As Ed highlights below, the Obama administration has little interest in exploring the full cost of its climate-policy prescriptions.
James Taylor details another recent example in the Heartland Institute’s latest edition of Environment & Climate News.
As we’re all aware, the EPA recently declared carbon dioxide a harmful pollutant, open to regulation under the Clean Air Act. Obviously, such a finding fits nicely with President Obama’s plan to rein in CO2. As it turns out, however, not everyone in the Obama administration was keen on EPA’s hurried decision: an inter-agency memo took issue with the EPA’s rush to judgment.
The report states that
an endangerment finding under section 202 may not be the most appropriate approach for regulating GHGs [greenhouse gases]. Making the decision to regulate CO2 under the [Clean Air Act] for the first time is likely to have serious economic consequences for regulated entities throughout the U.S. economy, including small businesses and small communities. Should EPA later extend this finding to stationary sources, small businesses and institutions would be subject to costly regulatory programs such as New Source Review.
The Finding should also acknowledge that EPA has not undertaken a systematic risk analysis or cost-benefit analysis,” the memo continued. “In the absence of a strong statement of the standards being applied in this decision, there is a concern that EPA is making a finding based on (1) ‘harm’ from substances that have no demonstrated direct health effects, such as respiratory or toxic effects, (2) available scientific data that purports to conclusively establish the nature and extent of the adverse public health and welfare impacts are almost exclusively from non-EPA sources, and (3) applying a dramatically expanded precautionary principle.
This, of course, should come as no surprise, since thorough cost-benefit analyses are completely absent, thus far, from federal decison-making on climate issues. In fact, there appears to be no need for them, since no cost is too high to save all of us from climate catastrophe. If honest, exhaustive analyses were performed, they’d be DOA anyway.
In the ECN piece
, Taylor writes,
The memo was leaked to the press on May 11 without a signature or named author. Media coverage reported the author was likely Shawne Carter McGibbon, acting chief counsel for the Office of Advocacy of the U.S. Small Business Administration, a White House executive agency.
Attempting to characterize the document as a partisan attack, an Obama administration official derided the author as “a holdover from the Bush administration” in an interview with the Associated Press.
The attempt to paint the author as partisan was roundly criticized as misleading and disingenuous. While it is true McGibbon served in the Bush administration, she was initially appointed to the Small Business Administration by President Bill Clinton, and before that she worked for former Democratic Rep. Al Wynn of Maryland.