By Sheldon

Not long ago the web was abuzz with the news that a judge had ordered EPA Director Scott Pruitt to disclose the climate science behind his claims that deny accepted science on global warming. Scientific American (“Judge Orders EPA to Produce Science behind Pruitt’s Warming Claims”) reported that:

Not long after he took over as EPA administrator, Pruitt appeared on CNBC’s “Squawk Box,” where he was asked about carbon dioxide and climate change. He said, “I would not agree that it’s a primary contributor to the global warming that we see.”

The next day, Public Employees for Environmental Responsibility, or PEER, filed a Freedom of Information Act request seeking the studies Pruitt used to make his claims. Specifically, the group requested “EPA documents that support the conclusion that human activity is not the largest factor driving global climate change.”

Another post on Daily Kos gives some idea of the kind of “science” we can expect from Mr. Pruitt and his ideological defenders. This situation constitutes yet one more example of the fallacious and questionable research that lies (pun intended) behind so much of conservative discussion on global climate change. Like everyone else, I do take some pleasure at the prospect of Pruitt having to explain to a larger audience what most of us already knew regarding the scientific basis for his political ideology.

However, by presenting such an easy target, ripe for debunking, other more important issues go unremarked, or even unknown by most people. As such, watching Pruitt flail around like a hooked bottom-feeder is a distraction from where the real battle over global warming policy is taking place.

Most people who are at all familiar with how things work in Washington understand that administrations come and go, but agencies remain. This vast bureaucratic inertia constitutes a built-in safeguard against ideological extremism, as was the intention, although reducing that bureaucracy has been an ongoing project for the GOP since the Gingrich revolution at least. Trump’s attacks on government agencies are particularly deep and wide-ranging—and dangerous—but they are hardly new.

This means that there has always been some disconnect between the ideology of the Director appointed to head any given agency, and the way things are actually done. In other words, while Pruitt’s climate denialism is infuriating and reprehensible, its actual influence on the development of EPA policy as it’s done deep in the bowels of the agency is limited.

A friend of mine, Dr. Dave Bella, a retired professor of Civil Engineering at Oregon State University, discovered this when he prepared a 20-page comment on a proposed repeal of carbon emission guidelines for generator plants powered by fossil fuels. As part of his research, he went deep into the EPA’s documentation in order to ascertain just how much of their policy was actually based on junk science. The answer was, practically none. The scientific data and climate assessment models used by the EPA under Trump is virtually identical to that used by the Obama administration. Back in the cubicles and corners of the agency, where these matters actually get thrashed out and the policy sausage gets made, the junk science does not hold sway (at least for now).

Instead, the EPA is using a different strategy apart from relying directly on junk science; they are instead focusing on the following two points:

The “forgone climate benefits” of repealing the CPP are small. That is, the impacts of climate change resulting from the emissions of coal fired electricity generation in the U.S. are far less than the costs stopping this use of coal.

The uncertainties are far too great to justify the actions of the CPP.

Digging further, Dave realized that:

Despite impressive research, sophisticated models, brilliant experts, and extensive calculations, these two key practices dominate assessments and the decisions that follow from them. These practices have been accepted as precedents. But, these practices all but assure that actions to reduce carbon dioxide emissions will not occur. (Emphasis in original)

Costs and Benefits

Let’s look at the first point. U.S. law requires that major projects and policy changes be subjected to a cost-benefit analysis. In other words, will the costs of this new policy outweigh its benefits? This is a tangled and complex subject, with mind-mangling justifications brought to bear over what constitutes a “cost” or a “benefit” that can stray into the realm of the Kafkaesque. For instance, if a million people quit smoking, this is a “cost” because of the hit to the economy due to a decline in cigarette sales—you get the idea.

These analyses use a number of assumptions, one of which is that there will always be exponential economic growth. I am not an economist, nor am I familiar with the math involved, but I’m told by people who are that in the case of global warming, that assumption cannot stand. There are models under development that take the reduction in economic growth into account, but they are fairly new and not yet in use by the EPA.

