Reason Foundation - Authors > Kenneth Green

Crichton's State of Fear

info@reason.org (Kenneth Green) — Wed, 19 Jan 2005 00:00:00 EST

Many people can teach. Many people can tell great stories. But few people can teach by way of telling a great story. Dr. Michael Crichton, physician-turned-novelist-turned screenplay-writer is one of those few.

State of Fear (HarperCollins Publishers, 2004, 603 pages) is actually three books in one - a fast-paced thriller, like Andromeda Strain and Jurassic Park; an explication that's too rarely seen in fiction of scientific arguments, complete with 18 pages of references, and, finally, a five-page policy brief of the author's conclusions drawn from the science he learned while writing his novel.

Let's take a look at the three books within State of Fear one at a time.

Science Fiction

First and foremost, State of Fear is, like most other Crichton thrillers, more about people than it is about technology. While some sort of technology run amok is often at the heart of a Crichton thriller, it's rarely (if ever) the technology per se, that causes or cures whatever disaster Crichton concocts. Rather, it's the evil or hubris of the people behind the technology that leads to destruction or salvation. People who misunderstand this point have occasionally branded Crichton a Luddite, someone who fears technology (particularly after his portrayal of the dangers of nanotechnology in Prey). But his faith in science and technology is evident in its implacable progression, and especially in the positive role it plays in the lives of his various characters. Far from a Luddite, Crichton is more of a cynic, believing that whatever technology is used, someone is likely to abuse it - an idea that's hard to dispute given the sweep of human history.

The basic plotline of State of Fear is pretty straightforward: a globe-spanning cabal of radical environmentalists is trying to spur the adoption of greenhouse gas emission controls by creating "natural disasters" that they can link to manmade climate change. The bad guys have stolen or purchased all the coolest toys of the terror trade, from rocket systems that can create superstorms, to explosives and giant "cavitators" that can trigger landslides, to lightning-bolt projectors, and, yes, to poisonous octopi used to kill people they don't like in a particularly unpleasant manner. This nefarious gang is challenged by the too-cool-for-school Dr. Richard John Kenner who is both the lead agent for a super-secret anti-terrorist group and also happens to be a brilliant professor of Geoenvironmental Engineering at MIT.

Kenner and his assistant, Sanjong Thapa, follow the basic sidekick archetypes: one suave and debonair, the other reliable, adaptable and combat-ready. Not surprisingly, they regularly kick butt. Other good guy characters in State of Fear include George Morton, a philanthropic environmentalist who comes to realize that his donations have been redirected toward violent mayhem, and Peter Evans, the somewhat na�ve lawyer-cum-stalking horse used to smoke out the baddies. Heading up the bad guy side is Nicholas Drake, the Machiavellian head of NERF (National Environmental Resource Fund), showing once again that you can't have a global cabal of bad guys without a proper acronym. Drake is aided by an actor, Ted Bradley, who combines the most annoying elements of Martin Sheen's presidential portrayal in The West Wing and environmentalist/actor Ed Begley Jr.'s performance playing, well, Ed Begley Jr. One of the few downsides of the fictional element of State of Fear is that the bad guys aren't exactly the brightest bulbs in the chandelier; they have more wallet and weaponry than wit. Still, if you want to see who wins, who loses, and who gets eaten by cannibals, you'll have to read the book.

Science Fictions

The second book interwoven with State of Fear is the one that has generated the most controversy, sparking both trenchant attacks and staunch support for Crichton. Using numerous charts and graphs, Crichton (through the slightly pedantic lectures of Dr. Kenner and company) reveals the limitations in the so-called science of climate change, which has up to now convinced many people that human beings are going to destroy the world by using their SUVs to take their kids to hockey practice.

Among the lessons taught by Kenner and company: temperature records from around the world aren't particularly reliable; that global average temperature has changed independent of the level of greenhouse gases throughout history; regional temperature trends vary widely, from stability, to pronounced cooling, to pronounced heating. Crichton's characters also explain that most of the world's ice is not melting, as Antarctica, with some 90 percent of the world's ice, is getting colder - only 2% of Antarctic area has melting ice, the rest is getting icier.

Crichton also hits other climate- and eco-myths, explaining that the world's sea level is not rising faster than normal, the world isn't experiencing more storms or other extreme weather phenomena; DDT doesn't cause cancer, and that native people weren't noble savages living in harmony with nature.

Critics have singled out the mini-lectures within State of Fear for particular scorn, and it's true, some can get between the reader and the primary plot line. But with all due respect to my own more-than-capable teachers, I'd have given a lot to have had professors who could so clearly, efficiently -- and entertainingly -- convey as much complex information as Michael Crichton does in State of Fear.

Science Facts

Finally, Crichton's third book within State of Fear is something that I've never seen from a fiction writer before: a policy study explicated through the science revealed within the tale, and an Author's Message, explaining what Crichton thinks we should do based on what we know about climate change. Among Crichton's many logical conclusions three stand out:

"We know astonishingly little about every aspect of the environment, from its past history, to its present state, to how to conserve and protect it. In every debate, all sides overstate the extent of existing knowledge and its degree of certainty.
Nobody knows how much warming will occur in the next century. The computer models vary by 400 percent, de facto proof that nobody knows; and
Before making expensive policy decisions on the basis of climate models, I think it is reasonable to require that those models predict future temperatures accurately for a period of ten years. Twenty would be better."

Great storytelling has been a vehicle for education throughout the history of humanity, and, in our times of increasing scientific illiteracy, State of Fear may be a particularly appropriate way to expose common people to the scientific problems that plague the arguments supporting greenhouse gas regulations. State of Fear is an excellent novel that concisely and clearly presents the arguments long asserted by those who are skeptical of claims that we know the climate is changing, that we know what causes the climate to change, and that we know enough to take control over the global climate through the manipulation of greenhouse gases.

Dr. Kenneth Green is senior fellow at Reason Foundation and Chief Scientist at Frasier Institute.

California Dreamin'

info@reason.org (Kenneth Green) — Mon, 15 Nov 2004 00:00:00 EST

As levels of traditional air pollutants like smog and soot continue to decline, regulators are setting their sights on the regulation of gases claimed to cause climate change - like carbon dioxide, usually referred to as CO2.

Now, California's regulators have passed rules that aim to reduce the carbon-dioxide emissions of the Golden State's vehicle fleet. But every indication suggests the California Air Resources Board's new rule, like its electric-car mandate of the 1990s, offers great economic pain for no environmental gain.

The board's latest decree sets a much lower standard for the amount of carbon dioxide that can be emitted by each year's new-car fleet sold in the state beginning in 2009. Ultimately, the required reduction in vehicle carbon-dioxide emissions for the fleet of vehicles sold in California will reach a stiff 30 per cent below current levels by 2016.

Unfortunately, the benefits of this low carbon-dioxide diet don't amount to much. The required 30-per-cent reduction in carbon dioxide certainly won't put a dent in global warming. Even taking every car in California off the road would reduce current global emissions of carbon dioxide by less than one-fourth of one per cent, a reduction that would have virtually no effect on the climate.

In fact, at current emission levels, reducing all motor fuel emissions in all of North America by 30 per cent would reduce global carbon emissions by only 1.5 per cent.

With emissions in developing countries like China and India far outpacing those in developed countries, the environmental effect of the new rules is likely to be undetectable in the long run. And that's assuming that automakers can come up with a fleet of cars that achieves those reductions - a dubious assumption at best.

A study by Sierra Research, an air-pollution consulting firm, found that contrary to the California regulators' claim, "vehicle design changes would need to occur at a rate that substantially exceeds historical practice, unless compliance is achieved by shifting motorists into small, lower-performance vehicles."

The costs of the new proposal border on the prohibitive. When the regulators proposed the new rule, they argued that motorists would save big at the gasoline pump - an estimated $1,703 over the life of each new passenger car sold in 2016.

The Sierra Research study, however, showed the regulators erred by lopping 30 per cent off the true cost estimates for developing key technologies needed to put their proposed carbon-dioxide reductions into effect. It also found the California officials were overly optimistic in assuming that such technologies as five-speed and six-speed automatic transmissions would be universally adopted by carmakers.

When taking out all of the regulators' unsupportable assumptions, Sierra Research found that new car buyers in 2016 would lose $3,357 over the lifetime of the vehicle compared with a no-regulation alternative.

A second cost likely would be dirtier air since forcing higher costs onto new cars causes people to hold on to their older, more-polluting cars much longer.

The perverse impact of the new regulation actually will be to slow the positive progress that California has made in reducing levels of traditional air pollutants.

While the new rules apply only to California, they're likely to increase new-car prices for buyers throughout the United States and Canada since 20 per cent of new cars are sold to Californians.

With that big a market at stake, automakers will have little choice but to apply the requirement to virtually every car sold in North America rather than go to the trouble and expense of fragmenting their production for two separate markets - California as one and the rest of North America as the other.

Unless one is gullible enough to believe that changing human actions through government coercion will save the Earth from the global warming disasters envisioned in the movie The Day After Tomorrow, California's new carbon-dioxide regulations are ill-advised. Their costs are too high and their benefits nearly non-existent.

Dr. Kenneth Green is senior fellow at Reason Foundation and Chief Scientist at Frasier Institute.

Cleaning the Air in California

info@reason.org (Kenneth Green) — Wed, 22 Sep 2004 00:00:00 EDT

Once again, California regulators are out to get full-size gasoline cars and light trucks. In the old days, such attacks would be tied to the goal of reducing smog or soot levels. But as air pollution continues to decline - despite people driving larger cars over longer distances, regulators have to find a new excuse to keep them in business, and the latest excuse is climate change.

The California Air Resources Board isn't targeting smog or soot, but rather carbon dioxide and nitrous oxide, the latter of which is better known as laughing gas. But ARBs proposed regulation is no laughing matter.

On Sept. 23 the state's Air Resources Board is set to mandate that new vehicles sold in California cut their greenhouse gas emissions 30% by 2016. By proposing a greenhouse gas emission standard for the California new vehicle fleet, regulators have shown they just don't get it: through millions of independent spending decisions, California drivers have demonstrated that they just don't want the gizmos that government technocrats want to peddle. They don't want tiny compact cars, they don't want electric vehicles, they're don't want to pay high premiums for hybrid cars, and they're not going to want to pay still more money for smaller, more "greenhouse-friendly" compact cars. Yes, there are news stories about new, sky-high demand for hybrids - but sales of all hybrids is expected to total 88,000 cars this year, a miniscule figure when you consider that there were 16.6 million light vehicles sold in 2003.

First, let's get the climate change excuse out of the way. California cars aren't causing climate change and even taking all of the state's cars off the road completely wouldn't make a dent in emissions. According to government emissions data, California motorists produce less than one-quarter of 1 percent of the world's emissions of the gases theoretically linked to global warming - a share that's declining every day as countries such as China and India continue to grow. On top of that, the proposed regulation only addresses only four out of the six major greenhouse gases, and only passenger vehicles, not commercial vehicles. Now, whether you believe that we face a risk of catastrophic climate change due to manmade gas emissions or not, it should be obvious that this new regulatory regime will provide little or no climate protection to current or future generations.

What about the effect on consumer choice and health? While the Air Resources Board postulates a hodgepodge of technologies they claim will reduce greenhouse gas emissions (like low-leak air conditioning systems), the only truly effective way to reduce emissions of carbon dioxide and nitrous oxide from cars is to either reduce the amount of fuel they collectively burn or change to a fuel that puts out less greenhouse gas per unit of energy. And the only way to do that is through mandating technology that would lighten and shrink cars or forcing "alternative fuel" vehicles, hybrid cars and battery-electric cars onto a market that has shown little desire for them.

The danger of such technocratic mandates doesn't lie simply in their failure - such mandates can expose people to higher risks in traffic accidents by forcing them into smaller, less protective vehicles. Such mandates also reduce consumer choice, suck resources out of the productive economy, and sink those resources into bureaucratic paper-shuffling and bean-counting.

California's new greenhouse gas standards would also jeopardize the progress being made against smog and soot. When people trade older cars for newer cars (yes, even newer SUVs), they generally put out less smog and less soot than before. Raising the cost of newer cars slows down such purchases and the associated air pollution benefit. And this proposal will certainly raise vehicle costs. While the creative accountants at ARB claim that people will save money over the lifetime of such vehicles because of fuel savings, the up-front costs ARB admits to are not-trivial. ARB claims that their proposed measures would add $960.00 to the cost of a new vehicle in 2016. But given their performance in predicting the cost and benefits of other measures, such as battery-electric cars and reformulated gasoline, there's every reason to assume that this newest estimate lowballs the costs, and blue-skies the benefits.

All of this adds up to making Californians less safe in the face of a climate that has always been and will always be variable, and occasionally extreme. Taking money out of people's pockets for higher fuel and automobile costs will mean less for all the other investments that can protect them from climate variability such as securing water resources, building resilient infrastructure and energy supplies, building a more diverse, robust, and resilient economy, or investing in education or health care. And that's no laughing matter.

Dr. Kenneth Green is senior fellow at Reason Foundation and Chief Scientist at Frasier Institute.

Pavley's Ploy May Carjack Motorists

info@reason.org (Kenneth Green) — Fri, 05 Jul 2002 00:00:00 EDT

Los Angeles Times

How bad is the auto emissions bill? ... Let me count the ways.

California's war on sport utility vehicles shifted into high gear with the backroom passage Monday of a bill that would commandeer consumer choice in automobiles under the largely fraudulent pretense of combating global warming. This is political carjacking at its worst.

Unable to pass federal fuel-economy regulations to stop people from driving the larger, more comfortable cars they want, environmentalists have taken their efforts to Sacramento.

A bill by Assemblywoman Fran Pavley (D-Agoura Hills) was the car haters' vehicle of choice because anything affecting the huge California car market is likely to affect the rest of the country. The measure, if signed by the governor, would make California the first state to regulate tailpipe emissions of greenhouse gases. Unable to pass the bill through the normal legislative process, Pavley had its language inserted into a nonenvironmental, technical bill sitting on the Senate floor and got it voted out of the Senate on Saturday. Call it "Pavley's Ploy," in case they change its name again to further confuse the public. The bill is now on Gov. Gray Davis' desk.

Pavley's Ploy is supposed to reduce California's emission of gases that some computer models hold responsible for global warming. But the numbers suggest that Pavley's Ploy isn't about preventing global warming. It's about preventing you from buying that next truck or SUV or driving the one you have as much as you want.

According to government emissions data, California motorists produce less than one-quarter of 1% of the world's emissions of the gases theoretically linked to global warming. According to government computer models, about 80% of observed or predicted global warming is because of greenhouse gases, most of the rest being caused by changes in land use for farming, forestry and so on. Whatever its other effects, when it comes to preventing global warming, this bill would provide virtually no benefit to future generations.

The only way to reduce emissions of carbon dioxide from cars (the main greenhouse gas they produce) is to either reduce the amount of fuel they collectively burn or change to a fuel that puts out less carbon dioxide per unit of energy. And the only way to do that is through mandating technology that would lighten and shrink cars, levying fuel taxes to reduce driving, adding per-mile driving fees to keep motorists off the road or pushing "alternative fuel" technology such as natural gas and electric-powered cars.

All those approaches have known failings, expose people to more risks and deprive them of consumer choice, suck resources out of the economy and sink those resources into bureaucratic paper-shuffling.

While climate change is still largely theoretical, the damaging effects of regulatory approaches like these are well-established facts. Not to put too fine a point on it, but forcing people into smaller cars would kill some of them. The National Academy of Sciences has acknowledged that lighter and smaller cars are inherently more dangerous. And no, that's not simply in collisions with SUVs. That's also true in accidents when some lightweight cars hit a guardrail.

Pavley's Ploy would also slow down the fight against the better-understood pollutants such as ozone and particulate matter because anything that raises the price of new cars reduces the single biggest positive force in easing air pollution: buying a new, less-polluting car.

Worse still, taking money out of people's pockets for higher fuel and automobile costs will mean less for other needs, such as education and health care.

The degradation of transparency in California's Legislature is only the first harm that Pavley's Ploy would foist on the public. If Gov. Davis signs the legislation, Californians will be poorer for it.

Dr. Kenneth Green is senior fellow at Reason Foundation and Chief Scientist at Frasier Institute.

Removing the 55 MPH Speed Limit

info@reason.org (Kenneth Green) — Wed, 05 Jun 2002 16:27:00 EDT

Good afternoon. I am Dr. Kenneth Green, Chief Scientist with the Reason Foundation.

Like everyone else in this room, I like to breath clean air. Having lived with asthma for nearly 30 years, I can attest to the importance of safe, breathable air. And thankfully, Houston's air quality is getting better every year, and has done so now for over a decade.

But having grown up in a single-parent household of very modest means, I can also attest that choice and flexibility in mobility, and economic strength are equally vital pillars of safety and health.

Fortunately, as we wrote back in November 2000, in a study touted as "The Solution" to Houston's air quality woes by the Houston Chronicle, there are innovative ways to clean the air that do not require us to sacrifice that choice, flexibility, and economic health. The 55-MPH speed limit imposed on Houston, however, is not one of those ways.

As we concluded then:

"A speed-limit reduction policy, besides being likely to spark social discord, is based on questionable assumptions about the relationship between vehicle acceleration and emissions. While the effect of reducing the speed limit might be a small NOx reduction in certain vehicles, the overall impact of slowing the flow of traffic will keep all vehicles running longer, as more time will be needed to complete a trip. It is not clear that current models of emissions are a function of speed, and the overall impact of speed reductions on the total vehicle fleet of both light and heavy-duty vehicles does not adequately capture the complexity of the speed/emissions tradeoff. Such uncertainty constrains sound policymaking, in that it invites unintended adverse consequences, inefficiently utilizes resources, and endangers the public's willingness to accept more reasonable emission-control policies. Moreover, lower speed limits on freeways in the Houston-Galveston area will be very difficult to patrol due to the high volumes of traffic. Law enforcement agencies are unlikely to obtain the additional budget funding necessary to this end. Further, the public may be unwilling to allow resources to be transferred from efforts to control serious crime to highway patrol."

Innovative alternatives to the 55-MPH speed limit abound. To name only one example, converting the existing, deeply flawed vehicle and inspection maintenance system, into a highly targeted, gross-emitter identification system could provide additional air quality benefits while freeing most motorists (who drive clean cars) from the cost and inconvenience of annual smog checks.

I thank you for the opportunity to help ensure that environmental policy provides real benefits while preserving choice, mobility, and economic health for the citizens of the State of Texas.

Hearing on Removing the 55-MPH Speed Limit on Automobiles

info@reason.org (Kenneth Green) — Wed, 05 Jun 2002 00:00:00 EDT

Good afternoon. I am Dr. Kenneth Green, Chief Scientist with the Reason Foundation.

But having grown up in a single-parent household of very modest means, I can also attest that choice and flexibility in mobility, and economic strength are equally vital pillars of safety and health.

As we concluded then:

I thank you for the opportunity to help ensure that environmental policy provides real benefits while preserving choice, mobility, and economic health for the citizens of the State of Texas.

Dr. Kenneth Green is senior fellow at Reason Foundation and Chief Scientist at Frasier Institute.

Cooperative Environmental Problem-Solving Works Best

info@reason.org (Kenneth Green) — Tue, 28 May 2002 16:29:00 EDT

Thank you Mr. Chairman. I am Dr. Kenneth Green, an environmental scientist with the Reason Public Policy Institute, a project of the Reason Foundation, a non-profit, non-partisan policy research and education organization headquartered in Los Angeles.

My interest in environmental policy originates quite a ways back, over 27 years, in fact, to the year when I was diagnosed with asthma, living a few hours north of here in the smoggy San Fernando Valley of decades past. I learned about the hazards of extreme environmental contamination the hard way: one day, when running the 600, my lungs simply locked up. I collapsed at the 600-yard line, my breath sounding like a steam whistle.

From then on, I was one of the kids you often see profiled in environmental media reports - sentenced to corrective physical education, to sit and play checkers while the other kids were out on the gym field.

Growing up with asthma taught me how important it is to have a healthful environment, and how radically environmental health hazards can impact the lives of our children.

But growing up with asthma was not my only formative experience. My father died when I was very young, and after a short stint with an abusive second husband, my mother decided to raise her two sons by herself, out in Los Angeles.

