental left has successfully placed roadblocks in the way of its deployment. Instead, they favor the mandated adoption of what amount to beta versions of technologies that might never be economic and create extreme environmental hazards of their own (see here, here, here, and here). To private adopters, green energy installations are often subsidized by the government, disguising their underlying inefficiencies. These premature beta versions are then embedded in our base of productive capital and often remain even as they are made obsolete by subsequent advances. The “putty-clay” nature of technology decisions should caution us against premature adoptions of this kind. This is just one of the many curses of central planning.

Not only have our leftist planners forced the deployment of inferior technologies: they are actively seeking to bring more viable alternatives to ruination. I mentioned nuclear power and even natural gas offer a path for reducing carbon emissions, yet climate alarmists wage war against it as much as other fossil fuels. We have Kerry’s plot to deny funding for the fossil fuel industry and even activist “woke” investors, attempting to override management expertise and divert internal resources to green energy. It’s not as if renewable energy sources are not already part of these energy firms’ development portfolios. Allocations of capital and staff to these projects are usually dependent upon a company’s professional and technical expertise, market forces, and (less propitiously) incentives decreed by the government. Yet, the activist investors are there to impose their will.

Placing Faith and Fate In Models

All these attempts to remake our energy complex and the economy are based on the presumed external costs associated with carbon emissions. Those costs, and the potential savings achievable through the mitigation efforts of government and private greenies around the globe, have been wildly exaggerated.

The first thing to understand about the climate “science” relied upon by the environmental left is that it is almost exclusively model-dependent. In other words, it is based on mathematical relationships specified by the researchers. Their projections depend on those specs, the selection of parameter values, and the scenarios to which they are subjected. The models are usually calibrated to be roughly consistent with outcomes over some historical time period, but as modelers in almost any field can attest, that is not hard to do. It’s still possible to produce extreme results out-of-sample. The point is that these models are generally not estimated statistically from a lengthy sample of historical data. Even when sound statistical methodologies are employed, the samples are blinkingly short on climatological timescales. That means they are highly sample-specific and likely to propagate large errors out-of-sample. But most of these are what might be called “toy models” specified by the researcher. And what are often billed as “findings” are merely projections based on scenarios that are themselves manufactured by imaginative climate “researchers” cum grant-seeking partisans. In fact, it’s much worse than that because even historical climate data is subject to manipulation, but that’s a topic for another day.

Key Assumptions

What follows are basic components of the climate apocalypse narrative as supported by “the science” of man-made or anthropomorphic global warming (AGW):

(A) The first kind of model output to consider is the increase in atmospheric carbon concentration over time, measured in parts per million (PPM). This is a function of many natural processes, including volcanism and other kinds of outgassing from oceans and decomposing biomass, as well absorption by carbon sinks like vegetation and various geological materials. But the primary focus is human carbon generating activity, which depends on the carbon-intensity of production technology. As Ross McKitrick shows (see chart below), projections from these kinds of models have demonstrated significant upside bias over the years. Whether that is because of slower than expected economic growth, unexpected technological efficiencies, an increase in the service-orientation of economic activity worldwide, or feedback from carbon-induced greening or other processes, most of the models have over-predicted atmospheric carbon PPM. Those errors tend to increase with the passage of time, of course.

(B) Most of the models promoted by climate alarmists are carbon forcing models, meaning that carbon emissions are the primary driver of global temperatures and other phenomena like storm strength and increases in sea level. With increases in carbon concentration predicted by the models in (A) above, the next stage of models predicts that temperatures must rise. But the models tend to run “hot.” This chart shows the mean of several prominent global temperature series contrasted with 1990 projections from the Intergovernmental Panel on Climate Change (IPCC).

The following is even more revealing, as it shows the dispersion of various model runs relative to three different global temperature series:

And here’s another, which is a more “stylized” view, showing ranges of predictions. The gaps show errors of fairly large magnitude relative to the mean trend of actual temperatures of 0.11 degrees Celsius per decade.

