The OTA and Environmental Policy

This week's change in the Environmental Protection Agency's stance on carbon dioxide is an excellent example of why the Office of Technology Assessment needs to be reopened. In short, the Obama administration declared that "carbon dioxide and five other industrial emissions threaten the planet."

Leaving aside the threatening the planet thing, it is worth noting that this change was brought about, in part, because the U.S. Supreme Court--not a group of scientists or even scientifically trained lawmakers--declared that CO2 was a pollutant under the Clean Air Act and, as such, subject to regulation under the EPA. The Bush Administration has ignored the ruling, for the most part, just as the U.S. Senate voted overwhelmingly to reject the Kyoto Treaty during the Clinton Administration, for the simple reason that the regulations required to comply with Kyoto would impose serious costs on our economy. The Wall Street Journal continues:

Lamar Alexander of Tennessee, chairman of the Senate Republican Conference, sought a middle ground, proposing to focus carbon caps on coal-fired power plants and vehicle tailpipes -- and holding off any move until the nation emerges from recession.
American Electric Power, a utility giant with 5.2 million customers in states from Texas to Michigan to Virginia, is already considering what coal plants would have to be shuttered and how high rates would have to go to comply with either a regulatory or legislative mandates to curb carbon dioxide.

Senator Alexander's take might make sense as a fall-back position, but the simple fact is that additional environmental regulations will slow down an already-troubled economy. Want to stay in recession for a few more years? Carbon dioxide regulations will do that, as businesses will have to pay heavy fines, make alternate investments, or just plain go out of business because they can't meet the technological needs of complying with new CO2 regs.

Regardless of the good intentions of the regulators and environmental-protection lobbyist groups, the end results will be less energy production, as witnessed by American Electrical Power decision above, and also less movement of goods and services. Trucks and planes are the primary means of getting goods and services to market, and if more truckers and airlines face bankruptcy due to lower sales or higher regulatory costs, our economy will grind to a screeching halt. People also will travel less because businesses pass on higher costs to the consumer. That means an even slower commercial aviation sector. And with a sicker economy, where will Obama get the tax revenues to pay for his massive budget?

Again from the WSJ:

A proposal by President Barack Obama would cap the emissions of greenhouse gases, then force polluters to purchase emission permits, which could be traded on the open market. The details of the cost of carbon credits have been left to Congress, although Mr. Obama has said he wants all emissions covered, with no allowance for free emissions, as some business groups and lawmakers want.

Interestingly, the "cap and trade" carbon credit scheme was born at NASA, where scientists needed to find a fair way to get time on the limited number of instruments available on the Galileo spacecraft orbiting Jupiter. Since lots of people had experiments they wanted to run and there were only a limited number of instruments aboard the orbiter, the Galileo team came up with a way to trade time. Someone considered applying the same logic to how much pollution would be allowed in a given region, and thereby allowed businesses to pay for more "carbon credits" to make up for additional pollution, or make a profit by improving efficiency and selling their lower carbon needs to companies that need them. This system has also been used to control the production, distribution, and use of electrical power.

Sounds great, right? Well, maybe. However, there are a couple of problems with the cap-and-trade system, the first of which is that the "experts" setting up the system established an arbitrary level of "total pollution" allowed or energy available to the system. They make no allowance for the possibility that their standard for carbon emissions might be too stringent (in the CO2 example) or that the amount of energy available might increase through new technologies in the power grid example.

Ah, but we're not done yet...

The details of the cost of carbon credits have been left to Congress

Some proponents of the cap-and-trade system have called this a "free market" approach to pollution control. That would make sense if businesses generating carbon dioxide were permitted to set the price based on market forces. However, as noted above, Congress would be setting the price/value of carbon credits, which means another government intrusion into the marketplace. Of course this could be done on purpose, as it puts a great deal of power into the hands of Congress and makes them seem like the "good cop" to industry--better to deal with representatives or senators than the bureaucrats at EPA. Talk about a protection scheme! So your choices on the price of carbon credits are a bunch of unscientific lawyers in Congress or unelected bureaucrats at the EPA. This isn't a choice between good and bad, but bad and worse.

The impact of the EPA finding could be dramatic. Using the Clean Air Act, the EPA could raise fuel-efficiency standards for automobiles, such as by authorizing nationwide adoption of California's rules for greenhouse-gas tailpipe emissions.