It was a brave decision that started out well at a small sandwich shop she opened with a friend, but they ran straight into the teeth of the 1970s economic recession. As local building projects were cancelled, the business failed. As rents inflated, and salaries stagnated, we were bumped from apartment to cheaper apartment.

I went to four different elementary schools in only two years. My mother’s health, none too good to begin with, wasn’t helped by the constant stress of trying to make it in an economy that was fighting against her.

Things stabilized a bit by the time I was 13, when my Bar Mitzvah brought me back a certain amount of my outdoor liberty.

Though it will no doubt horrify some listeners here today, that was when I took my $200.00 in Bar Mitzvah money, and bought a small off-road motorcycle – an 80cc Yamaha, to be specific.

Camping was the one recreation we could afford, and though I couldn’t hike, even in the clean air of the mountains or desert, I could ride, and boy, did I.

That little bike took me places that would make mountain goats nervous. It let me indulge my budding love for nature in ways that would have been impossible to me without the motorized assist.

That love for things natural formed the core of my motivation that ultimately carried me through my doctorate in environmental science and engineering at UCLA.

My smoggy childhood taught me these lessons that I’ve never forgotten:

Environmental quality is a vital good.

A sound economy is a vital good.

And the freedom of mobility, and the ability to develop oneself are vital goods.

My subsequent studies taught me, fortunately, that one needn’t trade one of these for the others. Indeed, studying environmental science and policy convinced me that choice and economic competition were not the enemies of the environment. Rather, choice, competition, and technological progress are the wellspring of safety, health, and environmental quality.

I’ve spent the years since my graduation looking for approaches to environmental problems that embody the wisdom of environmental science – approaches that are holistic, flexible, and cooperative.

Such approaches that tap into local knowledge are not only more likely to produce results, they are less likely to breed angry litigation, the ultimate waste of resources we need to invest in environmental quality.

Though muted by the events of September 11, debate over the direction of environmental policy has continued in the United States.

While many voices champion initiatives elevating the voluntary over the mandatory, the flexible over the rigid, and the decentralized over the centralized, those in opposition seem to hold an old, 1970s, “us versus them” mentality that holds voluntary, cooperative, and locally-derived approaches to solving environmental problems to be inferior to centralized, command-and-control approaches driven from Washington, D.C.

As a policy analyst without governmental portfolio, it's not my primary job to take sides in the political squabbles over who is, or who is not an environmentalist. But it is my job to defend approaches to environmental protection that can move society out of the bitter, recriminating legislative, regulatory, and judicial battles that have turned environmental policy into a battlefield, rather than the shared journey it could and should be.

In its time, the regulatory approach did considerable good – We have virtually eliminated open dumps, our air is constantly cleaner, we’ve reduced pollution in our surface waters, which no longer burst into flame, though we have a way to go before we can claim victory in that environmental arena.

But the low-hanging fruit that yields to such methods is pretty much plucked. The environmental problems that remain are not the simple ones of the past that might yield to blunt-object regulatory approaches.

Today’s problems require all the creativity that can be brought to bear, from the people with the local knowledge of the problem, and the technologies or behaviors that might ameliorate those problems all working together, rather than fighting it out in courtrooms, where only the lawyers benefit.

I'd like to review a few of the voluntary, cooperative, and locally-derived environmental policy approaches that have gotten results without all the negative baggage that command-and-control regulations historically breed.

First consider the air. Under the traditional permit-based approach to cleaning the air, Massachusetts found itself in an uncomfortable position in the 1990s, regulating some 10,000 businesses through 16,000 permits.

Some 4,400 of those permitted facilities were small, mom-and-pop businesses that, combined, only emitted about 5 percent of the state’s total air pollutant emissions.

So the state looked for a better way. Under the Massachusetts Environmental Results Program, a voluntary approach was tried.

Participating firms agreed to comply with a set of industry-wide whole-facility emission standards developed in cooperation with the Massachusetts Department of Environmental Protection.

Signing on to this voluntary, mutually agreeable standard would gain the small businesses of Massachusetts's freedom from the equipment-based permits that kept them mired in a regulatory morass.

And the program worked. In the first few years alone, the program resulted in a 43 percent reduction in fugitive emissions from participating dry cleaners, and a 99 percent reduction in silver discharges by photo processors.

A similar program was implemented in New Jersey, which set emission caps on participating firms, but let them achieve those emission targets in whatever ways they felt were most effective and efficient.

For one firm, the old source-by-source permitting processes had generated ten full binders of paperwork. The new system replaced 80 separate permits with a single permit, and could be processed in 90 days, rather than the 18 months required under the old system.

The result? One firm estimated that it reduced 8.5 million pounds of emissions per year because the new system allowed them to modernize their facility without the pain of individual equipment permitting.

Through the modernization, the firm eliminated 107 of 350 pieces of equipment.

Now let’s talk about water. In California’s Feather River basin in 1985, Pacific Gas and Electric discovered that 250,000 cubic yards of silt was piling up behind its dams.

Since the sedimentation was reducing reservoir capacities and damaging power generation systems, PG&E was about to follow the standard, and legally acceptable approach of dredging the reservoir.

But a concerned history teacher named John Schramel, county supervisor of Plumas County, proposed that the money earmarked for the dredging be used in upstream erosion-abatement programs instead, solving the cause of the sedimentation problem, rather than the symptoms. Gathering a coalition of anglers, business owners, government officials and environmental activists around his dining room table, Schramel formed the Feather River Alliance as a means to restore some of the local creeks and watersheds.

With funding from PG&E, the group did a trial run on the Red Clover Creek, and not only dramatically reduced watershed erosion and sedimentation, but restored what was a barren range riddled with sagebrush into a wet meadow lush with wildflowers and waist-high grasses, geese, herons, and sandhill cranes.

The Upper Clark Fork River basin in Montana has been utilized for over 100 years for mining and smelting purposes, and the water has steadily degraded.

In fact, 140 miles of the Clark Fork River, from Butte to Milltown, Montana constitute the largest Superfund site in America.

By the mid 1980’s, copper and zinc concentrations in the water were high enough to be toxic to fish, and logging operations in the area were causing soil erosion and streambank degradation.

In 1985, environmental groups pleaded with Montana’s department of Fish, Wildlife and Parks (DFWP) to initiate conservation efforts to increase instream flows to protect fish and wildlife habitats.

The DFWP agreed, but its plan was not exactly nuanced. The DFWP’s conservation effort would have halted all development in the basin, setting aside the water as a nature conservancy.

While area businesses were willing to work to see the river cleaned up, a ban on all water use would simply have run the local businesses needing that water for irrigation right out of business.

Having already spent over $1 million dollars in court over a previous hearing on the Missouri River, area irrigators wanted to avoid the judicial solution pathway.

Fortunately, a way was found out of the impending conflict. The Northern Lights Institute, a neutral third party stepped in to coordinate a voluntary agreement allowing the basin’s water users and managers to develop a basin management plan that would balance the interests of all the users while preventing any new demands to be made on the river’s flow.

Now over 10 years old, the Clark Fork project has a council of 21 members that work to not only clean and protect the river, but to balance the interests of the diverse area residents who want to use the river for business and recreation.

It has become popular to pooh-pooh voluntary, cooperative approaches to environmental problem solving of late, particularly as the Bush administration has made that a focus in setting environmental policy, and some groups seem determined to keep environmental policy debates as partisan as possible, though polls show that virtually all Americans are environmentalists, regardless of where they work.

Further, success stories abound showing that such approaches have been embraced by members of both major political parties, industry groups, environmental activists, and informed citizens.

To sum up, then: the low-hanging fruit of environmental problems has been plucked in the United States, and the problems that remain are tricky. Solving those tricky problems, while retaining the choice and economic competition that are the wellsprings of our safety, health, and environmental quality will require the cooperation of all parties, flexibility on all sides, the tapping of local knowledge, and the avoidance of wasteful litigation.

As many students of environmental policy have pointed out, environmental problem-solving works best when regulators: work cooperatively with the regulated community; set clear performance-based criteria for success; limit regulation to situations where a net environmental benefit is possible; give the regulated community maximum flexibility in achieving environmental improvement, and use measures that tap the incentive powers of the market, and adhere to a "polluter-pays" principle.

I thank you for the opportunity to speak to you today, and I will gladly take your questions.

American Lung Association's Report Misleads Public

info@reason.org (Kenneth Green) — Tue, 30 Apr 2002 00:00:00 EDT

According to "State of the Air 2002," a report to be released on May 1 by the American Lung Association (ALA), "more than 142 million Americans live in areas where the air they breathe puts them at risk." If that were true, air pollution would be one of the most serious health challenges in the United States. However, the ALA report greatly exaggerates Americans' exposure to and risk from unhealthful air, and misleads the public into believing that air pollution is getting worse, when in fact it has been improving.

How did ALA get the numbers so wrong? The ALA report is seriously misleading because:

Ozone levels are artificially inflated in dozens of counties when compared with actual ozone monitoring data.
Clean areas of many counties are counted as having dirty air.
The ALA grading system is more stringent than the Environmental Protection Agency's (EPA) proposed new "8-hour" ozone standard, which is specifically designed to protect those most at risk from air pollution.
ALA assumes 40 percent of people are "sensitive" to and harmed by moderately elevated ozone levels, while health effects research shows that only a few percent of people fall into this category.
The study implies that air pollution is bad and getting worse, when in fact air pollution levels have been dropping for at least 20 years in most areas, and only a few metropolitan areas still have a serious ozone air pollution problem.

As a result, ALA may be needlessly scaring tens of millions of Americans into believing their air is unsafe, and encouraging society to waste scarce resources on non-existent or minimal risks.

I. ALA Greatly Overstates Actual Exposure to Elevated Ozone Levels

"State of the Air 2002" artificially inflates ozone levels, reporting more high-ozone days per county than ever actually occur. Here's how: ALA tallied a countywide ozone violation for each day that at least one monitor in a county registered ozone greater than 0.084 parts per million (ppm). As a result, ALA counts more ozone violations for a county as whole than occurred at any single location in the county. This overstates ozone exposure for everyone, because ozone can affect your health only if it's high where you're located, rather than in some other part of your county.

Figure 1a shows this for Los Angeles County. Using the ALA method, Los Angeles County averaged 37 elevated ozone days per year from 1998 to 2000.[1] But no single location had more than 22 days of elevated ozone, and most had far less. This means that even for the people with the maximum ozone exposure in the county, ALA overestimates real exposure by more than 60 percent, and by much more than that for most people. One can also see this is true by asking the following question: "Where can I find the people in Los Angeles County who are exposed to 37 days per year of elevated ozone�" The answer is "nowhere," because no single location has this many annual days of elevated ozone. Figure 1b shows similar data for Maricopa County, Arizona, where the ALA method results in an even more exaggerated ozone exposure value.[2]

"State of the Air" artificially inflates ozone levels for dozens of other U.S. counties, including populous ones such as Cook (Chicago), Harris (Houston), and San Diego, in effect telling tens of millions of Americans that they are often exposed to elevated ozone, when in fact they are rarely or never exposed.

II. ALA Counts Many Areas with Clean Air as Having Dirty Air

There are several reasons for this:

ALA used an artificially stringent standard for determining when ozone levels are high enough to be harmful.
"State of the Air" isn't based on peoples' actual exposure to ozone, but rather on an artificially inflated exposure (see previous section).
Ozone levels have been declining in many places, but the ALA report is based on data from 1998 to 2000, when ozone levels were higher in many areas than they were in 2001.
ALA gives the same failing air quality grade to regions with both severe and mild air pollution problems, blurring the distinction between minor and significant health risks.

Most counties monitor ozone levels at several locations, because ozone levels usually vary from place to place. Table 1 shows the percent of ozone monitoring locations in a number of populous counties that comply with the current EPA ozone health standard (usually referred to as the "1-hour standard"), and with a new, much more stringent standard that EPA hopes to implement soon (usually referred to as the "8-hour standard"). Though large areas of most of these counties have clean air based on even the 8-hour standard, ALA assigned all of these counties a failing grade.[3] Dozens of other counties also received misleading grades from ALA.

III. ALA Greatly Exaggerates the Number of People Affected by Current Ozone Levels

ALA exaggerates the percentage of the population that is sensitive to relatively low levels of ozone. Researchers measure the effects of ozone on people via both quantitative tests of lung function and subjective ratings of symptoms. Lung function studies of children, adults, and the elderly have shown, not surprisingly, that factors such as ozone level, duration of exposure, presence of respiratory diseases, and physical activity level can affect people's responses to ozone.

These studies show that high ozone levels-0.12 ppm and above-especially combined with exposures longer than three hours, pre-existing respiratory disease, and exercise, can cause both substantial decreases in measured lung function and increases in subjective symptoms, such as coughing and pain during deep breathing. However, at ozone levels in the range of 0.08 ppm to 0.09 ppm, studies have found that most people don't experience measurable reductions in lung function and even fewer experience subjective respiratory symptoms, though some experience adverse effects, especially under conditions of multi-hour exposure combined with exercise. These low-exposure effects do appear to be temporary, however.[4]

Despite these research results, ALA assumes 40 percent of the population-including all children under 14, all adults over age 65, and all people with a respiratory disease-are "sensitive" to ozone, and suffer serious and permanent harm even when ozone levels are around 0.09 ppm on more than 3 days per year. ALA has thus greatly exaggerated the percent of the population affected by moderately elevated ozone levels.

IV. "State of the Air" Claims Air Pollution Is Bad and Getting Worse, when in Fact it is Generally Mild and Improving

The fight against smog is a great success story in environmental protection. According to EPA, ozone levels decreased by an average of 24 percent nationwide, between 1980 and 1999.[5] Southern California, the region with the worst air in the country, reduced its annual violations of EPA�s one-hour ozone standard by about 80 percent between 1980 and 2001. Houston, the second most polluted area in the country, reduced ozone violations by about 60 percent over the same period. Most, though not all, metropolitan areas have also achieved significant improvements in ozone levels. These gains occurred at the same time that Americans increased their driving by 75 percent.[6] Pollution measurements also show that emissions from cars and trucks�the major sources of ozone-forming pollution, are declining by about 10 percent per year as older vehicles are supplanted by more recent models that start out cleaner and stay cleaner throughout their lives.[7] This means that air quality will continue to improve. Readers of the ALA report would never know these facts. Instead, ALA misleads readers into believing that air pollution is getting worse and that the Clean Air Act is in danger of being rolled back.

Air pollution is also much less pervasive a problem than "State of the Air" claims. As of January 2002, 88 percent of ozone monitoring locations in the United States comply with the EPA's 1-hour ozone standard, while 59 percent comply with the 8-hour ozone standard. Furthermore, half of the locations that exceed the 8-hour standard do so by less than about 6 percent. Only a few metropolitan areas-San Bernardino, Houston, and Fresno-still have serious air pollution problems. The vast majority of other areas either have clean air, or have air pollution at a level harmful to only a few percent of the population. Nevertheless, ALA incorrectly claims "75% of Americans who live in areas with monitors are breathing in unhealthy amounts of ozone." While no one should be subjected to health-damaging levels of air pollution, the real state of the air is far more favorable than ALA would have Americans believe.

V. The Perils of Exaggerating Environmental Risks

ALA's inaccurate and misleading air quality ratings could scare tens of millions of people who breathe clean air into incorrectly believing that their air is unsafe. Tens of millions more might believe that their air poses a major health threat, when in fact their real risk is minimal.

Ironically, ALA's efforts could actually reduce Americans' overall health and safety. The ALA report will encourage the public to demand unnecessary additional expenditures to clean up air that is already clean. But in a world of limited resources, society can address only some of the many risks people face. When society wastes effort on small or non-existent risks, fewer real problems get the attention they deserve, reducing our health and safety.

Everyone deserves to breathe clean air, and nobody wants to see people suffering from pollution. A few areas of the country have serious air pollution problems that do threaten the health of people who live there. But exaggerating the public�s risk from air pollution is no better than ignoring real air quality problems. If society misspends scarce resources based on inaccurate information, more people will suffer not fewer.

Joel Schwartz is an adjunct fellow at Reason Foundation and visiting scholar at American Enterprise Institute.

Endnotes

[1] Ozone data were downloaded from EPA�s AIRdata web site, www.epa.gov/aqspubl1/annual_summary.html

[2] Phoenix has ozone monitoring locations in several areas of the city, and each one is marked by its own bar in Figure 1b.

[3] EPA�s current health standard for ozone states that a region will be considered to be in �non-attainment� if ozone levels during any one-hour period exceed 0.124 parts per million (ppm) on more than three days during the most recent three-year period. This standard is usually referred to as the �1-hour standard.�

Believing that this standard was not sufficiently protective of public health, EPA in 1997 proposed a new, far more stringent, ozone standard. Under this standard, an area is deemed in non-attainment if the average of the fourth-highest ozone level from each of the last three years is greater than 0.084 ppm. In this case, the daily ozone levels are averaged over an 8-hour period, and this standard is therefore usually referred to as the �8-hour standard.� EPA intended this standard to provide adequate health protection even for those most sensitive to ozone, such as some people with respiratory diseases.

The ALA standard is much more stringent than even the EPA�s 8-hour standard. Under the EPA 8-hour standard, a region would have to average roughly 12 days in a three-year period with ozone greater than 0.084 ppm before being out of compliance with the health standard. In contrast, the ALA won�t give a region a clean bill of health unless it never has any days with ozone greater than 0.084 ppm. Even though ALA chose a more stringent standard than the EPA 8-hour standard, EPA�s Clean Air Science Advisory Committee, an independent panel of scientists and health experts, concluded that EPA could have chosen an even less stringent standard than the 8-hour standard and still be equally protective of public health.

[4] On ozone�s health effects, see for example, EPA, Air Quality Criteria for Ozone and Related Photochemical Oxidants (Washington, D.C., July 1996), vol. II, Ch. 7; M. Berry et al., �Accumulated Exposure to Ozone and Measurement of Health Effects in Children and Counselors at Two Summer Camps,� Environmental Research, vol. 54 (1991), pp. 135-150; D. M. Spektor, �Effects of Single- and Multiday Ozone Expsures on Respiratory Function in Active Normal Children,� Environmental Research, vol. 55 (1991), pp. 107-122; and D. H. Horstman, �Ozone Concentration and Pulmonary Response Relationships for 6.6-Hour Exposures with Five Hours of Moderate Exercise to 0.08, 0.10, and 0.12 ppm,� American Review of Respiratory Diseases, vol. 142 (1990), pp. 1158-1163.

[5] EPA, Air Quality Trends 1999 (Washington, D.C, 2000).

[6] Vehicle use trends come from the U.S. Bureau of Transportation Statistics (www.bts.gov/btsprod/nts/ch1_web/1-29.htm) and the Federal Highway Administration (www.fhwa.dot.gov/ohim/hs99/tables/vm1.pdf).

Warning: Eco-Posturing Ahead in CA

info@reason.org (Kenneth Green) — Fri, 05 Apr 2002 00:00:00 EST

Are California's drivers responsible for global warming?

No. Even if everyone in California stopped driving or we could eliminate all greenhouse gas emissions from California vehicles, worldwide emissions would drop by less than one quarter of 1 percent.

Nevertheless, a group of state lawmakers and lobbyists are determined to pass a bill that will hit California drivers hard in the pocketbook and produce miniscule environmental improvements at best.

The bill, AB 1058 is heralded as a way to combat global warming. In reality, California drivers will be more affected by this bill than the environment.

Assembly Bill 1058, introduced by Assemblywoman Fran Pavley, D-Woodland Hills, would make California one of the first states to require the regulation of carbon dioxide emissions from motor vehicles.

The main impact of AB 1058 would be to end-run the federal government's decision not to increase fuel efficiency standards, to make SUV ownership more difficult, and to reduce the amount of driving we do.

That's because the only ways to trim carbon dioxide emissions from vehicles are to improve the fuel-efficiency of cars, require the use of alternative fuels or energy sources, or reduce driving altogether.

Let's start with that last one first. One look at the 101 or 405 freeway shows you how much we love our cars. Regulators have been bemoaning Californian's "love affair" with the car for decades without slowing it down. So we can assume that completely eliminating cars and driving is out.

