Steven Cohen writes in the Huffington Post:
EPA has historically been quite careful about gradually phasing in environmental rules to minimize economic disruption. (…)
According to this [OMB] analysis, EPA issued 30 major regulations from 1999 to 2009 at an estimated cost of $25.8 billion to $29.2 billion against estimated benefits ranging from $81.9 billion to $533 billion. As a society we have really not taken leave of our senses. When we make policies, the benefits generally outweigh the costs. Of course, for any given corporation or particular factory in any given financial quarter, the costs may be far higher than the benefits. And the costs might be borne by one group while the benefits may be felt by another. Still the idea that environmental rules kill jobs and destroy our quality of life is deceptive propaganda. It is part of a subtle and symbolic political campaign with the goal of delegitimizing government’s role in protecting the environment.
The rest of the article is well worth reading as well, in which Cohen fulminates against the “fact free climate policy debate” and the inconsistent position of the antiregulatory zeal that’s been getting more political momentum:
We seem willing to ensure [via government regulation] that the food we eat and the toys we give our children are free of poison, but seem reluctant to keep our land, air and water free of toxics.
(Hat tip Paul Luttikhuis)
Tags: cost benefit analysis, environmental economics, Environmental regulation, EPA, Steven Cohen
My view on climate change 
January 7, 2011 at 22:53
The problem with CO2 is no one has actually shown that it has caused any harm. In fact, most people view the claimed effect – a warmer climate – as a good thing. Sure, lots of people run around claiming that everything from cockroaches to earthquakes are caused by CO2 emissions but no one has actually shown that their claims are true.
This separates this like smog, acid rain, chemicals in rivers are all tangible and noticeably affect real life. This means the benefits of reducing pollution is measurable and spending to reduce it can be justified.
OTOH, ‘reducing’ CO2 emissions will never provide evidence that it made a difference or was just money dumped in a hole. This means CO2 reductions as a policy will always be a bad investment even if other forms of pollution control have had a positive effect.
January 8, 2011 at 00:05
Sherwood Rowland:
Increasing GHG in the atmosphere causes the climate to change in ways that will cauase increasing damage to society. It is the future increasing damage we’re trying to prevent or at least decrease to manageable levels. When the shit hits the fan, it will be too late to prevent it in a manageable way because of the large inertia in the energy system, the carbon cycle and the climate system.
There are big risks involved with postponing action.
January 8, 2011 at 10:01
TimG, you claim that “most people view the claimed effect – a warmer climate – as a good thing”. Any evidence for that? I know that the Inuit vehemently disagree with you that warming is a good thing (and they mostly live in one of the coldest places on earth: the arctic). I also have spoken to quite a few people living in Africa that are not too happy about even more warming. And then there are the people who realise that warming is not the only change in climate that can be expected.
January 9, 2011 at 07:54
Tim
“The problem with CO2 is no one has actually shown that it has caused any harm.”
Well there are a few people who would disagree with that statement, like 97% of climate scientists, virtually every major scientific organization in the world and at least 90% of scientists in general. Actually the greenhouse effect of CO2 has been known since 1824.
The greenhouse effect has been accepted science for a century.
Fourier calculates colder earth without an atmosphere (1824)
Tyndall discovers relationship between CO2 and long-wave radiation (1859)
Arrhenius calculates global warming from anthropogenic CO2 (1896)
Chamberlin models global carbon exchange including feedbacks (1897)
Callendar predicts global warming increase catalysed by CO2 emissions (1938)
Revelle predicts inability of oceans to sequester anthropogenic CO2 (1958)
from “The Discovery of Global Warming” by Spencer Weart
the greenhouse gas effect was first proposed by Joseph Fourier in 1824, proven to exist by John Tyndall in 1858, and quantified by Svante Arrhenius in 1896.
But for Rush Limbaugh and the Republicans and tea baggers, Global Warming is just an agenda cooked up by Al Gore and other liberals.
January 9, 2011 at 16:18
The problem with CO2 is no one has actually shown that it has caused any harm.
TimG, there is no proof, but there are a lot of lines of evidence that the globe is warming and that it is caused by excess CO2 that human activities add to the atmosphere. You do not want to know what the proof looks like.
January 9, 2011 at 19:51
The globe has warmed and it certainly appears that anthropogenic emissions contributed in part to this warming. Very, very few dispute this, although I’m sure we’ll see some here later in the day.