(C) Climate sensitivity to “radiative forcing” is a key assumption underlying all of the forecasts of AGW. A simple explanation is that a stronger greenhouse effect, and increases in the atmosphere’s carbon concentration, cause more solar energy to be “trapped” within our “greenhouse,” and less is radiated back into space. Climate sensitivity is usually measured in degrees Celsius relative to a doubling of atmospheric carbon.

And how large is the climate’s sensitivity to a doubling of carbon PPM? The IPCC says it’s in a range of 1.5C to 4.5C. However, findings published by Nic Lewis and Judith Curry are close to the low end of that range, and are those found by the author of the paper described here.

In separate efforts, Finnish and Japanese researchers have asserted that the primary cause of recent warming is an increase in low cloud cover, which the Japanese team attributes to increases in the Earth’s bombardment by cosmic rays due to a weakening magnetic field. The Finnish authors note that most of the models used by the climate establishment ignore cloud formation, an omission they believe leads to a massive overstatement (10x) of sensitivity to carbon forcings. Furthermore, they assert that carbon forcings are mainly attributable to ocean discharge as opposed to human activity.

(D) Estimates of the Social Cost of Carbon (SCC) per ton of emissions are used as a rationale for carbon abatement efforts. The SCC was pioneered by economist William Nordhaus in the 1990s, and today there are a number of prominent models that produce distributions of possible SCC values, which tend to have high dispersion and extremely long upper tails. Of course, the highest estimates are driven by the same assumptions about extreme climate sensitivities discussed above. The Biden Administration is using an SCC of $51 per ton. Some recommend the adoption of even higher values for regulatory purposes in order to achieve net-zero emissions at an early date, revealing the manipulative purposes to which the SCC concept is put. This is a raw attempt to usurp economic power, not any sort of exercise in optimization, as this admission from a “climate expert” shows. In the midst of a barrage of false climate propaganda (hurricanes! wildfires!), he tells 60 Minutes that an acceptable limit on warming of 1.5C is just a number they “chose” as a “tipping point.”

As a measurement exercise, more realistic climate sensitivities yield much lower SCCs. McKitrick presents a chart from Lewis-Curry comparing their estimates of the SCC at lower climate sensitivities to an average of earlier estimates used by IPCC:

High levels of the SCC are used as a rationale for high-cost carbon abatement efforts. If the SCC is overstated, however, then costly abatements represent waste. And there is no guarantee that spending an amount on abatements equal to the SCC will eliminate the presumed cost of a ton’s worth of anthropomorphic warming. Again, there are strong reasons to believe that the warming experienced over the past several decades has had multiple causes, and human carbon emissions might have played a relatively minor role.

Crisis Is King

Some people just aren’t happy unless they have a crisis over which to harangue the rest of us. But try as they might, the vast resources dedicated to carbon reduction are largely wasted. I hesitate to say their effort is quixotic because they want more windmills and are completely lacking in gallantry. As McKitrick notes, it takes many years for abatement to have a meaningful impact on carbon concentrations, and since emissions mix globally, unilateral efforts are practically worthless. Worse yet, the resource costs of abatement and lost economic growth are unacceptable, especially when some of the most promising alternative sources of “clean” energy are dismissed by activists. So we forego economic growth, rush to adopt immature energy alternatives, and make very little progress toward the stated goals of the climate alarmists.

A Carbon Tax Would Be Fine, If Only …

01 Friday Mar 2019

Posted by Nuetzel in Environment, Global Warming, Taxes

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A.C. Pigou, Carbon Dividend, Carbon Tax, Climate Change, Economic Development, External Cost, Fossil fuels, Green New Deal, IPCC, John Cochrane, Michael Shellenberger, Pigouvian Tax, Quillette, Renewable energy, Revenue Neutrality, Robert P. Murphy, Social Cost of Carbon, Warren Meyer, William D. Nordhaus

I’ve opposed carbon taxes on several grounds, but I admit that it might well be less costly as a substitute for the present mess that is U.S. climate policy. Today, we incur enormous costs from a morass of energy regulations and mandates, prohibitions on development of zero-carbon nuclear power, and subsidies to politically-connected industrialists investing in corn ethanol, electric cars, and land- and wildlife-devouring wind and solar farms. (For more on these costly and ineffective efforts, see Michael Shellenberger’s “Why Renewables Can’t Save the Planet” in Quillette.) Incidentally, the so-called Green New Deal calls for a complete conversion to renewables in unrealistically short order, but with very little emphasis on a carbon tax.