That leaves alternative fuels, and more efficient cars. Either way, Californians can expect to pay a lot more at the car dealership for their special, environmentally friendly cars and a lot more at the gas pump for their special, cleaner fuel.

Alternative fuel sources do offer some promise for reducing greenhouse gas emissions, fuel cells particularly. Several car manufacturers are developing the technology, but it probably won't be market-ready for several decades. The other alternative energy technologies that exist have already failed in the marketplace. For example, for all but a few Hollywood actor-types, electric car performance proved too unreliable and limited for most people's lifestyles. Natural gas is expensive, gives mediocre vehicle performance, and some scientists believe the leakage of methane in natural gas may actually aggravate global warming more than our current cars do.

So we're down to improving the fuel efficiency of our cars. Lawmakers in Washington recently refused to raise national fuel efficiency standards because of safety issues.

The National Academy of Sciences has acknowledged that lighter-weight and smaller cars are inherently more dangerous, and that government fuel-economy mandates have directly caused the death of thousands of motorists each year.

But even discounting the risk factor, the market trend toward larger, more versatile, more powerful vehicles suggests that a very large part of the population doesn�t want the Japanese-style compact car.

So how will California enforce this law calling for reduced carbon dioxide emissions?

The standard government playbook calls for the promotion of carpooling, more mass-transit, more HOV lanes, mandated bicycling facilities at employers, and so on. Those ideas have failed time and time again, leaving us with the possibility of a greenhouse gas tax for drivers.

A tax for driving sounds crazy, but it might be the only way to meet the bill's requirements. The tax could be based on miles driven, vehicle fuel efficiency, or a combination of the two. People and businesses with SUVs, trucks, and mini-vans would pay the highest price.

AB 1058 won't help the environment. It will however, inflict a financial burden on families, small businesses, and carmakers.

There is any easier and smarter way to go. If California regulators are determined to force greenhouse gas levels down before the rest of the world reaches agreement on which gases need reducing on which time-frame, they should look to increasing tree-planting, and changing agricultural methods that favor the removal of carbon dioxide from the air by trees and crops. That�s where any sane greenhouse gas reduction strategy would start.

Dr. Kenneth Green is senior fellow at Reason Foundation and Chief Scientist at Frasier Institute.

Hearing on Public Health and Natural Resources

info@reason.org (Kenneth Green) — Wed, 13 Mar 2002 16:35:00 EST

My interest in environmental policy originates quite a ways back, over 27 years, in fact, to the year when I was diagnosed with asthma, living in California’s then-ferociously smoggy San Fernando Valley.

Actually, diagnosed isn’t really the right word – one day, when running the 600, my lungs simply locked up, and I collapsed at the 600 yard line, my breath sounding like a steam whistle.

From then on, I was one of the kids sentenced to corrective physical education, to sit and play checkers while the other kids were out on the gym field.

The smog in those days was so thick that you didn’t need weather forecasters to tell you about it, and its impact on the lungs was strong enough that you didn’t need epidemiological studies to observe it.

Growing up with asthma taught me how important it is to have a healthful environment, and how radically environmental health hazards can impact the lives of our children.

It was a brave decision that started out well at a small sandwich shop she opened with a friend, but they ran straight into the teeth of the 1970s economic recession.

As local building projects were cancelled, the business failed.

As rents inflated, and salaries stagnated, we were bumped from apartment to cheaper apartment.

We managed to stabilize things by the time I was 13, when my Bar Mitzvah brought me back a certain amount of my outdoor liberty.

Though it will no doubt horrify some listeners here today, that was when I took my $200.00 in Bar Mitzvah money, and bought a small off-road motorcycle – an 80cc Yamaha, to be specific.

Camping was the one recreation we could afford, and though I couldn’t hike, even in the clean air of the mountains or desert, I could ride, and boy, did I.

That little bike took me places that would make mountain goats nervous. It let me indulge my budding love for nature in ways that would have been impossible to me without the motorized assist.

Was it noisy? You bet. Did it pollute? Yes. Did I destroy nature with it? No, I stayed on established roadways and trails.

It saddens me, now, to think of the kids like me that face no-motorcycle rules that would keep them from ever experiencing our country’s scenic beauty, or standing on an inaccessible mountain-top by themselves, wearing the sense of accomplishment that only getting there solo can provide.

My love for things natural took me, ultimately, through my doctorate in environmental science and engineering at UCLA.

My smoggy childhood taught me these lessons that I’ve never forgotten:

Environmental quality is a vital good.

A sound economy is a vital good.

And the freedom of mobility, and the ability to develop oneself are vital goods.

Rather, choice, competition, and technological progress are the wellspring of safety, health, and environmental quality.

Such approaches that tap into local knowledge are not only more likely to produce results, they’re less likely to breed angry litigation, the ultimate waste of resources we need to invest in environmental quality.

There is a big debate right now over the Bush Administration’s approach to environmental policy.

The arguments from those in opposition seem to embody an old, 1970s, “them versus us” mentality that holds voluntary, cooperative, and locally-derived approaches to solving environmental problems to be inferior to centralized, command-and-control approaches driven from Washington, D.C.

It is not my job to defend the Bush Administration. I’m sure they’ve got plenty of able-bodied defenders.

It is my job to defend an approach to environmental protection that can move society out of the bitter, recriminating legislative, regulatory, and judicial battles that have turned environmental policy into a battlefield, rather than the shared journey it could and should be.

Now I don’t deny that the regulatory approach did considerable good – We have virtually eliminated open dumps, our air is constantly cleaner, we’ve reduced pollution in our surface waters, which no longer burst into flame, though we have a way to go before we can claim victory in that environmental arena.

But the low-hanging fruit is pretty much plucked. The environmental problems that remain are not the simple ones of the past that might yield to blunt-object regulatory approaches.

So let’s review a few of the voluntary, cooperative, and locally-derived environmental policy approaches that have gotten results without all the negative baggage that command-and-control regulations historically breed.

First let’s consider the air. Under the traditional permit-based approach to cleaning the air, Massachusetts found itself in an uncomfortable position in the 1990s, regulating some 10,000 businesses through 16,000 permits.

Some 4,400 of those permitted facilities were small, mom-and-pop businesses that, combined, only emitted about 5 percent of the state’s total air pollutant emissions.

So the state looked for a better way. Under the Massachusetts Environmental Results Program, a voluntary approach was tried.

Participating firms agreed to comply with a set of industry-wide whole-facility emission standards developed in cooperation with the Massachusetts Department of Environmental Protection.

Signing on to this voluntary, mutually agreeable standard would gain the small businesses of Massachusetts freedom from the equipment-based permits that kept them mired in a regulatory morass.

Through the modernization, the firm eliminated 107 of 350 pieces of equipment.

Now let’s talk about water. In California’s Feather River basin in 1985, Pacific Gas and Electric discovered that 250,000 cubic yards of silt was piling up behind its dams.

Since the sedimentation was reducing reservoir capacities and damaging power generation systems, PG&E was about to follow the standard, and legally acceptable approach of dredging the reservoir.

Gathering a coalition of anglers, business owners, government officials and environmental activists around his dining room table, Schramel formed the Feather River Alliance as a means to restore some of the local creeks and watersheds.

The Upper Clark Fork River basin in Montana has been utilized for over 100 years for mining and smelting purposes, and the water has steadily degraded.

In fact, 140 miles of the Clark Fork River, from Butte to Milltown, Montana constitute the largest Superfund site in America.

By the mid 1980’s, copper and zinc concentrations in the water were high enough to be toxic to fish, and logging operations in the area were causing soil erosion and streambank degradation.

In 1985, environmental groups pleaded with Montana’s department of Fish, Wildlife and Parks (DFWP) to initiate conservation efforts to increase instream flows to protect fish and wildlife habitats.

The DFWP agreed, but its plan was not exactly nuanced. The DFWP’s conservation effort would have halted all development in the basin, setting aside the water as a nature conservancy.

While area businesses were willing to work to see the river cleaned up, a ban on all water use would simply have run the local businesses needing that water for irrigation right out of business.

Having already spent over $1 million dollars in court over a previous hearing on the Missouri River, area irrigators wanted to avoid the judicial solution pathway.

It has become popular to pooh-pooh voluntary, cooperative approaches to environmental problem solving, and some groups seem determined to keep environmental policy debates as partisan as possible, though polls show that virtually all Americans are environmentalists, regardless of where they work.

Further, success stories abound showing that such approaches have been embraced by members of both major political parties, industry groups, environmental activists, and informed citizens.

The low-hanging fruit of environmental problems has been plucked in the United States, and the problems that remain are tricky.

Solving them, while retaining the choice and economic competition that are the wellsprings of our safety, health, and environmental quality will require the cooperation of all parties, flexibility on all sides, the tapping of local knowledge, and the avoidance of wasteful litigation.

I urge you, in all the decisions you make, to ask first whether there is a flexible, cooperative, and local approach to environmental problem solving before you whip out the blunt-object of a centralized, one-size-fits-all regulatory approach run from afar.

Not only will we attain the environmental quality we seek that way, we’ll preserve the benefits of choice, economic competition, and economic strength that are the foundations of our wellbeing.

I thank you for the opportunity to speak to you today, and I will gladly take your questions.

Air Pollution and Mortality

info@reason.org (Kenneth Green) info@reason.org (Joel Schwartz) — Tue, 12 Mar 2002 00:00:00 EST

Air pollution is a serious concern to many Americans. Historical evidence of lethally high air pollution concentrations, and oft-cited comparisons of modern air pollution exposures to cigarette smoking have put air pollution control high on most peoples� radar. That is perfectly sensible. Making the world a safer place for ourselves and our children is the highest human instinct.

But our instincts can also mislead us if we devote scarce public health resources toward risks that are small, of low probability, and costly to reduce, while other risks that are larger, of higher probability, and less expensive to reduce get short shrift. And we are particularly easy to mislead when news coverage treats new studies of risk superficially�devoid of context and devilish details.

On March 6, the Journal of the American Medical Association published one such study by C. Arden Pope and co-authors entitled, �Lung Cancer, Cardiopulmonary Mortality, and Long-term Exposure to Fine Particulate Air Pollution.�[1] The Pope study contends that people living in areas with higher levels of fine, airborne particles are likely to die earlier than people living in areas with less fine-particle pollution. Specifically, the Pope study contends that living in an area with fine particulate levels 70 percent greater than average, results in a 6 percent increase in the risk of death over a 16-year period.

Although the authors claim to have demonstrated a substantial risk from air pollution, the analysis below will show they may have mistakenly attributed health risks to air pollution that are actually caused by other health-related factors omitted from their analysis. Furthermore, even taking the study�s results at face value, the study found a relatively small risk from particulates when compared with other risks people face, and America�s success in reducing air pollution means few areas now have particulate levels high enough to cause health damage.

Confounding Breeds Confusion

The Pope study is an �ecological study��that is, a study in which researchers observe people�s health, behaviors, and risk factors out in the real world, rather than in the tightly controlled conditions of the laboratory. Ecological studies are inherently limited because researchers cannot obtain detailed ongoing information about the relationships between people�s health and the potential causes of health risks. For example, the behavior of the subjects cannot be prescribed, and their diet, exercise and other health habits cannot be monitored on an ongoing basis. Pollution exposure can only be roughly estimated based on a few regional measurements, rather than actual individual exposure. Exposure is also uncertain because researchers don�t know how much time people spend outdoors, or whether they continue to live and work in the same place after their initial entry into the study.

As a result of these factors, it�s difficult to tell in an ecologic study whether observed health outcomes are the result of pollution exposure and not of other differences between people who live in high- and low-pollution areas. For example, if it turned out that people in high-pollution areas are more likely to drink or smoke, there�s a danger of inadvertently confusing an effect of alcohol consumption or smoking with an effect of pollution. This problem is known as confounding. Other confounders besides alcohol and smoking include diet, exercise frequency, income, marital status, �body-mass index� (BMI; a measure of obesity), and educational attainment.

The Pope study researchers accounted for most of these confounders in their analysis. But the factors were assessed only when people entered the study in 1982 and not afterward. If any of these factors changed after 1982, and if the changes were correlated with pollution levels, then the Pope study results would suffer from uncontrolled confounding. For example, if people in areas with higher pollution were also likely to get fatter between 1982 and 2000 when compared with people in lower-pollution areas, researchers could mistake an effect of body weight for an effect of air pollution.

According to the Centers for Disease Control, Americans indeed became much heavier, on average, during the last 20 years, and poorer people and minorities are at greater risk of obesity than whites and wealthier people.[2] If minorities and the poor are also more likely to live in areas with more particulate pollution, then it�s possible that increases in body weight or changes in some other health factor might actually be responsible for effects that the Pope study attributes to air pollution.

Similar concerns apply to other confounders, such as diet and smoking. For example, if the prevalence of smoking decreased more slowly in higher pollution areas during the last 20 years, then smoking might have actually been responsible for effects the Pope study attributes to air pollution.

Because the risks of smoking and obesity are so much larger than the risks the Pope study estimated for fine particulates, even a small difference in smoking and obesity trends between areas with differing pollution levels could swamp the claimed effect of differences in air pollution. For example, the Pope study found that a 70 percent increase in the concentration of fine, airborne particle levels increases risk of dying prematurely by 6 percent. But for a six foot, 200-pound, non-smoking man, gaining just 15 pounds increases the risk of an early death by 17 percent.[3]

Two other findings in the Pope study suggest that the authors� efforts to control for confounding were incomplete. First, the study found that particulate exposure increases the risk of lung cancer for men, but not for women. Second, the association of air pollution and either cancer or cardiopulmonary mortality held only for people with a high school education or less.

There are also other potentially confounding factors that the Pope study did not assess at all, including income and wealth, and physical activity levels. These factors also have a strong relationship to health and could have changed over time in ways that could cause misattribution of health effects to air pollution when they were actually due to other factors.

Assumptions Aren�t Always Accurate

While it is very important to determine whether low-level exposure to airborne particles poses a risk to human health, such research must be based on sound assumptions in order to provide valid information about health risks. Nevertheless, the Pope study authors made a number of questionable assumptions that should have steered them away from claiming to have generated the �strongest evidence to date� regarding the relationship between airborne particles and human health.

Regarding exposure, the study�s authors assumed that everyone within a zip code was exposed to the same level of particulate pollution, though evidence shows such exposure can vary widely. Not only does exposure vary from place to place in concentration, in the chemical composition of the particles.

The authors also assumed people told the truth on the initial questionnaires regarding how much they smoked and drank. But survey researchers have observed that people tend to under-report these behaviors. Thus, if the authors used survey responses to account for smoking and drinking, they could be underestimating that risk in their study population.

The authors also assumed that health-related behaviors did not change after the entrance survey in 1982. For example, this means the authors assumed that if one did not smoke on the entrance survey, one would not take it up, and that people who filled out surveys in 1982, and later died in the same area where they originally lived, had stayed there throughout. As noted in the previous section, this problem also applies to other health-related factors such as change in weight and diet after entering the study.

Context Offers Clarity

The Pope study authors contend that the study provides �the strongest evidence to date that long-term exposure to fine-particulate air pollution common to many metropolitan areas is an important risk factor for cardiopulmonary mortality.� Media reports on the study were also uncritical in repeating the study�s findings, while giving short shrift to its many limitations.[4] But even if we take the Pope study�s results at face value, the study greatly exaggerates actual risks, and does a poor job of placing the risk of particulate air pollution into the context of other risks people face.

The analysis in previous sections shows that the study�s authors may well have mistakenly attributed health risks to air pollution that are actually caused by other factors. But even ignoring this concern, the study found a relatively small risk from particulates. For example, the study found that reducing particulate levels by 60 percent would reduce risk of dying during a 16-year period by about 6 percent. But, a six foot, 215 pound, non-smoking man can achieve the same risk reduction by losing about five pounds, and three times the risk reduction by losing about 20 pounds.[5]

The Pope study also found that most of the health benefits from reducing airborne particulate levels accrue from reducing particulates down to a concentration in air of about 18 micrograms per cubic meter (mcg/m³). Reductions below this level provided little or no additional health benefit. But according to the Pope study�s pollution measures, all but 2 of 51 metropolitan areas were already below 18 mcg/m³ as of 1999-2000. National fine-particulate monitoring data also show that few areas of the country now have particulate levels above 18 mcg/m³.[6] Thus, even if the small additional health risk reported by the Pope study is real, few people are exposed to it.

Ongoing reductions in particulate levels also mean that future particulate levels will be even lower, further reducing risk. For example, total particulate emissions dropped 75 percent between 1940 and 1997, while per-capita emissions dropped more than 85 percent.[7] Total particulate levels in air declined about 50 percent between 1960 and 1990, while coarse plus fine particulates declined 19 percent between 1991 and 2000.[8] The health hazards discussed in the Pope study occur only after many years of exposure to elevated particulate levels. Continuing declines in particulate pollution suggest that remaining risks will not persist for long enough to damage health in the future.

The Pope study also provides little context on the pitfalls of ecological studies and of epidemiologic studies in general. A number of authorities in the field of epidemiology have concluded that studies that find relatively small increases in risk associated with various health risk factors are often unreliable, due to the likelihood of undetected confounding or bias (see discussion of confounding above).[9]

Everyone deserves air that�s safe to breathe, and most Americans agree on the importance of improving air quality in places where air pollution is high enough to threaten health. But most Americans also want to know that public health resources are going where they�ll get the biggest bang for the buck�that is, toward larger, more certain risks, rather than toward small risks that might not even be real. Exaggerating the public�s risk from air pollution is no better than ignoring real air quality problems. If society misspends scarce resources based on inaccurate information, more people will suffer, not fewer.

Dr. Kenneth Green is senior fellow at Reason Foundation and Chief Scientist at Frasier Institute.

Joel Schwartz is an adjunct fellow at Reason Foundation and visiting scholar at American Enterprise Institute.

Endnotes

[1] C. Arden Pope, et al., �Lung Cancer, Cardiopulmonary Mortality, and Long-term Exposure to Fine Particulate Air Pollution, Journal of the American Medical Association, vol. 27, no. 9, March 6, 2002.

[2] National Center for Health Statistics, Health, United States, 1998, with Socioeconomic Status and Health Chartbook (Atlanta: Centers for Disease Control, 1999).

[3] E. E. Calle et al., �Body-Mass Index and Mortality in a Prospective Cohort of US Adults,� New England Journal of Medicine, vol. 341 (1999), pp. 1097-1105.

[4] G. Polakovic, �Research Links Air Pollution to Lung Cancer,� Los Angeles Times, March 6, 2002 (www.latimes.com/news/nationworld/nation/la-000016775mar06.story), and Andrew C. Revkin, �Soot Particles Strongly Tied to Lung Cancer, Study Finds,� New York Times, March 6, 2002 (www.nytimes.com/2002/03/06/health/06SOOT.html).

[5] Calle et al., �Body-Mass Index and Mortality in a Prospective Cohort of US Adults�

[6] U.S. Environmental Protection Agency, Initial Summary of Preliminary 1999 Fine Particulate Matter (PM2.5) Monitoring Data (Washington, D.C., 2000).

[7] I. Goklany, Clearing the Air: The Real Story of the War on Air Pollution (Washington, D.C.: Cato, 1999).

[8] Ibid.; U.S. EPA, Latest Findings on National Air Quality: 2000 Status and Trends (Washington, D.C., 2001). Methods for measuring particulates have changed over the years, as progressively smaller particles were found to be the main culprits for health effects. �Total particulates� includes all particles suspended in air, regardless of size; �coarse particulates� includes all particles between 2.5 and 10 micrometers (0.0025 to 0.01 millimeters) in diameter, while �fine particulates� includes all particles up to 2.5 micrometers in diameter.

[9] G. Taubes, �Epidemiology Faces its Limits,� Science, vol. 269, September 8, 1995, pp. 164-169.

Stiffing California Motorists

info@reason.org (Kenneth Green) — Tue, 05 Feb 2002 00:00:00 EST

San Diego Union-Tribune

Californians may soon be paying considerably higher prices for cars and fuel than any other state in the nation.

Why? To fight carbon dioxide. That's right, the gas you exhale when you breathe. The California Assembly just passed a bill that would regulate carbon dioxide emissions coming from tailpipe exhaust. Now the bill is headed to the state Senate.