Essentially, it all comes down to something called the social discount rate. It is used to answer the question, for instance, of whether we can “grow out way out” of a problem; will technology come to our rescue? In our case, the SDR is a kind of summary variable that reflects how well our economic and technology can handle a given problem over time. With the right SDR, the problem will eventually take care of itself. Incidentally, Dave told me that if the same models being used to evaluate the benefits of addressing climate change had been used to evaluate slavery in the ante-bellum South, the conclusion would have been that the costs of freeing the slaves would have outweighed the benefits.

But apart from questionable assumptions behind the models, there is another, perhaps more important factor which is that the problems posed by global warming have no precedent in environmental science. In the past, it made sense to subject, say, environmental waste problems to this kind of analysis; the river was dirty, so you stopped the influx of waste by building a treatment plant, and the impact of the pollutants went away. Global warming isn’t like that. Even if we stopped all emissions today, the impacts would continue for centuries. But the current methods of cost-benefit analysis don’t take this into account. To make matters worse, the social discount rates used by the Obama Administration were much too optimistic, and those of the Trump Administration even worse. By the estimates of both administrations, the problem would go away by itself and we don’t need to do anything about it.

This is the real battlefield where the fate of global climate change policy is being fought, where fantastical, cynical, or merely questionable justifications are incorporated into analytical models that are almost certain argue against taking action.

Certainties Surrounding Uncertainty

The second point is to invoke uncertainty, that we just don’t know what will happen. I find this to be incredibly cynical, especially since we are dealing with a global climate which is one of the most complex natural phenomena imaginable; it has uncertainty baked in. It is a fact of life that will never, ever go away. The only way one manages to reduce uncertainty is to run numerous experiments, but since we only have one planet, the experiment can only be conducted once.

To some degree, climate scientists have painted themselves into this corner by insisting on developing models that can be used to make predictions (How this came about goes back to the origins of environmental science in the early days of the Cold War, but that’s another story). Because these predictions will always contain some level of uncertainty, this can be used by climate skeptics to cast doubt on the process. It also obscures the fact that while science is great at coming up with conclusions, what is really needed is a decision. Conclusions ought not to be taken in the presence of too much uncertainty, and they can almost always be put off; “More research is needed.” Decisions, by contrast, nearly always involve uncertainty, sometimes a lot of it. But they usually involve timetables or deadlines with little accommodation for the anodyne of certainty.

The bottom line here is that uncertainty cannot, must not be used to justify inaction. Even if we don’t know the details, or can’t predict events with complete accuracy, we do know that if nothing is done, bad things will happen. The EPA proposal for rolling back emission guidelines states,

“The EPA also plans to carry forward the approach that underscores the uncertainty associated with any agency action of this magnitude, especially in actions where discretion is afforded to State governments.” (As cited in Dave’s paper, p. 3)

I’ll let Dave have the last word on this point:

Clearly, “the approach that underscores uncertainty” is now and will be a driving force that will be carried forward. And, a primary outcome of this use of uncertainty has been, is now, and will be to prevent limitations on carbon emissions. A simple word count of the 2017 EPA RIA provides indicators of this approach. My own count of words and phrases found the following: “uncertainty” 122, “uncertainties” 40, global climate change 0, global warming 0, climate change” 8, “irreversible” 0, “long-lived” 0, “catastrophic” 2, “intergenerational” 3 and others also revealing.

The issue that concerns me is not uncertainty Itself. I accept uncertainty as a given! What concerns me is the use of uncertainty to avoid and cover up the intergenerational consequences of continuing our emissions.

It’s long past time that environmental advocates heed the distraction of junk science and bring these deeper economic and (for lack of a better word) philosophical issues into the light. Personally, I take some comfort in the fact that once exposed to wider public scrutiny, they will prove to be as arbitrary, cynical, and flimsy as the rest of the justifications that prevent action in the face of an existential threat.