The Carbon Tax

Many economists support the carbon tax precisely because it’s viewed as an attractive substitute for many other costly policies. Some support using revenue from the tax to pay a flat rebate or “carbon dividend” to everyone each year (essentially a universal basic income). Others have pitched the tax as a revenue-neutral replacement for other taxes that are damaging to economic growth, such as payroll taxes or taxes on capital. Economic growth would improve under the carbon tax, or so the story goes, because the carbon tax is a tax on a “bad”, as opposed to taxes on “good” factors of production. I view these ideas as politically naive. If we ever get the tax, we’ll be lucky to get much regulatory relief in the bargain, and the revenue is not likely to be offset by reductions in other taxes.

But let’s look a little closer at the concept of the carbon tax, and I beg my climate-skeptic friends to stick with me for a few moments and keep a straight face. The tax is a way to attach an explicit price to the use of fuels that create carbon emissions. The emissions are said to inflict social or external costs on other parties, costs which are otherwise ignored by consumers and businesses in their many decisions involving energy use. The carbon tax is a so-called Pigouvian tax: a way to “internalize the externality” by making fossil fuels more expensive to burn. The tax itself involves no prohibitions on behavior of any kind. Certain behaviors are taxed to encourage more “desirable” behavior.

Setting the Tax

But what is the appropriate level of the tax? At what level will it approximate the true “social cost of carbon”? Any departure from that cost would be sub-optimal. Robert P. Murphy contrasts William D. Nordhaus’ optimal carbon tax with more radical levels, which Nordhaus believes would be needed to meet the goals of the United Nation’s Intergovernmental Panel on Climate Change (IPCC). Nordhaus won the 2018 Nobel Prize in economics for his work on climate change. Whatever one might think of the real risks of climate change, Nordhaus’ clearly recognizes the economic downsides to mitigating against those risks.

Nordhaus has estimated that the social cost of carbon will be $44/ton in 2025 (about $0.39 per gallon of gas). He claims that a carbon tax at that level would limit increases in global temperature to 3.5º Celsius by 2100. He purports to show that the costs of a $44 carbon tax in terms of reduced economic output would be balanced by the gains from limiting climate warming. Less warming would require a higher tax with fewer incremental rewards, and even more incremental lost output. The costs of the tax would then outweigh benefits. For perspective, according to Nordhaus, a stricter limit of 2.5º C implies a carbon tax equivalent to $2.50 per gallon of gas. The IPCC, however, prescribes an even more radical limit of 1.5º C. That would inflict a huge cost on humanity far outweighing the potential benefits of less warming.

A Carbon Tax, If…

Many economists have come down in favor of a carbon tax under certain qualifications: revenue-neutrality, a “carbon dividend”, or as a pre-condition to deregulation of carbon sources and de-subsidization of alternatives. John Cochrane discusses a carbon tax in the context of the “Economists’ Statement on Carbon Dividends” (Cochrane’s more recent thoughts are here):

“It’s short, sweet, and signed by, as far as I can tell, every living CEA chair, every living Fed Chair, both Democrat and Republican, and most of the living Nobel Prize winners. … It offers four principles 1. A carbon tax, initially $40 per ton. 2. The carbon tax substitutes for regulations and subsidies and (my words) the vast crony-capitalist green boondoggle swamp, which is chewing up money and not saving carbon. 3. Border adjustment like VAT have [sic] 4. ‘All the revenue should be returned directly to U.S. citizens through equal lump-sum rebates.'”