Here's the problem - carbon dioxide doesn't contribute to smog and isn't a health threat. All of this is being done because some people believe carbon dioxide is causing global warming, and that preventing carbon dioxide from entering the air is the only answer. Never mind that there is still an ongoing scientific debate about global warming itself, and that some respected climate scientists believe that methane is a better target, California legislators have locked their sites on carbon dioxide.

What does this mean for Californians? Higher prices and more hassles with no improvement in health, safety, or environmental quality to show for it.

Unlike traditional air pollutants, carbon dioxide is not a "by-product" of fuel use that can be painlessly avoided. There are only three options for reducing carbon dioxide emissions from vehicles: increase the fuel-efficiency of cars and light trucks, require the use of alternative fuels or energy sources that put out less carbon per unit of energy, or reduce driving altogether.

We can assume that people aren't going to suddenly start riding their bikes or the bus to work in large numbers, so driving levels will remain about the same unless regulators whip out the "no-drive days" nightmare. That leaves us with increasing fuel efficiency or using alternative fuel sources.

Forcing regular gasoline vehicles into greater fuel-economy seems like a great idea, until one ponders what is required to do it. The fact is, fuel-economy mandates may actually cause us to lose ground in our attempts to curb air pollution. That's right, lose ground. Raising the cost of new cars, which fuel-economy mandates will do, leads middle and lower-class drivers to hold onto their older, more-polluting cars longer, thus having a negative effect on air quality. That's exactly the last thing that we want to do if we really care about reducing air pollution.

Cars have become vastly less polluting in the last 20 years. Even the popularity of SUVs will not reverse the trend toward cleaner air, since a modern SUV pollutes far less than an early 1990's automobile. Additionally, increased fuel-efficiency often comes at the expense of safety. To make vehicles more fuel-efficient, you have to make them lighter, and lighter vehicles are less safe.

Thus, the most logical way to reduce the emission of carbon dioxide is to go with fuels or energy sources that put out less carbon per unit of energy - that means electric cars or natural gas for now, and fuel cells in the future.

Fuel cells may be the light at the end of the tunnel. Some car manufacturers are actively developing the technology, but it may not be affordable for another 20 years. Electric cars have been the darling of the technocratic set for decades, but people have shown that they are not willing to buy cars that perform poorly compared to regular gasoline vehicles, or those that lack a convenient fueling infrastructure. Electric cars flopped spectacularly in the market, even with a government mandate and massive subsidies behind them.

Natural gas vehicles fail the market test because of the heavy tanks they require, dragging their performance down and gobbling up space that consumers want for carrying things. Another major problem with natural gas is that scientists believe that methane, the major component of natural gas, is a very strong (and possibly the strongest) greenhouse gas of all and damages the ozone. An expanded natural gas distribution system would not only cost a fortune, but could replace carbon dioxide emissions with methane emissions, arguably making global warming more likely, not less.

In the meantime, many people are concerned about the prospect of global warming and well they should be. Human safety, health, and environmental quality are tied to climate stability in many ways. But given the remaining uncertainties in the science, the proper response to that concern is research and no-regrets actions that we know will produce results like tree planting and no-till agriculture.

Forcing Californians to pay more for cars and fuel is bad enough. Forcing them to pay more to satisfy regulations that do more harm than good is something only policy makers could think of.

Dr. Kenneth Green is senior fellow at Reason Foundation and Chief Scientist at Frasier Institute.

Facts, Not Agendas in Textbooks

info@reason.org (Kenneth Green) — Sun, 02 Dec 2001 00:00:00 EST

Fort Worth Star Telegram

The State Board of Education recently made a brave decision, rejecting two proposed environmental textbooks that were not only factually erroneous but also blatantly biased. The publisher of one of the rejected books has since agreed to remove the bias and correct the errors.

I testified at that hearing and, in the process, pointed out several factual errors to the board in response to direct questioning.

In one case, the error was so obvious that its presence at that late stage of the book's editing was surprising. On one page of an environmental textbook, students were told that water vapor was the most important greenhouse gas. On the facing page, students were told that carbon dioxide was the most important greenhouse gas. This error was all the more stunning because it was about global warming, which many environmental activists, including many who testified at the hearing, view as the largest environmental problem of our time.

But factual errors were really the least of the problems these proposed school books had. By far, the biggest problem was bias, both subtle and blatant. With little exception, the texts reflected a politicized view of environmental science and policy that presents every environmental problem by worst-case scenarios; that assigns blame exclusively to industry, capitalism and Western values; and that proposes command-and-control regulations as the best solution, preferably at federal or international levels.

Consider this little gem, from one of the rejected texts: "Some scholars believe that the spread of democracy, which put land ownership and wealth in the hands of many, and the industrial revolution, which made mass production of goods possible and spread wealth throughout society, are at the root of the environmental crisis."

Shame on us for spreading democracy!

Or this one, also from a rejected text: "Human attitudes and beliefs are also responsible for many unsustainable practices. Denial, apathy, inability to respond to subtle threats, greed, acquisitiveness and other factors influence our economic systems, laws and way of life in profound ways. In short, they worsen our biological imperialist tendencies."

I'll bet you didn't even know you had biological imperialist tendencies.

Those favoring such biased views on the nature of environmental problems wanted to hide behind the language of the Texas education code, which seems to limit grounds for textbook rejection to "factual error" for all science-related texts. But one of the first people to testify read a letter from state Rep. Charlie Howard, who explained that the Legislature did not intend the Texas education code to be construed as narrowly as some school board members were insisting.

Supporters of the biased texts tried to discredit the school board decision and portray it as a partisan, fundamentalist religious coup d'etat. Indeed, after the vote was taken, the first comment heard was from a school board member who loudly observed that the vote was "party-line." That is a keen insight from a person who somehow saw neither bias in the proposed books nor any factual errors.

There is no question that we face environmental challenges and that our children are going to face even more. It's important that our kids receive a thorough and extensive education about these problems and the many problem-solving approaches available to them. But giving our children a heavily slanted view of environmental issues - slanted in any direction - will only poison the virtuous pursuit of safety, health and environmental quality.

If we choose to use environmental education as a vehicle to promote political agendas of whatever stripe, we will ill-prepare our children for overcoming the challenges they face.

Dr. Kenneth Green is senior fellow at Reason Foundation and Chief Scientist at Frasier Institute.

Getting the Bias Out of Environmental Communications

info@reason.org (Kenneth Green) — Mon, 01 Oct 2001 16:29:00 EDT

...

Q&A About Forests and Global Climate Change

info@reason.org (Kenneth Green) — Sat, 01 Sep 2001 00:00:00 EDT

...

Reducing Global Warming Through Forestry and Agriculture

info@reason.org (Steven Schroeder) info@reason.org (Kenneth Green) — Sun, 01 Jul 2001 00:00:00 EDT

Executive Summary

Elevated levels of carbon dioxide and other “greenhouse” gases may be contributing to higher global average temperatures in recent years, a trend frequently referred to as global warming. Some scientists predict that such warming could increase sea levels, stimulate weather that is more violent, alter patterns of disease, and have other potentially damaging effects. Carbon, a constituent of all the main greenhouse gases, is believed to play a pivotal role in the regulation of the earth’s temperature.

The major human activities that cause greenhouse gases to build up are the burning of wood and fossil fuels, and changes in land use that result in fewer plants capturing less carbon dioxide from the atmosphere. Since the beginning of the industrial revolution (around 1750), carbon dioxide in the air has risen more than 30 percent, from 278 to 368 parts per million, and other carbon-containing greenhouse gas concentrations have increased even more. Methane concentrations, for example, have risen by nearly 120 percent since the beginning of the 19th century, from approximately 790 parts per billion in 1850, to the present level of over 1,725 parts per billion.

Concerns over potentially negative effects of prolonged global warming have stimulated interest in restraining the buildup of greenhouse gases in the atmosphere. Proponents of immediate action favor measures aimed at slowing or stopping the buildup of greenhouse gases by using less fossil fuel, or using it more efficiently. An alternate approach that is gaining more attention shifts the focus away from slowing generation of greenhouse gases to removing greenhouse gases from the atmosphere and storing, or “sequestering,” them in a variety of ways. This study focuses on those efforts.

Advocates of sequestration point to numerous benefits of this approach, including lower costs of carbon dioxide control, reduced impact on lifestyles of people in developed countries, and greater ability to achieve domestic greenhouse gas reductions without transferring wealth or technology abroad.

There are three major ways to store additional carbon in forests (including soil):

Preventing Long-term Deforestation. In some cases, forested areas are harvested but not replanted, or land is converted to non-forestry or non-agricultural use. This limits the Earth’s natural ability to regulate greenhouse gases, including carbon dioxide. This can be offset by reducing long-term or permanent deforestation.
Increasing Tree-planting. More trees can be planted on marginal land, such as less-productive agricultural land. This directly removes additional carbon dioxide from the atmosphere, and locks it away in the woody tissue of the trees.
Improving Forest Management. Advanced forest management practices can be adopted more quickly and uniformly, particularly in developing countries where they have not yet taken hold. With such techniques, forests can be managed for long-term health and carbon storage as well as for wood production.

Carbon can also be stored in agricultural soils, which can retain as much carbon as forest soil. Practices that maximize both plant growth and carbon-retention in soils (called conservation tillage) can be used for cotton and most grain crops. Specific conservation-tillage practices that can increase carbon-retention by agricultural soils include:

No-till Cultivation. Tilling agricultural soils liberates trapped carbon, and is not always necessary for crop cultivation.
Maximizing Carbon Retention Through Fertilizer and Herbicide Use. Changing the way that fertilizers and herbicides are used can alter the way that agricultural soils store carbon-bearing matter underground, maximizing the retention of carbon.
Planting of “Cover Crops.” Fields with fewer cover crops are more likely to undergo degradation of subsurface carbon-bearing. Cover crops can be planted on “fallow” agricultural lands to preserve soil nutrients and carbon content between primary crop periods.

Many farmers are already adopting these practices to achieve higher production (and usually lower costs), allowing additional marginal land to be retired and reforested.

Finally, some forest and agricultural land can be used to grow trees and crops for “biomass.” Biomass is a term used to encompass the many different types of carbon-bearing plant matter that are not ultimately used for food production. Biomass includes unusable portions of agricultural crops, such as crop stubble, wheat stalks, and corn stalks. Biomass can be burned directly, or can be converted to fuels such as methanol, and has the potential to replace a significant amount of petroleum-derived fossil fuels.

While burning fossil fuels such as oil and coal adds carbon to the atmosphere, biomass avoids this by recycling the same carbon over and over again. Although carbon is released to the atmosphere when biomass fuel is burned, the carbon is pulled out of the atmosphere when the crops are re-planted.

Global carbon dioxide emissions contained about 8.2 gigatons of carbon in 2000 and, with “business as usual,” could reach 14.5 gigatons in 2050.1 Based on evaluation of published studies, potential amounts of emissions that could be stored in plants and soil or avoided by using biomass fuel, and their approximate costs, can be summarized as follows:

Changes in Forest Management. This could result in about 2 gigatons of carbon stored per year, at an average cost around $4 per ton of carbon stored.
Changes in Agricultural Management. This could result in about 1 gigaton per year in soil, with operational savings offsetting most of the costs.
Use of Biomass Fuels. This could substitute for 2 gigatons of annual fossil fuel emissions at a cost similar to the replaced fossil fuels.

Summing up these three areas, a projected potential annual savings of 5 gigatons would offset or avoid 35 percent of the “business as usual” emissions in 2050. Savings would grow toward this annual rate as sequestration efforts are established, be maintained for 30 to 50 years, and then slowly taper off as forests and soils approach their carbon capacity.

Major Media Mangle Global Warming Report

info@reason.org (Kenneth Green) — Thu, 07 Jun 2001 00:00:00 EDT

The National Academy of Sciences' National Research Council just released a report that basically says temperatures are rising, but we aren�t sure who to blame, while uncertainties in science make predictions of future climate conditions tentative at best. Unfortunately, politicians and journalists somehow missed everything except "temperatures are rising" in the "Climate Change Science: an Analysis of Some Key Questions" report.

"Panel Tells Bush Global Warming Is Getting Worse," screamed the New York Times.

"NAS Tells Bush Global Warming is Real Problem," shouted the Washington Post.

Both articles go on to observe that these new dire predictions might cause President Bush to re-think his position on climate change. Phil Clapp, president of the National Environmental Trust, tells the New York Times, "The president can no longer wiggle out of aggressive action by arguing that the science is inconclusive." The Post quotes John Kerry (D-Mass) as saying, "The report underscores . . . the full measure of the vacuum in the administration's leadership on this issue."

But statements from within the NAS report make one wonder if any of these people bothered to read the slim 24-page report before calling a press conference or filing their stories.

The very first page of the NAS report says, "Because there is considerable uncertainty in current understanding of how the climate system varies naturally and reacts to emissions of greenhouse gases and aerosols, current estimates of the magnitude of future warming should be regarded as tentative and subject to future adjustments upward or downward." That�s not exactly what any rational person would call an unequivocal affirmation that global warming is a well-defined threat.

The authors of the report are not even sure that you can blame global warming on humans. The report states that "A causal linkage between the buildup of greenhouse gases in the atmosphere and the observed climate changes during the 20th century cannot be unequivocally established." The statements made in the NAS report are so contrary to the conventional views of manmade climate change that headlines should have read, "NAS panel says humans may not be causing global warming!"

And while the NAS report observes that climate models have many uses, they also observe that climate models are far from perfect. They note that the simulation ability of such models is limited by "uncertainties in their formulation, the limited size of their calculations, and the difficulty of interpreting their answers that exhibit almost as much complexity as in nature." Predictions of future climate rest on a raft of assumptions, such as those projecting future fossil fuel and land-use changes that can affect the concentration of CO2 and other gases and aerosols. But these are exactly the areas, according to the NAS, where the science is weakest. The NAS authors point out that there are large uncertainties in underlying assumption about "population growth, economic development, life style choices, technological change and energy alternatives" used in predicting future climate conditions.

Perhaps the most egregiously under-reported aspect of the NAS report is the first "mainstream" acknowledgement that the landmark reports of the United Nations Intergovernmental Panel on Climate Change (IPCC) are significantly influenced by governmental officials and policy makers, and are not the purely scientific work of "2,000 scientists." Not only does the NAS reveal that the authors of the IPCC report are invited to participate by governmental representatives and tend to be disproportionately non-American, the NAS observes that governmental representatives are full partners in writing the "Summary for Policymakers" of the landmark IPCC reports. Stunningly, the NAS report confirms previously contested charges that the technical reports are retroactively modified in order to make them match the politically derived summary. Finally, the NAS points out that the "Summary for Policymakers" tends to downplay uncertainty, and admonishes that information about the confidence and probability of various predictions should always be included and looked at carefully, even in political summaries. Without such information, the Academy says, "...the IPCC Summary for Policymakers could give an impression that the science of global warming is "settled," even though many uncertainties still remain."

The 11-member panel of the NAS calls for an ambitious research agenda to address the remaining uncertainties of global warming science. They also give marching orders to American scientists: "The most valuable contribution U.S. scientists can make," the NAS says, "is to continually question basic assumptions and conclusions, promote clear and careful appraisal and presentation of the uncertainties about climate change as well as those areas in which science is leading to robust conclusions, and work toward a significant improvement in the ability to project the future."

Amen.

Dr. Kenneth Green is senior fellow at Reason Foundation and Chief Scientist at Frasier Institute.

National Academy of Sciences Raises More Climate Questions

info@reason.org (Kenneth Green) — Thu, 07 Jun 2001 00:00:00 EDT

A thorough understanding of the uncertainties is essential to the development of good policy decisions.

The most valuable contribution U.S. scientists can make is to continually question basic assumptions and conclusions, promote clear and careful appraisal and presentation of the uncertainties about climate change as well as those areas in which science is leading to robust conclusions, and work toward a significant improvement in the ability to project the future.

On June 6, 2001, an 11-member panel of the National Academy of Sciences (NAS) released "Climate Change Science: An Analysis of Some Key Questions," a report they prepared for President George W. Bush. The report confirms important points that many analysts critical of mainstream portrayals of climate change science and policy have argued for years.

In this report, NAS points out that:

Uncertainties in climate science throw the question of human causality of climate change into doubt;
Uncertainties in projecting future social trends make predictions of future climate conditions "tentative;"
Political influences played a significant role in shaping the "Summary for Policymakers of the United Nations' Intergovernmental Panel on Climate Change (IPCC), a key formal document in the U.N.'s three-volume Third Assessment Report on climate change; and
Understanding of climate change science is far from complete and is, in fact, still rudimentary in many areas.

The NAS report begins with an adamant statement that "temperatures are, in fact, rising." This is not news, however; virtually no one has argued that this is not the case. While the NAS goes on to affirm some of the technical claims from both the third Assessment Report of the U.N�s IPCC and the National Assessment Report of the United States Global Change Research Project, the NAS report has many sharply cautionary warnings scattered throughout.

This document culls key statements from the NAS report into discrete categories:

Key statements on understanding of the climate system and our forecasting abilities;
Key statements on human causation of observed 20th century climate changes;
Key statements on research needs (the only actual recommendations given by the NAS); and
Key statements on the IPCC process, scientific representation, and political influence on the "Summary for Policymakers" in the U.N.'s third Assessment Report.

1. Key Statements on Understanding of the Climate System and our Forecasting Abilities

While the NAS "generally agrees with the assessment of human-caused climate change" presented by the United Nations' IPCC, the authors of the NAS report seek to "articulate more clearly the level of confidence that can be ascribed to those assessments, and the caveats that need to be attached to them."

The following quote from the NAS report summarizes that effort quite well:

Because there is considerable uncertainty in current understanding of how the climate system varies naturally and reacts to emissions of greenhouse gases and aerosols, current estimates of the magnitude of future warming should be regarded as tentative and subject to future adjustments upward or downward.

The NAS report points out the many weaknesses in current understanding of climate processes:

Much of the difference in predictions of global warming by various climate models is attributable to the fact that each model represents these [feedback] processes in its own particular way.

The study of the role of black carbon in the atmosphere is relatively new. As a result, it is characterized poorly as to its composition, emission source strengths, and influence on radiation.

There is the possibility that decreasing black carbon emissions in the future could have a cooling effect that would at least partially compensate for the warming that might be caused by a decrease in sulfates.

Climate forcing by anthropogenic aerosols is a large source of uncertainty about future climate change.

The greatest uncertainty about the aerosol climate forcing�indeed, the largest of all the uncertainties about global climate forcings�is probably the indirect effect of aerosols on clouds.

The great uncertainty about this indirect aerosol climate forcing presents a severe handicap both for the interpretation of past climate change and for future assessments of climate change.

And while the NAS report clearly affirms the usefulness and importance of climate models, it observes that:

However, climate models are imperfect. Their simulation skill is limited by uncertainties in their formulation, the limited size of their calculations, and the difficulty of interpreting their answers that exhibit almost as much complexity as in nature.

Projecting future climate change first requires projecting the fossil-fuel and land-use sources of CO2 and other gases and aerosols. However, there are large uncertainties in underlying assumption about population growth, economic development, life style choices, technological change and energy alternatives, so that it is useful to examine scenarios developed from multiple perspectives in considering strategies for dealing with climate change.

Scenarios for future greenhouse gas amounts, especially for CO2 and CH4 are a major source of uncertainty for projections of future climate. Successive IPCC assessments over the past decade each have developed a new set of scenarios with little discussion of how well observed trends match with previous scenarios.

Finally, in another powerfully cautionary statement, the NAS confirms that some of the proposed factors involved in climate change are so uncertain that it is unknown whether the factors will cause warming or cooling:

The range of model sensitivities and the challenge of projecting the sign of the precipitation changes for some regions represent a substantial limitation in assessing climate impacts.

2. Key Statements on Human Causation of Observed 20th Century Climate Changes

When it comes to the all-important question of causality, the NAS report contains cautionary statements far stronger than those seen from other august scientific panels:

Despite the uncertainties, there is general agreement that the observed warming is real and particularly strong within the past twenty years. Whether it is consistent with the change that would be expected in response to human activities is dependent upon what assumptions one makes about the time history of atmospheric concentrations of the various forcing agents, particularly aerosols.