However, we really do not know very much at all about how much it is going to warm and what the likely effects will be. The quality of data (and, if I may be so bold) and hypothesizing regarding possible impacts is not of the same quality as it is of the original physics. (I’m sure there are disagreements with this as well.)
It may take more than 30 years to have a better idea of what the impacts and extent of global warming will prove to be. Some of those impacts may be in motion before that time. It makes sense to take prudent actions to put ourselves in a better position to act on this information.
I have no problem with the EPA regulating large scale emitters in the U.S. incentives for renewing the existing infrastructure for power generation have been badly skewed for 50 years, and hastening the retrofitting or replacement of ageing coal plants is not at all a bad thing.
If this were being done without the rhetoric, it probably would not be at all controversial.
January 9, 2011 at 23:23
Tom,
As to your last sentence:
If there hadn’t been such strong opposition to these kinds of measures, they could have been implemented decades ago.
January 9, 2011 at 23:31
Who to believe? Tom Fuller … or thousands of professional scientists who’ve been studying the issue their entire academic lives?
Hmmm … that’s a tough one.
January 10, 2011 at 13:11
Tom Fuller, write a book about it! One that will “swamp the conventional wisdom on climate change”.
Mosher is much better at that Trojan Horse-game you’re playing.
January 10, 2011 at 22:20
Ooh, Neven and dhogaza back to back. As usual, ignoring the topic and spewing ad hominisms. Cute–bookends for the vacuum between them.
January 10, 2011 at 22:40
Ooh, Neven and dhogaza back to back. As usual, ignoring the topic and spewing ad hominisms. Cute–bookends for the vacuum between them.
And as usual you have no difficulty in stooping to our level, or was that reaching up? :-B
January 10, 2011 at 23:19
Neven, do you really think that you should be immune from responses to your claptrap? How would that work macroeconomically speaking?
January 11, 2011 at 02:47
Well, Tom, you also said:
Yes, there are, thousands of scientists would disagree with your claim. The modern physical understanding is far advanced compared to (say) Tyndall or even Arrenhuis.
And I dare say there are thousands of scientists, professionals working in the field, who disagree with this:
So, once again, who to believe, the scientific consensus or Tom Fuller?
Also, you might look up ad hominem …
January 11, 2011 at 13:32
Neven, do you really think that you should be immune from responses to your claptrap? How would that work macroeconomically speaking?
I’m sorry, Tom, I don’t understand what message you are trying to convey here. Could you rephrase it and say exactly what you mean?
January 11, 2011 at 18:47
Hiya Neven
Would you care to explain your comment about a Trojan Horse game? (Not to mention why my esteemed co-author is better at ‘playing’ whatever you think he’s playing.)
Why would you infer that we are playing some kind of game? Because we wrote a book? (You will note that the conventional wisdom on climate change has in fact changed since the publication of our book, with the conventionally wise now admitting that the debate is not ‘settled.’ And no, I don’t think our book caused it–more like we caught the wave. But marketing speak is what it is.)
What game do you think we were playing? What game do you think I am playing now? What do you think I expect to win?
January 11, 2011 at 19:49
Would you care to explain your comment about a Trojan Horse game? (Not to mention why my esteemed co-author is better at ‘playing’ whatever you think he’s playing.)
Tom, I refer you to this blog post discussing the lukewarm position. Also read the comments, for instance the last one that refers to your esteemed co-author’s games.
So you write a book that is supposed to show that the debate is not settled, but at the same time you say that AGW is happening and it’s due to human activities? So, is it settled or not?
Unless you mean to say that the debate is one of not so bad consequences versus very bad consequences. But no one serious ever really said that this debate or the debate concerning solutions was settled.
For way too many years (thanks to the delaying tactic of the denial machine and gullible contrarians) the debate has been about ‘is it warming’ and ‘is it caused by humans’. Coincidentally when the position of denying both proposition becamse simply untenable – PR-wise – lukewarmers such as you started to enter the scene.
The message that people take away from your book, especially those that don’t read it, but see it featured prominently on WUWT and other places, is that the debate with regards to warming and humans causing it are still not settled.
And for that, my dear Tom, you bear a responsibility.