Rather than a carbon dividend, Warren Meyer proposes that a carbon tax be accompanied by a reduction in the payroll tax, an elimination of all subsidies, mandates, and prohibitions, development of more nuclear power-generating capacity, and contributions to a cleanup of Chinese and Asian coal-power generation. That’s a lot of stuff, and I think it exceeds Meyer’s normal realism with respect to policy issues.

My Opposition

Again, I oppose the adoption of a carbon tax for several reasons, despite my sympathy for the logic of Pigouvian taxation of externalities. At the risk of repeating myself, here I elaborate on my reasons for opposition:

Government Guesswork: First, Nordhaus’ estimates notwithstanding, we do not and cannot know the climate/economic tradeoffs with any precision. We can barely measure global climate, and the history of what measures we have are short and heavily manipulated. Models purporting to show the relationship between carbon forcing and global climate climate change are notoriously unreliable. So even if we can agree on the goal (1.5º, 2.5º, 3.5º), and we won’t, the government will get the tradeoffs wrong. I took the following from a comment on Cochrane’s blog, a quote from A.C. Pigou himself:

“It is not sufficient to contrast the imperfect adjustments of unfettered enterprise with the best adjustment that economists in their studies can imagine. For we cannot expect that any State authority will attain, or even wholeheartedly seek, that ideal. Such authorities are liable alike to ignorance, to sectional pressure, and to personal corruption by private interest. A loud-voiced part of their constituents, if organized for votes, may easily outweigh the whole.”

Political Hazards: Second, we won’t get the hoped-for political horse trade made explicit in the “Economists’ Statement …” discussed above. As a political matter, the setting of the carbon tax rate will almost assuredly get us a rate that’s too high. Experiences with carbon taxes in Australia, British Columbia, and France have been terrible thus far, sowing widespread dissatisfaction with the resultant escalation of energy prices.

Economic Growth: Neither is it a foregone conclusion that a revenue-neutral carbon tax will stimulate economic growth, and it might actually reduce output. As Robert P. Murphy explains in another post, the outcome depends on the structure of taxes prior to the change. The substitution of the carbon tax will increase output only if it replaces taxes on a factor of production (labor or capital) that is overtaxed prior to the change. That undermines a key selling point: that the carbon tax would necessarily produce a “double dividend”: a reduction in carbon emissions and higher economic growth. Nevertheless, I’d allow that revenue neutrality combined with elimination of carbon regulation and “green” subsidies would be a good bet from an economic growth perspective.

Overstated Risks: Finally, I oppose carbon taxes because I’m unconvinced that the risk and danger of global warming are as great as even Nordhaus would have it. In other words, the external costs of carbon don’t amount to much. Our recorded temperature history is extremely short and is therefore not a reliable guide to the long-term nature of the systemic relationships at issue. Even worse, temperature records are manipulated to exaggerate the trend in temperatures (also see here, here and here). There is no evidence of an uptrend in severe weather events, and the dangers of sea level rise associated with increasing carbon concentrations also have been greatly exaggerated. Really, at some point one must take notice of the number of alarming predictions and doomsday headlines from the past that have not been borne out even remotely. Furthermore, higher carbon concentrations and even warming itself would be of some benefit to humanity. In addition to a greener environment, the benefits include more rapid economic growth, improved agricultural yields, and a reduction in the salient danger of cold-weather deaths.

Economic Development: The use of fossil fuels has helped to enable strong growth in incomes in developed economies. It has also given us energy alternatives such as nuclear power as well as research into other alternatives, albeit with very mixed success thus far. And while a carbon tax would create an additional incentive to develop such alternatives, a U.S. tax would not accomplish much if any global temperature reduction. Such a tax would have to be applied on a global scale. Talk about a political long-shot! Increasing the price of carbon emissions also has enormous downsides for the less developed world. These fragile economies would benefit greatly from development of fossil fuel energy, enabling reductions in poverty and the income growth necessary to someday join in the prosperity of the developed economies. This, along with liberalization of markets, is the affordable way to bring economic success to these countries, which in turn will enable them to consider the energy alternatives that might come to fruition by that time. Fighting the war on fossil fuels in the underdeveloped world is nothing if not cruel.