Because of the large and still uncertain level of natural variability inherent in the climate record and the uncertainties in the time history of the various forcing agents (and particularly aerosols), a causal linkage between the buildup of greenhouse gases in the atmosphere and the observed climate changes during the 20th century cannot be unequivocally established.

The fact that the magnitude of the observed warming is large in comparison to natural variability as simulated in climate models is suggestive of such a linkage, but it does not constitute proof of one because the model simulations could be deficient in natural variability on the decadal to century time scale.

3. Key Statements on Research Needs

While the NAS report does not make outright recommendations, it does point out research needs and encourages additional research. This itself points to weaknesses in the underlying scientific understanding of climate change.

Reducing the wide range of uncertainty inherent in current model predictions of global climate change will require major advances in understanding and modeling of both (1) the factors that determine atmospheric concentrations of greenhouse gases and aerosols, and (2) the so-called �feedbacks� that determine the sensitivity of the climate system to a prescribed increase in greenhouse gases. Specifically, this will involve reducing uncertainty regarding: (a) future usage of fossil fuels, (b) future emissions of methane, (c) the fraction of fossil fuel carbon that will remain in the atmosphere and provide radiative forcing versus exchange with the oceans or net exchange with the land biosphere, (d) the feedbacks in the climate system that determine both the magnitude of the change and the rate of energy uptake by the oceans, which together determine the magnitude and time history of the temperature increases for a given radiative forcing, (e) the details of the regional and local climate change consequent to an overall level of global climate change, (f) the nature and causes of the natural variability of climate and its interactions with forced changes, and (g) the direct and indirect effects of the changing distributions of aerosol.

4. Key Statements on the IPCC Process, Scientific Representation, and Political Influence on the "Summary for Policymakers" in the U.N.'s Third Assessment Report

Perhaps the most fascinating element of the NAS report is its inquiry into the limitations of the IPCC process, and its questioning whether the IPCC "Summary for Policymakers" the most widely quoted element of all the IPCC publications faithfully represents the underlying technical reports.

While the NAS finds the underlying technical reports of the IPCC on the science of climate change (a.k.a. the "Working Group 1" section of the Third Assessment Report) to be rigorous and representative of mainstream scientific thought, it raised many concerns about the influence of political forces on the IPCC's overall reporting process and on key documents such as its "Summary for Policymakers" in the Third Assessment Report.

The NAS also confirms a practice that many critics of past IPCC reports have questioned: that of retroactively altering the technical studies to support the statements given in the "Summary for Policymakers." While "most" of these changes were acceptable to the IPCC chapter authors, the NAS suggests that "some scientists may find fault with some of the technical details, especially if they appear to underestimate uncertainty" (page 23).

Additional points raised by the NAS report include the following:

The 'Summary for Policymakers' reflects less emphasis on communicating the basis for uncertainty, and a stronger emphasis on areas of major concern associated with human-induced climate change. This change in emphasis appears to be the result of a summary process in which scientists work with policy makers on the document.

Changes to the 'Summary for Policymakers' are only approved by 'a fraction of the lead and contributing authors,' not the full body of authors of the WG1 report.

After analysis, the committee finds that the conclusions presented in the 'Summary for Policymakers' and the 'Technical Summary' are consistent with the main body of the report. There are, however, differences. The primary differences reflect the manner in which uncertainties are communicated in the 'Summary for Policymakers.' The 'Summary for Policymakers' frequently uses terms (e.g., likely, very likely, unlikely) that convey levels of uncertainty; however, the text less frequently includes either their basis or caveats.

Confidence limits and probabilistic information, with their basis, should always be considered as an integral part of the information that climate scientists provide to policy- and decision-makers. Without them, the IPCC 'Summary for Policymakers' could give an impression that the science of global warming is 'settled' even though many uncertainties still remain.

In addition, the preparation of the 'Summary for Policymakers' involves both scientists and governmental representatives. Governmental representatives are more likely to be tied to specific government postures with regard to treaties, emission controls, and other policy instruments.

Without an understanding of the sources and degree of uncertainty, decision-makers could fail to define the best ways to deal with the serious issue of global warming.

The newly released "Climate Change Science: An Analysis of Some Key Questions" report of the National Academy of Sciences is a noteworthy contribution to the ongoing debate over climate policy. While understanding that the Earth�s average temperature has increased recently, and affirming the mainstream scientific view that some of this warming is attributable to human action, the NAS report also acknowledges the current limitations of scientific understanding, and the dangers of mischaracterizing those limitations by exaggerated reporting that downplays uncertainty.

Dr. Kenneth Green is senior fellow at Reason Foundation and Chief Scientist at Frasier Institute.

Relevant Reason Publications

Plain English Guide 3: Exploring the Science of Climate Change

E-brief 105: Mopping Up After a Leak: Setting the Record Straight on the "New" Findings of the Intergovernmental Panel on Climate Change (IPCC)

Evaluating the Kyoto Approach to Climate Change (.pdf)

A Baker's Dozen: 13 Questions People Ask about Climate Change

IPCC Global Warming Report Fails to Deliver Sound Policy

info@reason.org (Kenneth Green) — Tue, 27 Feb 2001 00:00:00 EST

Climate is in the news again, as the United Nations Intergovernmental Panel on Climate Change (IPCC) has just released the Summary to Volume 2 of its Third Assessment Report (TAR) on climate change.

The IPCC released Volume 1 of the TAR in December of 2000, summarizing what is known about the science of climate change and speculating on the broad elements of how the climate is expected to change in the future. Volume 2 picks up where Volume 1 left off, translating estimated future temperatures into estimated future weather conditions, out to the year 2100.

The news from Volume 2 is gloomy. The Volume 2 "Summary for Policymakers" raises the specter of coastal inundation, increasingly violent weather, more droughts, increased spread of mosquito-borne illnesses, crop failures, and more. Even more depressing than the predictions, and the uncritical way in which the media are accepting them, is the way in which the summary puts forward a distorted image of the actual state of knowledge regarding future climate change impacts.

Global warming, and the climate changes that may result from it, is a source of concern to many people, and rightfully so. Radical changes in climate could cause severe disruption to ecosystems and human societies, regardless of the underlying causes of that change.

But rational policymaking requires an understanding of climate issues that reflects the true state of knowledge, not biased representations used to justify pre-selected policy objectives. The IPCC report process is a tremendous effort involving many hundreds of well-intentioned scientists. The three TAR volumes, which run to 1,000 pages each, are rich in detail and are careful to include numerous caveats that accurately portray the large uncertainties in predictions of future climate changes and impacts. However, the "Summary for Policymakers" in the new Volume 2, like the summary from the Volume 1, fails to carry that careful portrayal forward. Instead, the summary misleads more than it informs, passing off speculation as fact, and blurring key distinctions needed for sound policymaking.

False Certainty

Press reports have trumpeted the higher "degree of certainty" that this new TAR volume represents. One Associated Press article from February 18, 2001 characterized Africa's future as follows:

Grain yields are expected to decrease, and there will be less water available. Desertification will be worsened by reductions in average annual rainfall, especially in southern, North and West Africa. Coastal settlements in Nigeria, Senegal, Gambia, Egypt, and along the East-Southern African coast will be hit by rising sea levels and coastal erosion. [emphasis added]

The Volume 2 summary itself seems to lose track of the difference between predictions, and certainties. As the summary says regarding coastal zones and marine ecosystems,

Many coastal areas will experience increased levels of flooding, accelerated erosion, loss of wetlands and mangroves, and seawater intrusion into fresh water sources as a result of climate change. The extent and severity of storm impacts, including storm-surge floods and shore erosion will increase as a result of climate change including sea-level rise. High latitude coasts will experience added impacts related to higher wave energy and permafrost degradation. Changes in relative sea level will vary locally due to uplift and subsidence caused by other factors.

But footnote number six in the summary reveals the subjective nature of the report's predictions. Though the degree of certainty is reported through numerical ranges, the actual determination of certainty is a subjective exercise in which the authors of the report simply state their opinion and assign a number to it. The analysis does not include any mathematical tests of certainty, nor does it attempt to derive statistical confidence intervals. Instead, the degree of certainty of the report's predictions is based merely on a self-polling of the authors' professional judgment. As the footnote explains:

In this Summary for Policymakers, the following words have been used where appropriate to indicate judgmental estimates of confidence (based upon the collective judgment of the authors using the observational evidence, modeling results, and theory that they have examined): very high (95% or greater), high (67-95%), medium (33-67 %), low (5-33 %), and very low (5% or less). In other instances, a qualitative scale to gauge the level of scientific understanding is used: well established, established-but-incomplete, competing explanations, and speculative.

One has to applaud this attempt to quantify confidence levels, but one also has to ask whether these "confidence" measures are inherently misleading. Some expert comments about the models used to predict future regional climate changes suggest so. According to a Science news brief from June 2000, Jerry Mahlman, Director of NOAA's Geophysical Fluid Dynamics Laboratory observes that when regional climate models try to incorporate external factors such as population and economic growth rates, "the details of future climate recede toward unintelligibility." Climate modeler Filippo Giorgi, of the Abdus Salam International Center for Theoretical Physics, explains, regarding regional climate models of the sort used by the TAR authors, that "For the most part, these sorts of models give a warning, but they tend to give very different predictions, especially at the regional level, and there's no way to say one should be believed over another."

Further, as climate modelers from four separate climate modeling centers observe in an article from Nature, "Forecasts of climate change are inevitably uncertain." They go on to explain that "A basic problem with all such predictions to date has been the difficulty of providing any systematic estimate of uncertainty," a problem that stems from the fact that "these models do not necessarily span the full range of known climate system behaviour" (Allen, et al., October 2000).

What About the Human Factor?

The Volume 2 summary discusses the many things that can happen as a result of climate change, but a key distinction is buried in the very first footnote, which explains that the climate change talked about in the report includes all forms of climate change, whether it is warming or cooling, human-caused, or non-human-caused. The summary does not identify the relative contribution of human activity to overall global warming.

However, it is precisely this information that is necessary for making determinations of appropriate action - whether to try and reduce a particular human activity in order to forestall global warming, or whether to take actions to ensure that ecosystems and human systems are prepared to adapt to climate change, whatever the cause.

It isn't surprising that the media have not picked up on this, since the Volume 1 summary also glossed over the subject of climate change caused by human activity. Climate impacts are calculated based on predicted increases in global average temperature, using models that break out regional impacts of such changes. But predicted increases in temperature taken from the first summary were fed into "impact models" without observing that the majority of physically observed warming since 1860 was of non-human origin, and would have happened regardless of human action. The Volume 2 Summary similarly fails to point out what portion of its predicted future impacts flow from such non-human climate influences. As a result, the blurring of the first report carries over to the second, creating the incorrect impression that both climate change and its future impacts are solely the result of human activity.

This muddling of the underlying causes of climate change makes it difficult for policymakers - the very people intended to receive the report - to make intelligent decisions about whether to take actions to reduce the human contribution to climate change, or to prepare to adapt to the climate changes that are happening from forces outside of human control, such as changes in solar output.

Pessimistic and Unsubstantiated Assumptions

Another problem with the current report data is that all of its predictions are based on estimates of global warming and sea-level rise from Volume 1 - and some of those predictions were of questionable validity.

Working from more extreme "worst-case" estimates, the Volume 1 summary suggested a higher range of potential warming and sea-level rise by 2100. The average global temperature in the new report is modeled to increase from 1.5 to 5.8 degrees Centigrade (2.7 to 10.4 degrees Fahrenheit) by 2100. Predicted sea-level increases under the new scenarios range from 14 to 80 cm. (5.5 to 31.2 inches) by 2100.

However, the output of these models is only as good as what was put in. While Volume 1 competently describes what's currently known in climate change science, it does depend on more than a few questionable assumptions. These assumptions underlie the worst-case scenarios predicted for temperature and sea-level rise, including:

No mid-course abatement or education programs will be implemented between now and 2100, even in the face of what are predicted to be extreme climate changes;
Global deforestation will not decrease;
World gross domestic product (GDP) will increase by a factor of 10 by 2100;
Most energy production will be from carbon-based fuels, with limited technology growth;
Carbon dioxide emissions will nearly quadruple by 2100;
Methane emissions will more than double by 2100;
Carbon monoxide emissions will nearly triple by 2100;
Volatile organic carbon emissions will nearly triple by 2100; and
Fluorocarbon levels will rise dramatically by 2100, in some cases by a factor of 100.

Volume 1 provided little justification for these assumptions, which were generated by a special working group of the IPCC and which were reviewed in an alternate, informal review process far less rigorous than the scientific review process used in either the Volume 1 or Volume 2 review processes.

Conclusions

While everyone is rightly concerned about prospective changes in the global climate, it's questionable whether the TAR reports contribute to the process of developing effective climate policies. Though the underlying reports carefully hedge with statements of uncertainty, the summaries of the reports fail to accurately reflect the uncertainties that are a vital part of crafting rational policy responses.

The newly released Volume 2 "Summary for Policymakers" is no exception. It makes predictions based on simple models that: do not take into account current or historic climate phenomenon, are not calibrated to observed climate phenomenona, fail to emulate fundamental climate processes, and project a veneer of certainty that is not supportable from underlying technical reports or statements regarding similar exercises made in mainstream science journals.

Even accounting for the limitations of the models used in projecting 100-year weather patterns, the predictions of the report reflect garbage-in-garbage-out modeling. They are based on possible future scenarios that include speculative and often unreasonably pessimistic predictions about population, fuel use, technology development, international trade, development rates, and dozens of other factors.

By lumping together predictions of warming that have some human, and some non-human components, the report also fails to provide the kind of information that policymakers need in order to choose between policies that aim to slow global warming - by reducing greenhouse gas emissions - and policies that aim to adapt to global warming - by investing in technologies to offset specific climate impacts of concern, such as increased floods, or growth in insect-borne diseases.

The ramifications of climate change policy are too far-reaching to be based on distorted representations of the current state of knowledge in either climate science, or climate predictive ability. The newly released summary of IPCC's Third Assessment Report on Impacts, Adaptation, and Vulnerability follows a pattern of policymaker summaries that weaken the link between climate policy and reality, and subvert the goal of ranking environmental policy interventions based on rigorous use of scientific principles.

Dr. Kenneth Green is senior fellow at Reason Foundation and Chief Scientist at Frasier Institute.

Texas Enters Global Warming Fray

info@reason.org (Kenneth Green) — Tue, 16 Jan 2001 00:00:00 EST

Even as scientists are reporting a cooling of more than 2 degrees C in Antarctica over the last 35 years,[1] Texas regulators are about to step into the fray over global warming.

In response to a petition filed during the last presidential campaign, the Texas Natural Resource Conservation Commission (TNRCC) agreed to: [2]

Compile information on quantities of greenhouse gases currently in Commission and EPA databases (or estimate emissions where no information exists);
Survey the activities of other states and the federal government to assess what actions are being taken with respect to global warming;
Consult with other state agencies and universities regarding the science, potential effects, and potential solutions to global warming;
Estimate the reduction in greenhouse gases from activities already completed by the Commission and actions being completed at this time both at the state and federal levels;
Create a registry of these emission reductions; and
Prepare a report summarizing and analyzing the findings of items one through four. The report "should include recommendations to the Commission as to actions that the findings indicate are warranted, including any recommended changes or additions to existing commission rules."

The TNRCC posted a draft of the report to their Website on January 14, 2002 (http://www.tnrcc.state.tx.us/oprd/sips/greenhouse/index.html).

Some Troubling Recommendations

While much of the report is an unobjectionable attempt to summarize the state of knowledge regarding greenhouse gas emissions at the state level, some of the recommendations made by the Executive Director are troubling. Specifically, the Executive Director recommends that the TNRCC:[3]

Encourage the federal government to increase vehicle fuel efficiency standards for all classes of vehicles;
Encourage and support the development of vehicle technology changes such as hybrid vehicles, alternate fuels which result in lower overall emissions, and fuel cells which produce little or no emissions; and
Develop more detailed inventories of greenhouse gas emissions and sinks in Texas pursuant to federal methods yet to be developed.

First, consider the idea of encouraging increases in federal fuel efficiency standards, alternate fuel technologies, and so on. A wealth of research has shown that such actions on the part of government agencies can actually cause much more harm than good. Both alternative-fuel vehicles and more fuel-efficient vehicles require advanced technologies and the use of high-tech lightweight materials. But analysts have long observed that governments are notoriously poor at picking successful technologies, while forcing weight-reductions in vehicles is only likely to increase the likelihood that a passenger in such a vehicle will be seriously injured in a traffic accident.[4]

With regard to greenhouse gas inventories, high levels of uncertainty attached to every element of climate science puts the cart somewhat before the horse: it is still not known which greenhouse gases need to be reduced, if any. Yet creation of an inventory presumes that these gases are a problem, and warrant the cost and effort of tracking emission quantities. The creation of an inventory will also provide ammunition for the various pressure groups pushing greenhouse gas reductions regardless of the scientific state of knowledge, which is far from clear.[5]

Avoiding Common Pitfalls

Still, if an emissions inventory is unavoidable, it is worth noting that the Executive Director�s recommendation for an inventory avoids common pitfalls.

On the positive side, the recommendation calls for a greenhouse gas emission inventory that includes both sources of greenhouse gases as well as the "sinks" such as tree-planting and agricultural activities that remove carbon dioxide from the atmosphere. Far too little attention is given to the remarkable promise of carbon "sequestration" as a potential alternative to reducing emissions of greenhouse gases. Without considering carbon sinks of this sort, any partial inventory would be misleading: only the net greenhouse gas contribution of a given area is relevant to understanding its climate impact.

Making the inventory dependent on the establishment of federal methods for measuring greenhouse gases is also meritorious, since, if such an inventory is inevitable, such standard methodologies will at least prevent various states from low-balling their emissions, making the emissions of other states appear larger in comparison than they may actually be.

The Texas Natural Resource Conservation Commission was petitioned to enter the climate fray during an election, when climate policy was a high-profile issue. Considering the clamor for draconian greenhouse gas reduction measures, the resulting draft report on greenhouse gases is surprisingly benign. The TNRCC draft report has many meritorious voluntary measures that foster the reduction of greenhouse gas emissions by those who believe such reductions will increase environmental quality and protect human health. Still, several troubling recommendations mar the draft report, and would benefit from removal or modification.

TNRCC should stick with such no-regrets measures such as carbon sequestration and the capture of presently wasted landfill gases, while eliminating recommendations such as greenhouse gas emission inventories and technology mandates. To go beyond no-regrets actions on climate change, at this point, would divert resources from the management of known hazardous air pollutants toward gases that are only speculated to have a largely undefined impact on the environment and human health. Such investment of scarce public-health resources is likely to yield little positive return, and possibly do more harm than good.[6]

Dr. Kenneth Green is senior fellow at Reason Foundation and Chief Scientist at Frasier Institute.

Endnotes

[1] Peter T. Doran, et al., �Antarctic Climate Cooling and Terrestrial Ecosystem Response,� Letters to Nature, Nature (Online), January 13, 2001.

[2] Texas Natural Resource Conservation Commission, �Decision of the Commission Regarding the Petitions for Rulemaking Filed by Henry, Lowerre, and Frederick, LLP on Behalf of Public Citizen�s Texas Office, Clean Water Action, Lone Star Sierra Club, Sustainable Energy and Economic Development Coalition, and Texas Campaign for the Environment,� Docket No. 2000-0845-RUL (Austin, TX: Texas Natural Resource Conservation Commission) August, 2000.

[3] Texas Natural Resource Conservation Commission, �Overview and Recommendations Identified by A Report to the Commission on Greenhouse Gases,� Draft, (Austin, TX: Texas Natural Resource Conservation Commission), January 2002 (http://www.tnrcc.state.tx.us/oprd/sips/greenhouse/ExecutiveSum.pdf).

[4] Harry Gordon and Peter Richardson, �The Case Against Electric Vehicle Mandates in California,� Policy Study no. 189 (Los Angeles: Reason Foundation) May 1995. See also, Sam Kazman, �The Leaked Study on CAF�, Why it Doesn�t Justify Higher Fuel Economy Standards,� (Washington D.C.: Competitive Enterprise Institute) July 2001 (http://www.cei.org/gencon/004,02093.cfm); and Julie DeFalco, �CAFɒs Lethal Impact on Auto Safety,� (Washington D.C.: Competitive Enterprise Institute) June 1999.