That could require auto makers to produce more hybrid and electric vehicles, such as the Chevrolet Volt plug-in hybrid under development by General Motors Corp. The Volt, however, is expected to carry a sticker of about $40,000, or roughly twice the price of a conventional Chevrolet Malibu sedan.

This has already become an issue. With GM, Chrysler, and Ford taking bailout money from the government, Uncle Sam has seen that it can pretty much dictate to these companies whatever they want, from capping CEO salaries to picking what cars they can build to firing the CEO. The American public might not want the Chevy Volt, but that's what the government wants to give them. And what are our poorer citizens supposed to do if they can't afford the Volt?

Another side effect of the Volt and the other brands' hybrid vehicles is that new technologies are expensive, just like new pharmaceuticals on the market. Companies make the price of these vehicles more expensive to recoup their investment until such time as 1) the vehicles are a proven money-maker and 2) they've improved enough to be mass-produced and thereby reduced in price. Government doesn't think that way, because points 1) and 2) are private-sector ways of thinking. Government says, "This is the car you will be allowed to buy, and if you don't like it, you can't have another."

How did CO2 become a pollutant, anyway?

Carbon-dioxide levels in the Earth's atmosphere have fluctuated wildly for millennia; at one point billions of years ago, it was the dominant gas in the atmosphere.

However, the EPA ruled that today's higher concentrations are the "unambiguous result of human emissions." Concentrations of carbon dioxide and other gases "are well above the natural range of atmospheric concentrations compared to the last 650,000 years," the agency said.

A couple of questions come to mind here:

• If CO2 levels have fluctuated wildly (and naturally) in the environment over the last 650,000 years, how are we to determine what constitutes a "normal" level of the gas?
• And what is so special about the last 650,000 years as opposed to the last million years? Or 65 million years, for that matter?
• Who is setting the levels for what's deemed appropriate, and what guidelines are they using?

The WSJ notes:

In its decision, the EPA stressed that it considers CO2 and other so-called greenhouse gases to be pollutants because of their role in propagating climate change, not because of any direct health effects.

This is almost unbelievable arrogance on the part of the EPA. Instead of using an objective standard for harm, like "X parts per million of Y compound in the atmosphere has been determined to cause Z health consequences," they instead have opted to make CO2 a pollutant based on a theory that is still in debate. After all, just in the last 30 years, we have shifted from fears about global cooling (1970s) to global warming (1988-2007) to now global cooling again. Unable to decide which horse to bet on, environmental activists now use the ambiguous term "climate change" so as to hedge their bets and still get the regulations they want.

The EPA did acknowledge some positive impacts from higher CO2 concentrations.

What might those impacts be? And why aren't those impacts weighed against the potential downsides? What standards of "positive" and "negative" impacts are being used, and who is deciding and enforcing what side of the climate-shift debate should be considered most important?

This is the sort of situation that calls for a new arbiter. By all means, we should leave data collection and science to the scientists. However, when it comes to deciding what is to be done about scientific findings--especially on a federal government level--such decisions should be made in the open by elected officials. There is never only one solution to a technical problem. This is what separates engineering from science. Science might determine that, in fact, the Earth is warming due to human-based industrial activities, and said warming will produce negative effects on human civilization. Engineers and political decision makers have the obligation to come up with and decide upon the best solutions. For instance:

• If too much carbon in the atmosphere is the problem, are there newer, more efficient ways to sequester the carbon without regulating and taxing the productive economies of the West?
• If temperature increases are the problem, might we not place a large Fresnel lens at the Earth-Sun Lagrange (L2) point to reduce the amount of solar radiation the planet is receiving?
• If flooding from melting glaciers is the problem, how much would it cost to build more homes on stilts or more cities behind walls?
• If the Earth absorbing too much sunlight is the problem, mightn't we increase the albedo (reflectivity) of our cities by requiring white-tile roofs instead of gray or black?

Again, the science might be what it is--and the data are still coming in--but the decision about what to do with the findings should be debated in an open forum, not decided arbitrarily based on the personal political biases of some very partisan bureaucrats or self-appointed "experts." The OTA can provide the necessary buffer between information and decision-making that makes our society stronger than those that suffer from command-and-control economies. We'd best start now, before the EPA starts acting "for our own good," even if the results of their regulations turn out to be very, very bad.