Inhofe and Republicans are Right: Analysis of Climate Bills is Flawed

Republicans are absolutely right and absolutely wrong when it comes to EPA analysis of climate legislation. They are right that the analysis has flaws, but they are wrong about what should be done about it.
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If you've missed it, the Republican members of the Senate and Environmental Public Works Committee failed to show up to work today.

As part of the Republican theatrical obstructionism to moving forward with the Kerry-Boxer Clean Energy Jobs and American Power Act, the Republican senators are staging a boycott of Committee hearings despite Senator Boxer's appeals for bipartisan efforts to find solutions for serious problems. (All of this, of course, leading to a question: Senator, what is your excuse for skipping work today?) The recalcitrant Republican Senators' central argument is that the Environmental Protection Agency (EPA) has not done a thorough analysis specifically of Kerry-Boxer. And, within that, that the EPA analysis of the House legislation (Waxman-Markey American Clean Energy & Security (ACES) Act) is simply inadequate.

First, let's face facts: does anyone think that fossil foolish James Inhofe is leading this Republican rebellion with an intent of serious engagement on moving forward with climate change mitigation legislation with better analysis in hand? Once you've finished laughing, we can move forward. Thus, the fact that the EPA provided simply a meta analysis of Kerry-Boxer, based on work on Waxman-Markey, has little real relevance to decision-making and the situation at hand.

Second, let us state a fact: The Republicans are absolutely right and absolutely wrong at the same time when it comes to EPA analysis of climate legislation.

They are right that the EPA analysis has serious flaws.

But, they are absolutely wrong about what those flaws are and what should be done about it.

Voinovich makes much noise about the imagined costs of acting to mitigate climate change but doesn't begin to address the issue of the costs of inaction nor does he spend any time discussing the quite significant benefits (from improved health to improved productivity to improved student performance to ...) that will come from taking serious action.

EPA did perform an analysis of the Waxman bill, but a detailed look at EPA's work, reveals the use of assumptions, which, in some cases, defy practical and technological realities. ... In addition, major provisions of the bill weren't modeled at all, including various mandates and requirements that will diminish the effectiveness of the trading system and increase overall program costs.... EPA's modeling is only as good as the assumptions built into it. Unrealistic assumptions about technology and offset availability and the lack of a comprehensive analysis of the entire legislative proposal greatly limit our understanding of the potential costs of the program.

Senator Voinovich actually has had a hold on an appointment to the EPA, demanding that the EPA do an analysis of climate legislation to his satisfaction or else he will continue the hold.

While the hold is a sad example of a problem in our legislative process, Voinovich is absolutely write that EPA's analysis is flawed ... but for absolutely the wrong reasons.

As per the words above, Voinovich doesn't cease to speak of the failure of the analysis to examine adequately "potential costs", he never (ever) raises the issue of potential costs of inaction and the potential (no, the real) benefits of action.

The core problem for EPA analysis is that it is far too narrowly defined, focusing almost solely on only one segment of a four-part equation. The analysis is heavy on the costs of action in budgetary terms but with very limited discussion as to the benefits of action and, in essence, zero focus on the costs and (very limited) benefits of inaction. The EPA (and CBO and others) inadequately, for example, calculates the benefits to the economy of reduced fuel prices due to reduced demand. (Basic capitalist equation: supply vs demand. Reducing demand is, functionally, the same as increasing supply for price equation purposes.) The EPA did not consider the health care implications of fossil fuel pollution and how moving forward with global warming mitigation will, as a necessary corollary, drive down the pollution that is so seriously costing American society. (According to a study recently released by the National Academy of Sciences, this is a $120 billion / year cost. Oh, by the way, that study limited its examination to the use of fossil fuels and did not count implications of its production.) They do not examine productivity improvements that will occur due to greener work environments (and improved educational performance due to greening schools). Nor is there a valuing of the strengthened dollar due to reduced oil imports. Nor ... The list of absent material is extensive enough to fill multiple books. And, these analysis do not even begin to calculate perhaps the most significant financial value of moving forward with climate change mitigation legislation: the insurance value for reducing the potential of (near) worst-case catastrophic climate change.

And, well, there is the real challenge that these analyses focus on "gross domestic product", which is truly an inadequate measure of a society's health and strength. For example, an oil spill will actually increase GDP (at least in the near term) due to the clean-up activities. Fossil-fuel pollution actually boosts (at least near and mid term) GDP due to the health care costs of treating asthma, mercury poisoning, cancers, and other resulting illnesses from that pollution. Thus, there is a fundamental question: do these analyses provide a meaningful window on societal strength and well-being?

Thus, James Inhofe, George Voinovich, and other Republican Senators staging their theater event today are absolutely right: the EPA (and CBO and ...) analysis of climate legislation is inadequate. More importantly, Inhofe, Voinovich, and others are absolutely wrong as to why. Rather than failing to examine the true costs of action, these analytical organizations are failing to provide a robust window as to the much higher true costs of inaction and the much higher true benefits of action.

PS: Let us be clear, the problem really isn't with the EPA analysts. The EPA study team clearly recognized that there is a larger picture than their analysis.

While this analysis doesn't quantify the impacts of higher temperatures and other effects of increasing GHG concentrations, the U.S. Global Change Research Program (in its June 2009 report, "Global Climate Change Impacts in the United States") described the impacts that we are already seeing and that are likely to dramatically increase this century if we allow global warming to continue unchecked. In the report, it documents how communities throughout America would experience increased costs, including from more sustained droughts, increased heat stress on livestock, more frequent and intense spring floods, and more frequent and intense forest wildfires.

Sadly, this is the type of study limitation that Voinovich is not focused on fixing.

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