[5] Kenneth Green, �Exploring the Science of Climate Change,� Plain English Guide No. 3, (Los Angeles: Reason Foundation) August 2000.

[6] Kenneth Green, �Seeking Safety in a Dangerous World: A Risk-Reduction Framework for Policymakers,� �Policy Study No. 261 (Los Angeles: Reason Foundation) August 1999.

Group's Summary Overheats Warming Threat

info@reason.org (Kenneth Green) — Mon, 27 Nov 2000 00:00:00 EST

Every other November, groups representing governments, environmentalists, industry and others attend an international meeting to plan global warming policy. This year, they're meeting in the Hague.

Many people worry about disastrous changes in climate and see recent omens as troubling. Changing temperatures near the Earth's surface suggest the climate, largely stable for the last 10,000 years, is resuming older, more mercurial patterns. There's been a noticeable global warming trend during the last 100 years, and there's evidence suggesting that humanity may have caused some still-unknown portion of that increase by changing levels of forestation and by emitting greenhouse gases into the atmosphere.

But it's a big leap from a responsible concern about recent climate patterns to the heated rhetoric pouring out of the Hague rhetoric shaped by uncritical media coverage of a draft "summary for policymakers" leaked to the press in late October. The summary for policymakers supposedly reflects the authoritative 3,000-plus-page Assessment Report of the Intergovernmental Panel on Climate Change.

That worthy document is written by several hundred climate investigators and reviewed by several thousand other experts, myself included. The Assessment Report, updated every four years, is often said to reflect what "2,000 scientists think about global warming." The summary, on the other hand, is written by a few high-level members of the Intergovernmental Panel on Climate Change and is reviewed mainly by politicians.

Taking the leaked summary at face value, headlines have blared that scientists predict worse warming than before, with predicted future temperatures rising from the 4.5 degrees Centigrade of the last landmark report to a possible 6.5 degrees Centigrade of warming by 2100. This lends urgency to the mission in the Hague, we are told.

But the reported jump in predicted temperatures only appeared in the summary, not the underlying Assessment Report, and it only appeared in the last six months, long after the scientific review ended. Since the climate itself didn't change radically in the last six months, what accounts for the sudden increase in the forecast?

The answer lies in a sudden gust of questionable assumptions that blew into the modeling process six months ago, with limited expert review. Future climate predictions are produced with computer models incorporating thousands of assumptions about the future, including population rates, energy use levels, international economics and so on. These models have improved over the years, but like all computer models, there's a "garbage in, garbage out" problem.

Between April and October 2000, after the expert reviewers of the Assessment Report had done their work, a haphazardly formed sub-group came forward with the assumptions they would use for predicting future climate. One of these new sets of assumptions envisions the worst of all possible worlds, climate-wise, where energy use is profligate, where fossil-fuel use is maximized, and where people do absolutely nothing to improve things, even in the face of massive changes.

That gloomy scenario, cranked through simple climate models, produced the predictions of higher temperatures in 2100. Everything else, sea-level rise, ice melting, rainfall and storm predictions all flow from that one, post-review exercise.

But is this realistic? Consider three of the biggest underlying assumptions. One key assumption is that there will be no programs implemented between now and 2100, even in the face of predicted climate changes. Given that such programs are already being implemented in forestry and agriculture, this assumption can�t be right.

Another assumption is that the entire developing world will completely catch up to developed countries, and have the same per-capita income and energy demand. When you consider that the rich-poor gap has been going in precisely the opposite direction for the last hundred years, that assumption is highly unlikely.

A third assumption suggests that most energy production in 2100 will be from high-carbon fossil fuels, with only moderate advances in efficiency and emission control. Given that the entire history of energy use reflects more efficient use of lower-carbon fuels (particularly during the past 50 years) with sharply lower emissions per unit of energy, this assumption is highly unlikely.

It is only natural for people to be curious about the climate, and concerned about radical change.

By the same token, climate fears are easily inflamed, and humanity will not profit from acting on draft reports that pass off speculation for knowledge, and that sacrifice scientific credibility for political posturing.

Right now, in the Hague, 10,000 people are arguing about how to centrally plan the Earth's climate. The key document setting the tone is a leaked draft laced with unrealistic assumptions and misleadingly portrayed as reflecting "what 2,000 scientists think about global warming." That's more than vaguely unsettling.

Dr. Kenneth Green is senior fellow at Reason Foundation and Chief Scientist at Frasier Institute.

Clearing the Air in Houston

info@reason.org (Kenneth Green) info@reason.org (Lisa Skumatz) — Wed, 01 Nov 2000 00:00:00 EST

Under the Clean Air Act, the Houston-Galveston area has been designated a nonattainment area for ozone, a pollutant created by two other types of air pollution: volatile organic compounds (VOCs) and nitrogen oxides (NO_x).

The extent of Houston-Galveston’s nonattainment suggests that area regulators will have to implement a large number of strategies to reach compliance. But there are many possible pathways that lead to compliance, and the draft State Implementation Plan for Houston-Galveston is peppered with measures that have a history of weak performance and inefficiency.

Conventional regulatory control measures and mandatory behavioral control measures including construction bans, specialized fuel requirements, burdensome inspection programs, traditional permit systems, and other control-based approaches have been shown to lack flexibility, efficiency, and effectiveness, while also igniting social conflict.

Market-oriented strategies, by contrast, allow for flexibility in implementation, provide incentives for cooperation, and help reduce some administrative burdens when compared to conventional approaches. This study describes nearly three-dozen market-oriented or flexible strategies that show promise for assisting the Houston-Galveston area in reaching attainment.

Policymakers in the Houston-Galveston nonattainment area should consider the following:

Vehicle Emissions Pricing is a process in which vehicle registration fees are based upon the level of emissions from the vehicle and annual distances driven. Variations on this theme include strategies to shift fixed-cost fees associated with vehicle ownership to mileage-based fees, providing some (albeit imperfect) connection between registration fees and pollution-generating activity.
Emissions Trading reduces emissions from stationary sources, usually within a single industry and pertaining to a specific pollutant, by setting an overall emission cap for an entire area and allowing sources to trade emission credits based upon the costs and benefits as determined by each source. Some trading systems also allow for the generation of credits through mobile source reductions at facilities or in transportation fleets. These strategies help by limiting pollution and providing incentives to adopt cleaner technologies on an accelerated schedule.
Alternative Permitting Approaches move away from the bean-counting approach of permitting each piece of polluting equipment by establishing facility-wide or even industry-wide emission limits and performance standards for specific industries or companies, thereby allowing them to meet the limits in cost-effective ways or buy and sell, rather than just trade, emission credits. Such alternative strategies have produced great success in several states, including New Jersey, Massachusetts, and Mississippi.
Incentives for Adopting New Technologies (or removal of tax and regulatory barriers to introducing new technologies) can help accelerate the adoption of lower-polluting technologies, replace or retrofit high-polluting fleets, and provide incentives for improved operation of vehicles. Incorporating emission budgets or incentives into construction contracts, for example, could provide incentives for advancing vehicle turnover and off-road engine turnover or retrofit with newer technologies, reducing emissions. A wide range of mechanisms is available, and many have shown promise in other locations.
Incentives or Pricing of Road Usage, including market-based HOV lanes or toll lanes, and time of day road (and parking) pricing can also be very effective in reducing emissions.
More Efficient and Discerning Methods for Inspection and Maintenance Procedures can maintain improved emission levels at lower costs. Using new technology to find non-complying vehicles on the road, and focusing inspection efforts on that segment of vehicles expected to have higher emissions, or allowing emission check exemptions for newer vehicles can provide greatest benefit at lower administrative cost and lower inconvenience to (relative) non-polluters.
Voluntary Employer Incentives Can Encourage Employees to Use Alternatives to Commuting, including parking cash-outs, tax incentives, and creative tradeoffs in benefits packages. Such approaches have performed well in other locations and provide incentives in the private sector and at needed times of day. Incentives can also be provided that encourage the viability of private automobile-sharing cooperatives that help make it practical to avoid automobile ownership for many.

Innovative market-oriented strategies should be among the most prominent strategies considered as regulators develop methods to reach attainment in the Houston-Galveston area. These approaches reduce emissions in a more efficient, equitable, and cost-effective manner than conventional command-and-control approaches.

Innovative strategies can increase compliance and help reduce the need for enforcement because they tend to be more self-enforcing. They allow and encourage flexibility and creativity in reducing emissions and reaching goals. Yet they do not impede the later introduction of other strategies if sufficient progress toward attainment is not met. Most importantly, market strategies can reduce overall costs of achieving attainment goals.

Table of Contents

Introduction*

Conventional Control Measures and Limitations*

A. Permitting*

B. Growth Management or Land-use Controls*

C. Emissions Trading or Emission Fees*

D. Transportation Demand Measures and Commuter Alternatives*

E. Incentives, Pricing, and Trading Strategies*

F. California Reformulated Gasoline and Alternate Fuels*

G. Bans and Limits*

H. Enhanced Inspection and Maintenance*

Summary*

About the Authors*

Part 1

Introduction

Ground-level ozone is produced from a combination of nitrogen oxides (NO_x), volatile organic compounds (VOCs), sunlight, heat, and other weather conditions. Since heat and sunlight play pivotal roles in the formation of ozone, May through September is designated as "ozone season." Controlling ozone formation is complicated because:

NO_x and VOCs come from a broad variety of sources;
The climactic and geographic conditions contributing to ozone formation cannot be controlled; and
The reaction produced by the above components varies with their proportions in the mixture.

A small quantity of NO_x is generated by a variety of natural sources, such as lightning, volcanic activity, and soil microbes. However, most NO_x sources are manmade, released as emissions from both stationary and mobile sources. VOCs are released from both organic sources, such as foliage, and human sources, such as industrial solvents.

For those areas that have ozone concentrations in excess of federal standards, the U.S. Environmental Protection Agency (EPA) requires the submittal of a State Implementation Plan (SIP), containing a list of proposed strategies addressing on-road and off-road mobile sources, and point-source strategies sufficient to reduce emissions to acceptable levels.

The eight-county Houston-Galveston area was designated a nonattainment area for exceeding ozone pollutant standards, was labeled "Severe II," and given a timetable of the year 2007 to reach attainment. A state implementation plan (SIP) was submitted to the EPA, providing structure and strategies for reducing emissions and reaching compliance.

While the Houston-Galveston area meets federal standards for sulfur dioxide, carbon monoxide, nitrogen dioxide, some classes of particulate matter, and lead, the Houston area exceeds federal standards in the emissions of volatile organic compounds (VOCs), compounds that contribute to the formation of ozone. The Clean Air Act requires a 15 percent reduction in these emissions from 1990 levels. The Houston-Galveston area also exceeds federal standards for nitrogen oxides (NO_x), which are also ozone precursors.

While reducing the levels of VOC in the Houston-Galveston area would remove some ozone precursors, there would still be enough to cause a problem. What determines the extent of ozone formation in Houston-Galveston, then, is NO_x.

Table 1 summarizes the situation for VOC and NO_x in the Houston-Galveston area. The table shows that the highest percentage of NO_x arises from point sources, followed by on-road and off-road generation sources, each of which contributes a substantial share to the overall NO_x problems in the Houston-Galveston area.

Table 1: Houston Galveston Area Nonattainment Area Emissions Summaries (In Tons Per Day (TPD))
	VOC emissions, in tpd	Percentage of VOC by source	NO_x emissions, in tpd	Percentage of NO_x by source	CO emissions, in tpd	Percentage of CO by source
Point	209.04	9.8 %	672.05	53.8%	243.37	7.2 %
Area	177.78	8.3 %	15.58	1.2 %	34.11	1.0 %
Non-Road Mobile	147.91	6.9 %	260.49	20.8 %	1425.66	42.3 %
On-Road Mobile	173.76	8.2 %	302.04	24.2 %	1667.87	49.5 %
Natural	1422.34	66.8 %	-	-	-	-
Total	2130.83	100.0 %	1250.16	100 %	3371.03	100 %

Source: Texas Natural Resource Conservation Commission, Houston/Galveston Nonattainment Area, tnrcc.state.tx.usairaqpeirsumhg.htm

Table 2: Houston Highway Emissions, 1990 Base Case
	NO_x	VOC
1990 Base Case Emissions	251.70	337.10
1999 SIP Budget for 2000	283.01	132.68

Table 2 summarizes the highway emission problems in the Houston-Galveston area, and Table 3 shows the distribution of emissions for off-road construction equipment. As the tables show, Houston’s NO_x problems are roughly half generated by stationary, or "point" sources, and half by mobile sources, both on- and off-road.

Table 3: 2007 Houston-Galveston Equipment NO_x Emissions
Source	Tons per Day NO_x	Source	Tons per Day NO_x
Crawler tractors Rubber-tired loaders Tractors/Loaders/Backhoes Cranes Off-highway trucks	22 14 11 9 7	Off-highway tractors Excavators Graders Scrapers Other	7 6 5 4 16
		Total	102 tons/day

Source: U.S. EPA Region 6, personal communication to Lisa Skumatz from Guy Donaldson, 3/17/2000.

Part 2

Conventional Control Measures and Limitations

A variety of conventional strategies have been proposed to address Houston’s air-emission problems. These include:

Permitting strategies;
Land use or sprawl controls;
Emission caps and budgets;
Demand management and commuter alternatives;
Incentives, pricing, and trading strategies;
Reformulated fuels;
Bans and Limits; and
Inspection and maintenance, and others.

The elements listed in the proposed Houston-Galveston State Implementation Plan might well bring the area into compliance with federal standards. However, research suggests that several of these measures perform poorly in the real world, carry significant negative impacts, and would be better replaced with innovative alternative approaches to reducing emissions.

Negative impacts include significant infringement on individual autonomy and lifestyle choice; increased costs for energy, goods, and services; regional impacts on employment, economic competitiveness, and productivity; poor allocation of public health and environmental agency resources; and lost opportunities to address other social and environmental problems through resource misdirection.

Theory and experience suggest that innovative and market-oriented approaches could provide equal or better environmental performance, while causing less negative impacts.

A. Permitting

Historically, the conventional agency approach to stationary-source control has centered on the issuance and enforcement of permits. In a permitting approach, various pieces of equipment (such as boilers, incinerators, etc.) are individually permitted based on the emissions they produce. Installation of new equipment or changes in equipment require a permit revision or new permit applications. Permit-oriented controls identified in the Houston-Galveston SIP include, for example, the requirement for Reasonably Available Control Technology (RACT) on all stationary source equipment inside the Houston-Galveston area.

However, research suggests that several of these measures perform poorly in the real world, carry significant negative impacts, and would be better replaced with innovative alternative approaches to reducing emissions.

But the permit-based approach has many problems, not the least of which is a tendency for permits to proliferate. As previous studies have documented, permit-based approaches suffer from three major problems:

Permits focus on compliance, not performance. Permits regulate equipment and are merely a proxy for environmental improvement. While businesses are lost in the shuffle of paperwork and worried about compliance, they are less able to focus on how to best achieve actual emission reductions. Narrowly highlighting certain procedures or equipment isolates firms from the greater goal of environmental protection and deflects attention from pollution prevention and environmental innovation. On the agency side, permit writing and enforcement become ends in themselves, utilized for raising funds for the department or to track the success of a particular agency. Compliance, not performance, becomes the main focus for both the regulator and the regulated community.
Permit programs are difficult to reform. Permits create constituencies with a vested interest in their continuance, and reform becomes a very difficult exercise. The pressures against reform come from many sides as well, including the environmental protection agencies and the businesses they regulate. In order to implement permits, permit-writers are trained in specific media, focusing their energies on air, water, or waste permits. They are well acquainted with their work and have standard operating procedures for performing their duties. Any perceived change to these procedures may be strenuously resisted. Businesses that must comply with these permits can also prove an obstacle to reform, as they may fear the uncertainties that come with change.
Permit programs create adversarial relationships with the regulated. The nature of the permitting process, the amount of paperwork that must be collected, and the need to obtain separate permits for each medium or process has fostered an adversarial relationship between businesses and governments. The first problem with the centralized nature of the permit system (especially in the case of federal regulations) is that the regulated and the regulators have little face-to-face contact. Little allowance is made for local conditions and/or extenuating circumstances, and businesses are forced into the preconceived mold of regulation by a distant agency. Permit writers tend to develop a skewed view of industry as well, seeing them in person only when there has been a violation. Suspicion and mistrust breed in this atmosphere.

Innovative permit approaches offer considerably greater promise than conventional permit-based approaches. Successful permit-reform programs have taken place in Massachusetts, New Jersey, and Mississippi. Each case illustrates the benefits of innovative approaches:

Massachusetts. In Massachusetts, an excessive focus on permits led to a virtual collapse of agency resources. In 1996, the agency found itself administering no less than 16,000 individual permits. Although these permits covered equipment or processes in 10,000 companies, they only accounted for 5 percent of the state's total air pollution sources. The answer in Massachusetts was a switch from command-and-control permitting to industry-wide performance standards that applied to all applicable processes at all company facilities within a given sector. Results of the pilot project were startling. While most initial requests for participation in regulatory reforms had hovered around 30 percent to 35 percent, the Massachusetts "ERP," as it was called, received an 85 percent response rate. Moreover, 80 percent of all received applications were accurate, setting another record in Massachusetts’s regulatory history. Most importantly, compliance rates shot up. Under the ERP, the overall compliance rate of participating firms rose from 33 percent in spring 1996 to 78 percent in spring 1997. Furthermore, twelve of the eighteen firms involved in the pilot project reported a positive impact on their ability to implement pollution-prevention programs, and seven of the companies reported that compliance costs under the new regime were "insignificant," which was not previously the case under permit-based regulation.
New Jersey. In New Jersey, excessive focus on permits had led to an anti-business climate that was described as "second only to California on a list of where not to manufacture chemicals in the U.S." Companies relocated to the South or out of the United States in order to escape the adverse business climate that the permit regimes had created. Manufacturing in New Jersey declined by 30 percent in the 1980s as compared to the 1970s, with the chemical industry alone losing 1,600 jobs in 1993. At its height, the New Jersey Department of Environmental Protection had more than 4,000 employees, more than three times the number of employees in the U.S. Department of Education, and more than half the number of the U.S. Department of the Treasury. The permit process involved long delays in issuing permits, spiraling costs, and uncertainty about the standards for compliance. This climate had the exact opposite effect of what was intended, as industry critics pointed out that the permit-approval process frequently delayed manufacturers from getting pollution-control equipment into service. The innovative answer in New Jersey was the adoption of facility-wide permits, a process begun in 1995. Under facility-wide permitting, the average time for permit processing dropped from 18 months to two months; 69 percent of the companies using a facility-wide permit predicted net cost savings because of the process; the average net benefit to the facilities was $6.3 million per year; and for every dollar spent in the process, there was a net savings of $5 to $8.
Mississippi. In Mississippi, the problem with a permit-based approach was twofold. First, its fragmentary nature required separate and frequently redundant paperwork to be filed according to whether emissions were air, water, or soil. These single-medium permits were difficult for industries to track and comply with, and often led to the shifting of emissions from one medium to another, in a process described as "a regulatory shell game." A typical facility, furthermore, might have to work with six or seven separate permit writers within different media divisions, and an average of four permits was required for a facility. If public notice were required for a permit, the process could last over 120 days. Tracking permits was also a problem for Mississippi's Department of Environmental Quality, which, because of budget shortfalls, had to stop regulating 3,000 smaller wastewater dischargers and had to quit regulating smaller air emissions sources. In the face of these difficulties, Mississippi's Department of Environmental Quality is in the process of re-engineering itself, with a key component being a "one-stop" permit process that would cover all media for a given facility, and assign one "Permit Manager" to work with a given facility. Though the Mississippi approach faces challenges from both the EPA and environmental advocacy groups, and the program is still being built, the flexibility and benefits of such an approach seem promising.

Rather than implementing conventional permit-based approaches, the Houston-Galveston nonattainment area should consider several of the innovative permitting approaches described above, and listed in Tables 4-6, including facility-wide permitting, and industry-wide emission standards.

B. Growth Management or Land-use Controls

One strategy proposed as a way to reduce driving, and therefore, pollution, is growth management and control over land use, though studies suggest that these measures are themselves problematic.