Did it never cross your mind that if you would want to be taken serious as a ‘lukewarmer’ (whatever that may be), it might have been better if you didn’t write a sensationalistic hitpiece that didn’t change one bit about climate change and the science that tries to explain it? It’s like saying you care about the future of golf, and then quickly write a book called ‘Tiger and his Pussycats!’ and in the description: ‘You will be shaken to the core and never look at golf the same way!!!!’
One the one hand you say Global Warming is real and caused by humans, on the other hand you actively participate in the besmirching of climate scientists and climate science by extension, along with the more typical denialists that don’t have a case when it comes to the science. Never mind all the other tripe you wrote before your CRUtape paparazzi stuff.
You are contradicting yourself, and IMO that’s the next natural stage in the delaying tactic. Either that, or you’re suffering from a lack of self-consciousness that permits you to hold several contradictory opinions at the same time. Some people (like Michael Tobis) think it’s the latter, and it could well be. For Mosher I’m pretty sure it’s the first.
Timeo Danaos et dona ferentes
January 11, 2011 at 20:53
Pity you didn’t read it Neven, or you would realize you’re scapegoating yet another person who believes in the science. But I guess that doesn’t matter, as long as you can deligitimize dissent–or medicalize it, as the end of your post seems to hint at.
But as far as I’m concerned, I see no need to pay any attention to criticism of me based on a book I cowrote that the critic doesn’t bother to read. How many different ways can I say that you come off like an idiot when you write crap about a book you didn’t read?
January 11, 2011 at 20:59
I believe the host at the site you referred us all to said pretty much the same thing using nicer words to your hatchet job on Lucia and Mosh, didn’t she?
I’ll just say it plainly. You’re an idiot looking for a cheap way to get into the forefront of blog commentary on the AGW side, but unwilling to do the work to deserve it.
January 11, 2011 at 21:00
What hatchet job on Lucia? Lucia is genuine.
January 11, 2011 at 21:05
‘Lucia is not so bad, but one of her main flaws is that people like Anthony Watts are her buddies and she closes her eyes and ears as soon as someone points to the Denial Machine. Naive is the best word to describe her.’
‘My description of Lucia and Mosher are indeed subjective, based on numerous comment threads here and there.’
Someone said by the comments ye shall know the blogger…
January 11, 2011 at 21:17
Like I said, Lucia is IMO genuine, whereas Mosher certainly, and you perhaps, are hypocrites and know it. And with ‘perhaps’ I mean to say that you are a hypocrite, but perhaps not aware of it.
‘My description of Lucia and Mosher are indeed subjective, based on numerous comment threads here and there.’
In that sentence is more honesty than you will ever be able to muster. I know my limitations. And you? You wrote Climategate: The Crutape Letters, something which would never have been written by someone who believes AGW is a potential problem.
Someone said by the comments ye shall know the blogger…
You are right, Bart doesn’t deserve either of us. All the best with your delaying tactics, Tom.
January 11, 2011 at 21:27
read the book
January 11, 2011 at 22:34
Someone’s gotta explain to me how someone could be a hypocrite and not know it. I would think that would violate laws of physics or something…
January 11, 2011 at 22:59
Tone it down please, this is getting tedious. And no namecalling, as someone said by the comments ye shall know the blogger…
January 11, 2011 at 23:06
Bart,
It’s too bad nobody is addressing the post. You have identified a study done by a government which spent money. My money. And the same government commissioned the study to determine the benefits of the government in question. Of course we should take a skeptical look at the item by item list, however, life is short.
As I expected, and apparently nobody else, the list appears to be entirely full of garbage numbers. For instance, the new regulations for salmonella implemented at a staggering cost of 74 million dollars, allegedly produced a 1.2 billion dollar benefit. Remember the huge egg recalls recently in the US. Pure bovine scatology folks.
Or how about the 4 million dollars invested for a 35 million dollar return for PILOT AGE LIMIT INCREASE — haha. Wow.
Reduced stopping distance for truck tractors – 46 million for 1.3 billion benefit – bull
The whole thing is a government funded propaganda exercise. The numbers are bogus, likely on both sides of the equation.
January 11, 2011 at 23:23
Well Jeff, go back to Lomborg’s Skeptical Environmentalist–he looks at cost benefits of some regulatory changes and finds that some are remarkably beneficial. Not always the ones that get pointed to. Had the EPA gone back further in time, they could have pointed at a number of regulations that even you would most likely support and which have yielded great benefits. Getting lead out of paint and gasoline being two examples that come to mind…
January 11, 2011 at 23:30
Tone it down please, this is getting tedious.