Deceits of the Climate Claimants

23 Monday Jul 2018

Posted by Nuetzel in Global Warming

≈ 1 Comment

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Al Gore, Alpine Tree Lines, Armadillos, Desertification, Global Greening, global warming, Ocean Acidification, Polar Bears, Social Cost of Carbon, Steven Hayward

Well-meaning souls innocently parrot the global warming narrative but generally know little of the controversies surrounding its validation, or lack thereof. That includes much of the mainstream media. Every warm day is evidence of global warming. Every cold day is evidence of extreme volatility brought on by climate change. Every big storm, every forest fire, and every endangered species is attributed to warming. The poles are melting, the sea is rising, the sky is falling, and it is mostly bullshit. But in the meantime, the mythology of global warming has become an all-purpose cudgel for state oversight and “redistributive justice”, primarily to the benefit of the “climate change industrial complex. The myths are repeated so frequently that many accept them as facts. Here, I list a few of these myths along with information that should give pause to anyone tempted to take them too seriously.

The science is settled: There are a number of great scientists who dispute the global warming narrative (and see here). But a few studies have claimed incredibly widespread consensus (97%) among scientists that mankind drives climate change. These studies are generally plagued by biased samples of scientists (sometimes including non-scientists), faulty selection and classification of paper abstracts, and direct involvement of climate activists in the research process. These studies tend to present the “consensus” as one side of a stark dichotomy, with no nuance or middle ground for those subscribing to anything less than the inevitability of a warming catastrophe.

Record high temperatures: The temperatures that are almost always reported are surface temperatures that are subject to extreme bias. The most drastic bias is caused by increasing urbanization. Urban weather instruments are often sited in areas with an increasing amount of impervious ground cover, which absorbs sunlight and heat, leading to the so-called “urban heat-island effect”. This has imparted an upward trend in urban temperature readings. Moreover, urban temperature readings tend to be over-sampled in estimates of global surface temperatures, reinforcing the distortions in measured warming.

Melting poles: Arctic sea ice extent has been in modest retreat since 1980, when satellite measurement began to allow more accurate readings. The Antarctic, however, has shown a trend in the other direction, as shown in this piece by Judith Curry. In the same article, Curry shows that specific Arctic locations had less sea ice 6,000 to 8,000 years ago than today. For more complete information on satellite-era trends in sea ice extent, see this informative reference page (scroll way down for Antarctic information). Looks like Al Gore’s dire prediction that the poles would melt by 2007 was just a little off target.

Polar bear extinction: We are constantly seeing warnings of polar bear extinction on social media. Memes feature desperate-looking bears stranded on ice floes, drifting away from their cubs. Perhaps you aren’t supposed to know that polar bears are extremely strong swimmers. Or that the polar bear population is been thriving, increasing by an estimated 10-20% since 2001. So whether or not the past few decades have seen a decline in sea ice, the bears seem be doing just fine.

Rising sea levels: The rate of increase in sea levels over the past 8,000 years has been vey slow relative to the 10,000 years prior to that, when they rose at rates of up to 5.5 meters per century. That compares to recent rates of about one foot per century. Predictions that islands in the Pacific would be swallowed by the seas have not come to pass. In fact, satellite images show that more of the world’s sandy shorelines accreted than receded between 1984 and 2016, This does not appear to be a crisis by any means.

Increasing storms: No, the frequency and intensity of tropical cyclone activity has decreased since 1900, a trend that has continued unabated over the past 20 years. I know of at least one study suggesting otherwise, but it is based purely on modeled relationships, not hard data, and not tested against data. The frequency and intensity of droughts and floods has been flat to declining as well. And while more weak tornadoes are detected today than in the past, the frequency of moderate to strong tornadoes has decreased over the past 45 years.