The main focus of such strategies involves shortening and reducing vehicle trips or making mass transit very convenient. Some methods include guidelines about reducing cul-de-sacs that do not intersect with other streets (and therefore require "in" and "out" trips rather than connections), growth restrictions, and other strategies. Chicago and Portland have been active in growth management and land-use strategies; credit guidelines are being examined in California.

However, these strategies have significant drawbacks and may not be advisable for Houston:

Growth management strategies do not provide immediate benefits. Rather, their benefits are realized 20 years out. This is not a time frame compatible with Houston’s situation. Further, the strategy significantly affects growth and development for a problem that occurs six hours a day.
Based on the progress from the last 20 years in air quality, in that same 20-year horizon, technological changes in transportation are likely to have achieved the same or additional benefits at lower cost and without the social aspects of this type of social planning.
These types of strategies seem ill suited to application in areas with different lifestyle priorities and resident characteristics that focus on decentralized living—including Texas.

Land-use strategies have functions beyond air quality—including maintaining urban cores, ensuring land-use diversity, maintaining green space, or other reasons. However, the near-term impacts in air emissions are minimal, so a case for land use strategies to achieve emission goals is weak.

Rather than implementing growth-management or land-use policies with known failings and little air-pollution-reduction power, the Houston-Galveston nonattainment area would benefit more from considering alternative strategies to promote alternative commuting. Providing and maintaining pedestrian walkways in cul-de-sac areas to allow pedestrians to easily walk through to buses and transit options (or commercial areas) on other streets is one such strategy that the Houston-Galveston nonattainment area might implement.

C. Emissions Trading or Emission Fees

Two types of large-scale economic incentives that can produce emission reductions include emissions trading and emission fees. Both use an economic mechanism (using "price" to influence behavior) to reduce stationary source emissions, and once the environmental goal is set, can help achieve that goal at a lower social cost than mandatory reductions or command-and-control measures. Emission-trading regimes go beyond simply applying a flat economic pressure, however, and actively use market forces to find the lowest-cost emissions reductions within a boundary area.

Generally, these programs have the goal of reducing emissions, with their designs reflecting targets for certain times of day and certain types of emissions. The prices or limits are effective in providing incentives to achieve faster turnover of older equipment or more rapid adoption of new technologies. Of course, these strategies require monitoring of compliance and enforcement like other environmental regulatory approaches.

Historically, emissions fees have been less frequently implemented, largely for four key reasons:

Emission fees are often viewed as taxes, particularly when revenue neutrality is not vigorously preserved;
Fees perceived as taxes are generally less politically palatable;
Emission-trading credits are more easily related to quantitative amounts of pollutants; and
Emission fee levels may be harder to set properly to achieve the desired objective.

For these reasons, our discussion will focus on emissions-trading schemes. Emissions trading works like this: within a polluted area, a "cap" is established for a given pollutant (such as NO_x or VOC), a reduction in that cap over a specified time is established, and credits are issued to existing businesses according to their emissions based on a baseline inventory. Usually, the cap is lowered periodically for facilities in the emissions-control area.

Some businesses will be able to generate emissions reductions meeting or exceeding the required reduction economically, while others, at the point of diminishing returns on emissions-control equipment, might not be able to reduce emissions enough to meet the reduction target. In order to continue operating, those businesses must buy surplus emission credits from others. The same holds for businesses that wish to expand, and for new businesses starting up.

The end result is that incentives are created for each facility to reduce emissions as far as possible. Those capable of generating surplus emissions credits can turn them into profit, while those who cannot may stay in business by buying emissions until new technology appears to let them reduce their emissions cost-effectively. The ever-increasing cost of credit acquisition in a shrinking market ensures that such facilities will not wait too long before installing new emissions-control equipment in order to end the required purchase of credits.

Emissions-trading programs have been used nationally with considerable success in the case of sulfur dioxide trading among electric utilities. In Los Angeles, a similar cap was established for VOC reductions.Emissions-trading programs might offer the Houston-Galveston region a chance at achieving emissions reductions while minimizing economic dislocation, and certainly warrant modeling and consideration for SIP inclusion as a replacement for less-effective measures.

The relative balance between NO_x and VOC problems, and their ultimate contributions to ozone development varies across the eight-county Houston-Galveston area. Further, they can vary by region, time of day, and season, complicating the forecasts of patterns of ozone creation and the development of solutions for the Houston-Galveston air quality problems. These variations must also be taken into account in designing trading schemes if equitable and effective solutions are to be developed.

Finally, trading schemes depend crucially on a regulatory component. Without clear, measurable caps and enforcement, trading schemes will not be successful. Although environmental justice considerations have reduced enthusiasm for trading in some areas, and trading strategies are not always the panacea, they provide opportunities for reducing pollution at lower social cost.

Rather than emission fees, or similar levies, policymakers in the Houston-Galveston area should first consider emission-trading programs; emission budgets, quotas, or incentives embedded in construction contracts; and emission trading for off-road equipment based on equipment type and time of day.

Emissions-trading programs have been used nationally with considerable success in the case of sulfur dioxide trading among electric utilities.

D. Transportation Demand Measures and Commuter Alternatives

As analysts have shown in numerous reports, behavioral transportation control measures (TCM), transportation demand management (TDM) programs, and commuter alternative programs have serious limitations. These programs are:

Largely Ineffective. The biggest problem with vanpool, rideshare, and park-and-ride transit programs is that few people find them a suitable alternative to individual mobility. In most households, transportation flexibility has become a critical element in maintaining quality of life, in going to work, taking children to school, shopping, socializing, and so on. Trip chaining, the linking of trips that serve personal and work needs, is also increasingly important in people's transportation choices. Consequently, programs reliant on changing people’s driving behavior produce little benefit. Employer rideshare programs in California, for example, were found to produce less than a 1 percent reduction in vehicle miles traveled, less than a 1 percent reduction in trips taken, and less than a 1 percent reduction in hydrocarbon emissions.
Poorly Targeted. Since most TCM and TDM strategies focus on commuter trips, they can only affect a relatively small percentage of the overall transportation-related emissions. Based on experience in Los Angeles, studies show that work trips to major employment sites (of 100 or more employees) only account for about 40 percent of total work-related travel. Work-related travel, in turn, only represents approximately 26 percent of all trips and 32 percent of vehicle miles traveled on an average annual basis. Thus, programs like vanpooling, park-and-ride lots, and so on can only affect about 10 percent of daily trips, and 13 percent of daily vehicle miles traveled. Full attainment of a 25 percent increase in average vehicle ridership would produce only a 2 to 3 percent reduction in trips, and perhaps a 3 to 4 percent decrease in daily vehicle miles traveled (VMT). These statistics indicate that in Los Angeles (and probably in the Houston-Galveston area), only about 7 percent of ozone precursor emissions come from vehicles used for commuting to and from work.

However, Houston’s air quality problem is severe enough that even strategies that on their face show relatively marginal impacts must be considered seriously. With strong economic incentives for changing commuting patterns, some of these strategies can be a useful part of attainment plan. Innovative alternatives to such measures center on the creation of competitive, market-based, flexible alternatives to solo driving.

Despite the general limitations of this approach, several options show promise, and are included in Tables 4-6 for consideration in the Houston-Galveston area. Particularly promising are several programs that provide strong employer incentives to encourage commuting alternatives. Because they can be applied to many levels of employers, such programs may provide good options for the Houston-Galveston area:

Federal Activity in Employer Incentives. There has been considerable activity at the federal and state levels, with several Eastern states adopting measures to encourage commuting alternatives. The Federal Transportation Equity Act for the 21^st Century encourages commuter choice, and employers can offer employees a choice of pre-tax salaries or pay the cost of transit up to $65 without tax implications as qualified benefits. Another provision allows for employers to offer cash in lieu of employer-provided parking spaces up to a maximum of $175 per month, which is viewed as additional income to the employee. These benefits can be compounded, and the parking "cash out" can apply to teleworkers.
State Activity in Employer Incentives. Maryland has inaugurated a 50 percent tax credit to employers that pay the cost for employee transit passes (up to $60/month), and these benefits can be taken in combination with the federal incentives. The benefits can be taken against income, franchise, or insurance premium taxes in the state to exempt the employer from withholding tax on these benefits, to improve the level of accountability, and to assure that the benefit and paper trail is with the employer, not the employee. Maryland is also working to expand the credit to guarantee emergency rides home, a program that evidence indicates has not been abused. California has parking cash out provisions: one in eight employees took advantage of the program, and transit ridership reportedly doubled, car- and vanpooling increased, as did other alternatives. Washington offers a $60 per year employee credit (which also applies to walking or biking). Other states are working on telework tax credits, accelerated depreciation on home office equipment, and other strategies to encourage nontraditional commuting. New Jersey has an employer trip-reduction emission-credit program through which employers submit a three-page plan outlining their trip reduction plans. This program provides emission credits, which can be bought and sold.

The biggest problem with vanpool, rideshare, and park-and-ride transit programs is that few people find them a suitable alternative to individual mobility.

A number of other alternatives to traditional SOV driving are also showing promise in other parts of the nation and internationally:

Rubber-tire Transit. Rather than focus on the expansion of costly rail systems with low carrying capacity, areas seeking to create attractive alternatives to single-occupant driving would do well to explore the potential of rubber tire transit: expanded bus services running along dedicated busways, through bus tunnels, and along rights-of-way now used by or reserved for light rail systems. Studies have repeatedly shown that such rubber tire systems can outperform rail in terms of cost, number of passengers carried, speed of travel and flexibility.
Private Shuttle Van System. Beyond expansion of public bus systems, research by Reason Public Policy Institute (Reason Public Policy Institute ) has explored the promise of a decentralized, on-demand network of private shuttle vans as a means of reducing solo driving. A network of such shuttles, operating over a highway system featuring high-occupancy vehicle (HOV) or toll lanes (HOT) would be more likely to produce an increase in average vehicle occupancy than any number of other traditional transportation control measures or mass transit systems. This system, or systems like it, are in use both in foreign countries, and have been used successfully here in the United States. Examples include the jitney system of Atlantic City, and the more limited airport shuttle services which have exploded since their introduction in the early 1980s.
Automobile Sharing Programs. Several private firms have begun to offer automobile-sharing arrangements that provide ways to maintain the convenience of driving at lower costs than owning a private vehicle. In Switzerland, Canada, and several places in the United States (San Francisco, Seattle, Portland), companies maintain a fleet of automobiles dispersed in garages in neighborhoods throughout the city. Members can reserve use of the car at reservation centers or through the Internet, and a special credit card gives them access to the garage and car. The firms advertise that the use of the automobiles provides convenience at half the cost of owning an automobile; the economics for the Swiss program demonstrated savings for drivers traveling less than 7,000 miles per year. The firms are growing quickly (the Swiss program grew 50 percent the first year and 30 percent the second year). The market has grown beyond environmental consumers because of the convenience and demonstrated cost savings. The programs are called BART station car and City Car Share in San Francisco, Flexco/Flexcar in Seattle, CarSharing Portland in Portland, Mobility CarSharing in Switzerland, and other names elsewhere.

Though too often applied poorly, employer incentives, commuter alternatives, and pricing incentives to encourage nontraditional commuting offer benefits in changing the overall economics associated with commuting. Policymakers in the Houston-Galveston area should consider employer tax incentives or credit programs for encouraging telecommuting or commuter alternatives; incentives or removal of regulatory impediments for automobile-sharing companies or cooperatives; market-based shuttle van transit systems; or limiting or shifting hours for government workers.

Employer incentives, commuter alternatives, and pricing incentives to encourage non-traditional commuting offer benefits in changing the economics associated with commuting.

E. Incentives, Pricing, and Trading Strategies

Economic strategies—pricing and incentives—can be effective in encouraging adoption of different technologies or activities more rapidly than they may have been adopted otherwise. Well-designed strategies can help reflect costs that are not commonly reflected in market prices, including environmental considerations and other externalities. These types of incentives can help adjust decision-making toward socially preferable solutions.

However, although theoretically very powerful and equitable, there are some concerns associated with implementing economic strategies. These include:

There is often a lack of political will to implement economic instruments or adopt serious measures to avert air impacts;
Sometimes the illusion of progress is given when, actually, measures are only being debated, not sincerely implemented;
Governments sometimes find ways to undermine permits and economic strategies through special exceptions;
Economics may not always represent the best overall strategy; other disciplines and priorities should also be considered in decision-making; and
Economic instruments can sometimes disadvantage the poor, and "middle class" activities may not change at all (e.g., they will continue to buy and drive higher-polluting vehicles).

However, if these difficulties can be avoided, economic strategies provide benefits at lower social cost and help preserve choice and creativity in developing solutions to problems. Economics can provide a constant pocketbook reminder about tradeoffs. In addition, economic strategies can help get past barriers and bring in pricing to try to account for or internalize negative impacts on the environment.

Effective strategies could work to affect driving patterns through:

Increasing the variable cost of driving (and reducing the fixed costs) through strategies like reformulating vehicle fees or insurance to a cost-per-mile;
Increasing the costs of driving single-occupancy vehicles or reducing the relative costs of high-occupancy vehicles;
Peak-period pricing to better reflect the total costs of driving at particular times of day or year; and
Differential fees to reflect the fact that some vehicles contribute more to the emissions problems than others—either higher polluting vehicles or those that are driven more.

Economics can provide a constant pocketbook reminder about tradeoffs.

An enhancement on these strategies would be to provide incentives through tradable credits that could apply to emission budgets or trading schemes.

One example of an economic strategy would be to institute direct emission pricing for automobiles. In such a system, annual vehicle registration fees would be based on a combination of distances driven and the emission characteristics of the vehicle. Such pricing would create incentives both to limit needless travel and for the purchase of lower-emitting vehicles. Economists have studied vehicle-emission pricing and shown it to be a promising approach to air pollution, which ties individual choice to individual consequences. Researchers at Resources for the Future found that "even under uncertainty, fees are more efficient than the command and control policy." An EPA guide for the implementation of such a program is already in print.

A report prepared for the EPA by consulting groups ICF Incorporated and Apogee Incorporated used information from numerous studies to assemble a summary of the effects of various transportation-pricing measures on travel demand and emissions. The report mentioned the following strategies and impacts:

Employee Parking Fees. Increases of $1.35 to $2.75/day in short- and long-term parking fees were effective at decreasing vehicle miles traveled (VMT) to worksites between 12 and 39 percent, and decreased single occupancy vehicles (SOV) by 66 percent to 81 percent.
Differential Parking Fees. Strategies that increased SOV parking from $1.60 to $5 per day or decreased HOV rates up to $2 per day (or provided $42 transit subsidies) were effective in achieving 19 to 31 percent reductions in vehicle trips community-wide.
Fuel Taxes. Surcharges from $0.40 to $2 per gallon led to a 1 to 7 percent decrease in VMT, trips, VOC, CO and NOx, and a 1.4 to 25.7 percent decrease in carbon dioxide.
Emissions Fees That Vary by Vehicle Efficiency. Surcharges of one cent to five cents per highway mile led to decreases of 2 to 7 percent in VMT; 2 to 12 percent in peak period vehicle hours traveled; 8 to 37 percent in daily VOC, 4 to 17 percent in daily NOx; 8 to 20 percent in daily carbon monoxide; and 3 to 7 percent in daily PM10.
Emissions Fees That Vary by Vehicle Miles Traveled. Fees of $200 to $1,200 per year per vehicle led to reductions of 1 to 7 percent in trips, 14 to 37 percent in VOC, 13 to 35 percent in carbon monoxide, and 5 to 18 percent in Nox.
At-the-pump Charges Based on Vehicle Miles Traveled. Based on estimates for west coast metropolitan areas, the ICF/Apogee study finds VMT fees of one cent to five cents per mile would lead to decreases of 9.3 to 11 percent in VMT, 8.6 percent in trips (10 percent shift to transit), 4.5 to 8.6 percent decrease in carbon monoxide, 4.1 to 9.1 percent decrease in VOCs, 5 to 8.6 percent in NOx, 9.4 percent in carbon dioxide, and 11 percent in PM10.
Pay-as-you-go Car Insurance. Changing insurance to a per mile fee between 10 cents and 40 cents per gallon led to estimates of a 32 million metric ton/year reduction in carbon emissions.
Roadway Congestion Pricing Fees. Work by the Puget Sound Regional Council estimated that congestion fees between 5 cents and 30 cents per mile, depending on the level of congestion, time of day, and other factors could lead to the following reductions: 5 to10 percent in peak period VMT, 0 to 2 percent in NOx, 0 to 7 percent in VOC, and 2 to 3 percent in PM₁₀.

Many strategies might work to provide pricing or other signals to promote less driving, use of lower-polluting vehicles, or increased fleet turnover.

Note that in some cases, relatively large surcharges were necessary to effect even minor changes in behavior—transportation choices can be fairly inelastic. However, given that Houston needs to achieve a significant amount of reduction immediately, these strategies show strong promise because they can be achieved quickly—more quickly than larger fleet transformations or widespread adoption of new technologies.

Many strategies might work to provide pricing or other signals to consumers that would alter their choices toward less driving, use of lower-polluting vehicles, or increased fleet turnover. Related strategies were also included under the section on transportation demand management strategies. Before defaulting to command-and-control measures, policymakers in Houston should seriously consider strategies such as:

Employer tax incentives or credit programs for encouraging telecommuting or commuter alternatives;
Incentives or removal of regulatory barriers for automobile sharing companies or cooperatives;
Competitive, private-sector shuttle van transit systems;
Limitations or shifts of hours for government workers;
Market-based HOV or toll lanes;
Time-of-day congestion pricing for roads;
Time-of-day or congestion parking pricing;
Emission pricing based on miles driven or emission levels of vehicles (on- and off-road);
Time-of-day pricing for use of high-emitting vehicles (off-road, construction);
Mileage-based pricing for insurance or vehicle fees;
Incentives and pricing at airports;
Credits for scrapping old automobiles;
Credits or incentives for vehicle, engine, or fleet replacement, or for adopting alternative fuels (on- and off-road); and
Credits or incentives for implementing new emission-reducing technologies or infrastructure including:

Truck-stop electrification
After-market emission-reduction technologies, or after-market retrofits for heavy duty equipment
Technologies that reduce cold-start emissions
Ozone-eating catalysts in vehicles and air conditioners
Improved gas cans (off-road)

Rather than focus on picking specific fuel formulations, policymakers in Texas non-attainment areas (including Houston-Galveston) should explore innovative ways of fostering a more rapid vehicle fleet turnover.

F. California Reformulated Gasoline and Alternate Fuels

The saga of California's experimentation with reformulated gasoline will probably become a textbook case of the absence of both a holistic vision and foresight by federal and state environmental planners. Reformulated fuels were mandated over a variety of objections, ranging from estimated high costs to predicted and claimed adverse health impacts of oxygenates. While questions of cost and health impacts are disputed, what is not disputed is the fact that the main oxygenate added to produce California reformulated gasoline (a chemical called MTBE) has created a serious controversy over its potential to cause groundwater pollution. Most importantly, oxygenates such as MTBE seem to have little effect upon urban air quality, particularly NO_x emissions. In a report by the National Science and Technology Council, MTBE was found to produce a small reduction in carbon monoxide, but reductions in VOC levels were offset by increases in the production of toxic aldehydes, and the more critical NO_x emissions were either unchanged, or actually increased with the use of oxygenated fuels.

Rather than focus on picking specific fuel formulations, policymakers in Texas nonattainment areas (including Houston-Galveston) should explore innovative ways of fostering a more rapid vehicle fleet turnover. Super-Ultra Low Emission Vehicles are within two years of the market, and moving them into the vehicle fleet quickly could have a far greater year-round impact on emissions than reformulated fuels, with less chance for unintended health or environmental consequences. Market-based incentives such as reduced vehicle registration fees and sales taxes for fuel-efficient vehicles could encourage the purchase of newer vehicles that put out fewer emissions using conventional gasoline. Several of these strategies are included in our recommendations and are detailed in the sections on economic incentives or elsewhere.

G. Bans and Limits

Although mandating changes, such as lower speed limits or limits on construction-hours, often appear to provide direct and immediate benefits at costs that seem no higher than the cost of the paper to print them, the experience from these types of strategies is less convincing.