I apologize, Bart. One of my resolutions was not to write when I’m chagrijnig, but there you go.
ps If it wouldn’t be too much to ask: could you forward my e-mail address to JvdLaan?
January 11, 2011 at 23:37
Tom,
I’m not against reasonable regulation, I’m just naturally skeptical of a government proclaiming its own benefit.
January 12, 2011 at 00:49
Well, I think you’re right to be skeptical about that, but there are positive cases that exist.
January 12, 2011 at 18:23
I agree with Tom here, but Jeff probably also has point that such cost-benefit analyses are ultra-sensitive to the assumptions that go in it, and as a result shouldn’t be talken all too seriously. I’m not saying though that it makes them bull, as Jeff seems to suggest, and I don’t share his deep distrust (at times bordering on paranoia) for anything government related.
January 12, 2011 at 21:43
Errr…Bart, Jeff Id does not “seem to suggest” anything, he clearly says it IS bull. No need to provide evidence or argumentation, of course!
I’m not sure what he intends with linking the egg recall to the report: if he intends to indicate that DESPITE the new rules there still was an outbreak of salmonella enteritidis, fair enough. If he thinks the new rule resulted in the egg recall…think again.
January 13, 2011 at 02:38
Most I deal with on a daily basis respect my opinions slightly more than assumption of paranoia. I can rationalize my points and admit my error. Unfortunately, in this case it appears that I may be right again.
I challenge anyone to justify any of the single positively beneficial numbers in the entire program. Find just one item in the report above with a dollar benefit, look at the + vs – and tell me how it is accurate in detail.
Someone may find one but I bet nobody puts the effort in. That would be telling/depressing wouldn’t it! Read the words, report the results. Does any citizen of the world care enough to try?
January 13, 2011 at 10:21
Jeff, why don’t you ask the EPA to provide you with a sample calculation?
But do start with reading the guidelines:
http://yosemite.epa.gov/ee/epa/eed.nsf/pages/Guidelines.html
Of course, you will probably complain they estimate certain benefits at a too high monetary value. That’s where discussions on “accurate” become discussions on “values”, and not those of the arithmetic kind. For example, the EPA currently puts the Value of Statistical Life (VSL) at 6 million dollars. That’s based, in part, on how much people would be willing to pay to save their own life. Note that this is a drop of 2 million dollars compated to 2000…
January 13, 2011 at 15:54
Marco,
I wasn’t looking to refute claims about the hypothetical single defensible benefit number. There are too many numbers for a single one to make a difference in the study. I was making the point that nobody ever checks and if they do, nobody is there to listen to a critique. What does an indefensible study mean when nobody is there to read or critique it. It is kind of sad really as this looks like an area where the government could be cut back – eliminate fake studies.
Of course the government uses this sort of thing as a commercial for their own success — see how good we are with your money!! We’re wonderful, give us more so we can get bigger!
On an off topic but related note, my company put out an add for a job in assembly which started at 8.50/hr plus free benefits and received more than 100 applicants in the first two days. We give them a fourth grade math test. While they are 98% HS graduates, most cannot subtract, some cannot add. They have no ability to grasp a study like this and worse, wouldn’t have a clue that it may be flawed.
January 14, 2011 at 08:52
“May be flawed” is considerably different than “bull”, Jeff.
I would hope a HS graduate does know that a libertarian loudly proclaiming a study is fake, without providing any evidence it is, may well be due to his ideological bias, rather than the study really being fake.
January 14, 2011 at 18:52
Marco,
I pointed to three examples of bull. As my previous statement made clear, the study cannot be reversed by a few items. Also, you should be aware that the may be flawed quote addressed specifically “a study like this” which may be flawed and not specifically this study.
The gotcha stuff is tiring.
January 14, 2011 at 20:03
Then stop playing the “gotcha” game, Jeff. This is what you were trying with dismissing my criticism as not aimed appropriately. We still have your suggestion, and few people will disagree, that you called this a fake study:
“What does an indefensible study mean when nobody is there to read or critique it. It is kind of sad really as this looks like an area where the government could be cut back – eliminate fake studies.”
January 18, 2011 at 03:06
Can you defend one point of the study? Any single point with reasonable financial numbers? Can anyone?
January 18, 2011 at 03:07
A study is also indefensible if the facts for the defense are not available.