Desertification: Increases in carbon concentration have not been associated with desertification, as the media seem to have concluded. As noted above, the frequency of drought has been steady to declining. In fact, precipitation data suggests that patterns of variability in rainfall do not square with the predictions of climate models. In fact, the world has seen an increase in green vegetation since 1985, even in arid regions.

Ocean acidification: The reported declines in ocean pH levels over the past few centuries are actually smaller than the normal seasonal variation in pH levels. The presumed negative impact on sea life appears, after all, to be minimal to nonexistent (see the same link).

Higher alpine tree lines: We’ve been waiting. It hasn’t happened, but that hasn’t stopped some activists from stating it as established fact.

Armadillo northward migration: I’ve heard this cited as “proof” of global warming. The range of armadillos extended as far north as southern Missouri and Kansas in the early 1970s, so this isn’t new. In fact, armadillos began their migration northward into the U.S. before the mid-1800s. Some biologists have attributed the migration to warming but acknowledge many other reasons, including more forested habitat in the north and factors such as movement of cattle by rail. Armadillos burrow and are able to keep warm underground in the winter. Of course, a series of warm winters can bring them further north along with other species, but a few cold winters can take a toll on the population and push them south again.

U.S. carbon criminality: U.S. CO2 emissions have been in almost steady decline on a per capita basis for at least seven decades, long before the carbon freak-out began. The declines have resulted largely from the normal market process of competitive efficiency in production. China leads the world in total annual CO2 emissions by a wide margin, about 80% ahead of the U.S. in 2017. Total U.S. emissions actually declined in 2017 for the third straight year, while emissions in China, the EU, and for the world all increased. In fact, China was actually in compliance with its pledge under the Paris Accord despite the increase, so the pledge was not especially ambitious.

High social cost of carbon: The estimates used by the Environmental Protection Agency are plagued by poor methodology and are subject to great uncertainty. Some studies rely on a series of tenuous causal links, such as CO2 emissions to global temperatures to ice melt to sea level to real dollars of coastal damage many years hence, all without considering variances at each stage, and assuming zero effort to adapt or mitigate damages over long time frames. A shortcut approach relies on historical correlations between temperatures and such measures as heat-related deaths, labor productivity and real output. These estimates extrapolate old relationships to the distant future and ignore the very real human tendency to adapt. The underlying assumptions are undercut by such basic facts as ongoing migration to warmer regions. The estimates also fail to account for the likelihood that warmer weather will improve agricultural productivity.

The public’s interest in climate change has waned, and no wonder: sensible people do not buy hype and demands for sacrifice in the face of contradictory evidence. Revelations of statistical fraud have led to even more skepticism. And when your “proof” is founded on model extrapolation, often theoretically-based rather than empirically-based, you’re skating on thin scientific ice. At this link, Steven Hayward has an interesting take on the public’s increasingly jaundiced view of global warming activism:

“Scientists who are genuinely worried about the potential for catastrophic climate change ought to be the most outraged at how the left politicized the issue and how the international policy community narrowed the range of acceptable responses. Treating climate change as a planet-scale problem that could be solved only by an international regulatory scheme transformed the issue into a political creed for committed believers. Causes that live by politics, die by politics.”

Pruitt Out At EPA; So Is Eco-Absolutism

13 Friday Jul 2018

Posted by Nuetzel in Environment, Regulation

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Andrew Wheeler, Clean Air Act, Clean Power Plan, Clean Water Act, Compliance Costs, Endangerment Finding, Environmental Justice, Environmental Protection Agency, EPA, Ledyard King, Navigable Waters, Paris Climate Accord, Scott Pruitt, Social Cost of Carbon, Sue and Settle, Superfund, Transparent Science

Green munchkins celebrated the fall of a house of cronyism earlier this month when it crashed right on top of EPA chief Scott Pruitt. Not that the Environmental Protection Agency has ever been free of cronyism and wicked warlocks, but Pruitt stumbled into an awkward appearance of coziness with industry representatives and was seemingly too fond of his expense account. The munchkins, however, will be sorely disappointed to learn that Andrew Wheeler, Pruitt’s replacement on at least an interim basis, will press forward with the same deregulatory agenda. They might imagine Wheeler as the surviving Warlock of the West, but the munchkins are incapable of understanding the deeper nature of wickedness at the EPA.

The agency took an expansive role during the Obama Administration (see this note on “environmental justice”, and this on the use of the “social cost of carbon” in rulemaking, and this on water regulation). Aggressive action was directed at emissions of carbon, a trace greenhouse gas (four parts per 10,000), but one that is necessary for life. In 2009, the EPA reached its “endangerment finding” that greenhouse gases, including carbon, pose a threat to humanity that must be addressed under the powers conferred upon the agency by the Clean Air Act. The Obama Administration viewed this finding as a regulatory carte blanche, ushering in a series of draconian, high-cost measures to reduce U.S. carbon emissions. Unfortunately, the environmental lobby is notorious for its inability to see beyond first-order effects. It cannot come to grips with the fact that green policies often waste more resources than they save, undermine the economy, infringe on liberty, and have their greatest negative impact on the poor.

President Obama also pushed for American participation in the Paris Climate Accord, which would have required transfers of billions of dollars of wealth to the often-corrupt governments of less developed countries for alternative energy projects. Beyond green energy objectives, this was presumably restitution for our past carbon sins. Whatever shortcomings Pruitt might have had, I valued his leadership in opposition to the Paris Accord and his role in dismantling the EPA’s overzealous regulatory model.

Pruitt might have earned praise from the green lobby in at least one area. He placed particular emphasis on streamlining Superfund site remediation, including a radioactive waste site in the St. Louis area. It is one of the so-called “top-10” sites that have been given high priority by the EPA. But there are 1,300 Superfund sites across the country, so Andrew Wheeler will have to be creative to succeed with more than just a few of these cleanups.

Ledyard King discusses the likely course of Scott Pruitt’s legacy under Wheeler, including continued opposition to the Paris Accord, reversing or deemphasizing renewable power mandates, reduced staffing and fewer enforcement actions. The Clean Power Plan is slated for replacement with rules that are not prohibitive to coal-fired power. Emissions from coal-burning are already heavily regulated, and CO2 and its unproven harms do not offer a valid pretext for a wholesale shutdown of the coal industry. Actions under the endangerment finding, if there are any, are likely to be more circumspect going forward. However, there are disconcerting reports that the Trump Administration may seek to subsidize or protect coal interests from more cost-effective alternatives, like natural gas.

According to King, Wheeler will continue Pruitt’s effort to balance representation on EPA advisory boards between academicians and business and state interests, include more geographic diversity on these boards, and end grant awards to members. Wheeler will continue to push for EPA rule-making based on fully-transparent science, rather than studies relying on private data. There are also likely to be efforts to stop “sue-and-settle” actions used by partisans to gain court-ordered consent decrees, which subvert public participation in the regulatory process.

The endangerment finding combined with the dubious and notoriously uncertain “social cost of carbon” gave EPA regulators almost unbridled power to control private activity. This ranged from questionable efficiency standards, uneconomic mandates on energy sources, and prohibitive emissions standards. The EPA also promulgated an expansive definition of “navigable waters” as an excuse to regulate virtually any puddle, or sometimes puddle, as wetland under the Clean Water Act. This overzealousness is a consequence of over-application of the precautionary principle, under which any prospective risk to humanity or the environment provides a rationale for regulation, taxation, or prohibition of an activity. It is also a consequence of refusing to recognize that government regulation, when it offers any benefit, has diminishing returns. The compliance costs of EPA regulations have been estimated to exceed $350 billion annually, a substantial impediment to economic growth that imposes cruel penalties on business, workers, and consumers. It is all the worse that these effects are strongly regressive in their impacts across income levels. Scott Pruitt may have been his own worst enemy, but his departure at this point might well advance the much-needed deregulatory agenda, as it is now that it is in the competent hands of Andrew Wheeler.