Expensive enforcement agencies and procedures are needed;

Many would argue that the California experience in improving air quality provided clear lessons that approaches that attempt to change people's behavior rarely work;
Such measures are usually divisive and are more expensive than options that allow flexibility in achieving objectives (e.g., market-based strategies); and
They expose what should be a transparent and objective air quality protection process to accusations of social engineering.

A speed-limit reduction policy constitutes one such type of policy to effect behavioral change, which, besides being likely to spark social discord, is based on questionable assumptions about the relationship between vehicle acceleration and emissions. While the effect of reducing the speed limit might be a small NO_x reduction in certain vehicles, the overall impact of slowing the flow of traffic will keep all vehicles running longer, as more time will be needed to complete a trip. It is not clear that current models of emissions are a function of speed, and the overall impact of speed reductions on the total vehicle fleet of both light and heavy-duty vehicles do not adequately capture the complexity of the speed/emissions tradeoff. Such uncertainty constrains sound policymaking, in that it invites unintended adverse consequences, inefficiently utilizes resources, and endangers the public's willingness to accept more reasonable emission-control policies. Moreover, lower speed limits on freeways in the Houston-Galveston area will be very difficult to patrol due to the high volume of traffic. Law enforcement agencies are unlikely to obtain the additional budget funding necessary to this end. Further, the public may be unwilling to allow resources to be transferred from efforts to control serious crime to highway patrol.

Bans on the use of heavy-duty construction/mining diesel equipment during the morning hours represent another behavioral constraint that is likely to trigger significant social discord and quality-of-life impacts through increased costs of construction. Not only can market options provide better, cheaper, and more effective alternatives to the ban; this particular type of ban can lead to other problems, including increases in highway construction costs, traffic congestion, traffic accidents and fatalities, mobile source air pollution, and nighttime noise. In addition, there are questions regarding the models of the air emissions and health gains associated with the strategy, concrete integrity might be affected, and other quality of life and economic impacts would result—making such a ban is questionable on several bases.

Policymakers in Houston might consider several basic strategies of this type where they are not already in place. These include traffic signal synchronization and similar strategies to reduce idling and congestion-related emissions, with signals timed to guide traffic at preferred speeds, and traffic diversion options. During specific periods, the city may need to divert high-emitting diesel vehicles to routes around the city rather than through it.

H. Enhanced Inspection and Maintenance

Inspection and maintenance (I/M) programs embody the idea that some mechanism must be put into place to ensure that light-duty vehicles are kept in non-polluting condition. This basic idea is reasonable. Air pollution from vehicles degrades air quality and may impose potential harm upon other individuals who must breathe polluted air. Therefore, motorists have an obligation not to impose this harm on others. However, the specific mechanisms embodied by traditional I/M program requirements have produced dubious benefits, sometimes at high cost.

Agency claims of high I/M program effectiveness are common. The EPA claims enhanced I/M programs can yield a 28 percent overall emission reduction. California agencies, long considered to be on the "cutting edge" of air pollution control methods, put forward similar claims. The California Air Resources Board has claimed that Smog Check programs in California led to a 25 percent overall reduction in automobile emissions statewide since the late 1980s. The California South Coast Air Quality Management District (SCAQMD) has a more specific breakdown, predicting that enhanced I/M programs will result in a 28 percent reduction in VOCs, a 31 percent reduction in carbon monoxide (CO), and a 9 percent reduction in NOx. Finally, prior to implementation of enhanced I/M in Arizona, the EPA predicted reductions of 35 percent for VOCs and a 7 percent reduction in NOx.

However, benefits from enhanced I/M programs appear to fall far short of earlier predictions. While some studies suggest that enhanced I/M does result in some emission reductions, reductions are as much as 50 percent lower than predicted achievements.

A recent study, examining the effectiveness of California’s enhanced vehicle inspection and maintenance program used data from vehicles which were tested at their regularly scheduled time, and then again before transfer of ownership found that actual emission reductions were only 5 percent for HC and NOx, and 20 percent for CO, up to two months after the regularly scheduled test.

In terms of absolute performance, I/M program effectiveness has been studied by researchers at Resources for the Future (RFF) for the Arizona area. While EPA predicted a 35 percent reduction in VOC, the RFF researchers documented only a 13 percent reduction. EPA predictions were considerably closer to reality for NOx reductions. Where EPA predicted a 7 percent reduction in NOx, the RFF researchers documented an 8 percent reduction.

The low effectiveness of traditional I/M programs has been attributed to several technical phenomena, including inconsistent behavior of vehicle emission-control systems and post-test deterioration of emission control systems or system repairs. Others argue, however, that the biggest obstacles to success of all I/M programs are behavioral, resulting from the misguided incentives inherent in a system that revolves around the necessity of passing an annual (or biennial) test. Such programs generate incentives to "pass the test," but they do not create behavioral incentives for motorists to maintain clean vehicles year-round. As Charles Lave, an economist at the University of California, Irvine, puts it: "Such periodic testing is akin to a program that tries to "control" drunken driving by scheduling drivers for a breathalyzer test every two years." Traditional I/M programs also create incentives for fraudulent actions on the part of emission-test facility personnel, and for tampering.

As Charles Lave, an economist at the University of California, Irvine, puts it: "Such periodic testing is akin to a program that tries to "control" drunken driving by scheduling drivers for a breathalyzer test every two years."

An optimal system for cleaning up on-road vehicles is one that pays attention to incentives for motorists to keep their cars clean. Traditional I/M programs fail to do this, as do conventional enhanced I/M of the sort proposed for the Houston-Galveston area. A better program would focus on identifying and remediating high-polluting vehicles, as well as motivating motorists to invest in enduring repairs.

The Houston-Galveston SIP takes a strong step forward with its proposed implementation of remote sensing and on-board diagnostics to detect high-emitting vehicles. However, an adjunct program that would further refine the focus of inspection and maintenance on the small number of high emitters should be considered. Beyond the identification of high-emitting automobiles, several techniques can be used to identify clean cars, which can subsequently be exempted from annual inspection, thus reducing the load on the planned dynamometer test centers, and saving motorists time and money. Cars less than 6 years old have very low failure rates, and can be exempted from annual testing without fear of missing significant emitters. Remote sensors can also be used to identify clean cars older than 6 years old, and those cars can also be exempted from annual testing. The feasibility of using remote sensors to erect such a "clean-screen" program has been demonstrated in pilot projects in Ontario, Canada; Greeley, Colorado; and Phoenix, Arizona.

Focusing only on identifying the high-polluting vehicles would allow more attention to be paid to actually repairing these cars. Classification as an extreme emitter should be based on the relative contribution to the pollution problem, not through reference to a vehicle's variance from its ideal lowest-emission state. There is, of course, no "bright line" that determines what vehicles should qualify as extreme emitters. In part, setting the extreme-emitter cut-off point would depend upon how much emission reduction one was attempting to achieve and which universe of vehicles was likely to actually be repairable. Also, such cut-offs might be revised over time as vehicles become cleaner and cleaner, should continued mobile-source emission-reductions be necessary.

Policymakers should consider several alternatives to traditionally implemented enhanced inspection and maintenance for Houston. These alternatives include clean-screening and high-emitter detection with remote sensing; emission check buy-out; and an air quality improvement program, allowing polluters to pay into a fund used to reduce pollution elsewhere.

Part 3

Suggested Ozone-Reduction Strategies for Houston

Stationary Sources: Table 4 lists and outlines market-oriented stationary source measures which can help the Houston-Galveston area achieve emission reductions effectively and efficiently while avoiding approaches that tend to be punitive, inflexible, and inefficient, such as specific equipment permitting and specific technology mandates.

Mobile Sources: Tables 5 and 6 list and outline the market-oriented and innovative measures that can help the Houston-Galveston area achieve emission reductions efficiently and effectively while avoiding conventional mobile source approaches that have many well-known limitations, such as mass transit, centralized vehicle inspection and maintenance, mandatory employer rideshare programs, mandated fuel substitutions or reformulation, vehicle technology standards, etc. Instead, Houston should promote more innovative approaches, designed to speed fleet turnover and adoption of new technologies or lower-polluting operations, encourage alternatives, and improve efficiencies of regulations. These are outlined below. Table 5 addresses strategies for on-road sources; Table 6 summarizes strategies for off-road emissions.

Table 4: Suggested Strategies to Consider for Stationary Sources
Strategy	Description	Experience
Facility-wide permitting	In facility-wide permitting, the regulatory focus is on the total emissions of a facility, rather than individual pieces of equipment. The New Jersey Department of Environmental Protection introduced facility-wide permitting in 1995, producing environmental benefits while giving facilities the flexibility they need to comply with environmental regulations and provide environmental protection while remaining competitive.	New Jersey
Industry-wide emission standards	Industry-wide emission standards apply the facility-wide permitting model to entire industries. Rather than setting emission caps individually for each facility, industry-wide emission standards replace equipment permitting for an entire industry. Industry-wide emission standards have been successfully demonstrated in Massachusetts, where the Environmental Results Program showed that industry-wide permitting could produce greater compliance and greater environmental benefits than the traditional approach to piecemeal permitting.	Massachu-setts
Emission-trading programs	In emission-trading programs such as the national SO₂ trading program, or the RECLAIM VOC (volatile organic compound) trading program, an emission cap is established over an area, emission rights are established, and a system is designed to allow trading in those emission rights between firms within the capped area. California’s Bay Area Air Quality Management District has also implemented an emission pricing regime, allowing trading in Bay Area Emission Reduction Credits. One relatively untapped option would allow trades between mobile and stationary sources, for example, through automobile repair-assistance or scrappage trading programs.	California Air Quality Manage-ment District San Francisco
Self-audit and cleanup incentives	Another approach to attaining better environmental performance is to encourage firms to voluntarily adopt environmental management and information programs, such as the ISO 9000 standards, the CERES principles, the GEMI principles, and others. Such an approach has been adopted in Oregon, with the Green Permits/Environmental Management Systems Incentives Project (EMSIP). One other example is the CMA Responsible Care initiative.	Oregon
Incentives for retrofit of gener-ators for peak power units	There have been demonstration projects that show potential to reduce NOx emissions for diesel applications including generators. This includes SCR (selective catalytic reduction) strategies for peak power generators, and are available for new and retrofit models.
Broad-based energy and resource- efficiency programs	In Toronto, they have adopted a Greenhouse Gas (GHG) Pilot Trade program that provides credits for an array of energy and resource conserving activities that help reduce energy use and thus power production and emissions. Credits are provided for efficient street lighting, landfill gas recovery, waste reduction and recycling, water conservation, carbon sequestration (tree planting), community greening, building code amendments, bicycle infrastructure, land use for energy efficiency, alternate cooling technologies, and transportation demand management strategies.	Toronto, Ontario, Canada
Connected street system or pedestrian pass-throughs	Portland has street design guidelines that require streets to intersect within particular distances and restricts cul-de-sacs (which waste gas by requiring drivers to backtrack out the streets to progress). Where cul-de-sacs and similar developments exist, pedestrian walkways or pass-throughs are encouraged to assure pedestrians can use short cuts to get to mass transit or shopping areas. Oregon has other sprawl strategies; options and credit programs are being implemented or studied in Chicago and California	Portland, OR

5: Suggested Strategies to Consider for Mobile On-Road Sources
On-Road Strategies that Speed Fleet Turnover
Strategy	Description	Experience
Credits for scrapping old automobiles	In California, credits have been made available for removing old automobiles from operation—automobiles that have a disproportionately negative impact on air quality. These schemes have been successful in removing high-polluting vehicles from service (although there have been some glitches in the system), and the credits have been used to offset more expensive emission retrofits for industry in the state. Overall, this has helped reduce emissions at a lower social cost.	California
Expanded or enhanced credits for purchase / replacement of vehicles / engines	A credit system, similar to those established for scrapping high-polluting automobiles, could be established for replacing high emitting automobile or diesel engines with lower polluting engines (e.g., alternative fuels, diesel hybrid engines, etc.) could be established. The credits would be performance-based in their values (rather than technology based), could allow for alternative fuels (where appropriate). The credits could be banked, applied against other retrofit opportunities, or traded/sold. These could be established for the range of polluting engines found in the H-G area, including automobiles and trucks, as well as off-road sources like marine and recreational vehicles. This credit should apply to purchase / upgrade of automobiles, construction equipment, diesel vehicles, marine equipment, and other engines.	California
Credits for replacement / retrofit of fleets and airport vehicles	Credits for replacement and upgrading of fleet vehicles—particularly government fleets, which can represent a significant share of vehicles—can help achieve the goals for the Houston-Galveston area. This may be achieved through replacement with more efficient engines, or use of alternative fuels. Proxies for current fleet levels may be established based on fuel consumed or other indicators and fleet age to reduce the administrative burden. Incentives should be provided for automobile, truck, and other fleets (garbage trucks, etc.). Upgrades and alternative fuels at airports (in transit vehicles, airline fleets, etc.) can be very effective in reducing pollutants at an already stressed environment. Again, the credits would be performance-based in their values (rather than technology based), and could be banked, applied against other retrofit opportunities, or traded/sold. Note that the South Coast Air Quality Management District in California is considering acting on their legal authority to potentially regulate all publicly owned fleets and require alternative fuels or low emission fleets to reduce emissions. This includes diesel, airport, and other fleets.	California, Massachu-setts
On-Road Strategies that Speed Adoption of New Technologies
Legalization of after-market emission reduction technologies	EPA-favored inspection and maintenance programs focus on returning the tested vehicles to the exact operating condition that they had when they were new, right down to requiring original equipment. After-market emission-reduction devices exist that allow cars and off-road diesel equipment to perform better than when they were new. Inspection and Maintenance protocols should focus on getting the best performance out of each car, not simply the performance it had when new.
Credits for truck stop electrification	The South Coast Air Quality Management District in California has rules that allow credits for truck stop electrification. Trucks would be retrofitted with on-board equipment to allow the truck to plug into an electrical outlet rather than idling the diesel engine. Credits could be offered to the trucks and potentially to the truck stop operators. These credits could go to the trucks or fleets, or potentially to third parties that need credits and are willing to pay for the retrofits. The credits could be banked, traded, sold, etc. Some monitoring would be required to assure that the drivers use this option. This technology is on the shelf, but has not been implemented widespread, nor has anyone applied for the credits in California, to date.		California
Incentives for ozone-eating catalyst for air conditioners and automobiles	A catalyst that converts ozone (O₃) to oxygen (O₂) upon contact provides advantages by reducing ozone in the environment. This technology has been applied to automobile radiators and to air conditioners. The technology is purported by the manufacturer to convert 75 percent of the ozone that flows across the automobile radiator, and 80 percent of the air passing across the air conditioner condensers. The technology works at room temperature, but efficiencies increase at equipment operating temperatures. Volvo automobile company has installed the equipment in about 230,000 vehicles to date, and other auto companies are considering the technology. Estimates of the cost per ton of emissions (NOx or VOC) vary depending on source. In December 1999, this technology became eligible for federal Tier II automobile OEM credits; California Air Resources Board (CARB) was the first to adopt credits in November 1998. The manufacturer (Englehard Corporation) is examining credits for stationary sources in Texas and federally.		Federal, California
Incentives for retrofits for revised fuels or technologies to improve diesel operations	Incentives could be developed to encourage adoption of new or retrofit technologies that reduce emissions in on- and off-road vehicles. There have been demonstration projects that show potential to reduce NO_x emissions for diesel and large-emitting vehicles, including construction applications. This includes SCR (selective catalytic reduction) strategies for generators for construction units (and peak power units), and in some trucks. The truck models perform best in new equipment rather than retrofit, although the generators can be successfully retrofitted. Emulsified diesel fuel also shows promise, including marine applications. Increasing the cetane level in the diesel fuel (e.g. through additives) –shortens the time between compression and ignition and improves cold start emissions. Some municipalities are specifying 5 percent improvements in NO_x and 1 cent per gallon cost increases to get PM10 reductions.
On-Road Strategies that Modify Operations or Equipment or Behaviors
Market-based HOV or toll lanes, or time-of-day congestion pricing on roads	Time-of-day pricing on roads has been implemented elsewhere to help reduce emissions during crucial hours. Examples include the SR91 "Hot Lane" in Orange County, California. The preferred design would be revenue neutral. Such approaches would also facilitate the evolution of private transit alternatives, such as extensive networks of Shuttle Vans.		California
Direct emission pricing based on emission levels and miles driven	The most efficient way to target on-road emissions would be to price them directly, through a system of emission charges levied based upon the emission characteristics of the car, and the miles it is driven. Such systems have been studied extensively, as in the Los Angeles REACH task force and the California Air Resources Board statewide working group on market-based measures. The hurdles to implementing direct emission pricing of automobiles are more political than technological.		Los Angeles, California
Mileage-based insurance pricing and vehicle fees	Automobile insurance pricing might be modified to increase the component assigned based on the miles driven. This has the effect of increasing the variable cost and decreasing the fixed cost of driving. One insurance company in Houston has been reported to be considering or testing this option. It may, however, be expected to have only a limited effect, considering that recent significant increases in gasoline prices have had virtually undetectable impacts on driving. However, the concept may have merit when combined with other "fixed costs" including potentially annual vehicle taxes, etc.		Houston
Traffic control measures to reduce congestion-related emissions	Such measures might include traffic signal synchronization, additional tolled road construction, incentives to promote telecommuting and flexible work-hours, and could include time-of-day congestion pricing in certain circumstances.		Portland, other
Incentives or credits for modifying diesel vehicle operation	Incentives could be provided that would help manage truck diesel emissions by managing diesel speed, and the path vehicles take through Houston. For example, trucks might need to be diverted on an episodic basis to alternate roads that run "around" Houston, rather than through it. Firms or fleets that agree to permanent rerouting might be another target, but abuse might be a consideration.
Incentives to Encourage Alternatives in Commuting
Market-based shuttle van transit systems	Mass transit programs are promoted as a method of reducing vehicle use and vehicle emissions by providing alternatives to solo driving. But traditional mass transit programs are largely ineffective at cleaning the air, and may actually make the problem worse by increasing traffic congestion. Reason Public Policy Institute has developed an alternative transit plan, which uses privately owned and operated shuttle vans running over a highway system with either High Occupancy Vehicle lanes, or High Occupancy / Toll lanes. Shuttle transit has been shown to be competitive with mass transit in some foreign countries. In the United States, consumers have experience with van shuttle transit in the form of hotel shuttles, airport shuttles, tourist shuttles, and employment-related vanpooling.		U.S. and international
Limiting or shifting hours for government workers	Limiting or shifting hours for some kinds of workers can cause difficulties in terms of safety and cost. However, shifting and limiting hours for most types of government workers may be more effective than other sectors, and may have far fewer secondary impacts. These workers may be shifted from 12 noon to 8 pm shifts or may be provided incentives to do so; additionally, incentives for teleworking (including easier home office tax considerations, etc.) may assist the Houston area in meeting attainment levels.
Employer tax incentives or credit programs for encouraging telecommuting or commuter alternatives	Government can offer tax incentives for employers to modify benefits packages for employees to encourage transportation alternatives—including car/vanpooling, walking, biking, mass transit, etc. The federal "Commuter Choice" program (National Transportation Equity Act for the 21^st Century) provides pre-tax benefits for paying up to $65 of transit, or cash outs of up to $175/mo for parking spaces. This is currently in use, and some states have enhanced these benefits, including Maryland, California, Washington, and others. Options for rides home for emergencies must be available, and evidence indicates there is not abuse of the system. These incentives for telecommuting can either stand alone and be offered by Texas government, or be offered by companies and used as partial offsets in an emission trading regime. New Jersey has an employer trip reduction emission credit program, and employers submit three page plans outlining the trip reduction plan and get emissions credits that may be bought and sold.		Maryland, California, Washington, Federal, elsewhere
Time-of-day / congestion parking pricing	Parking pricing can be set much higher during periods during which driving is to be discouraged in order to encourage use of mass transit, off-peak time driving, or use of multiple occupancy vehicles. In addition, parking prices can be set much higher for SOVs and much lower for HOVs. Employer parking buy-out strategies are addressed elsewhere.
Incentives for establishing automobile sharing companies or cooperatives	In several locations in the US, Canada, Switzerland, and other locations in Europe, a private company maintains a fleet of automobiles dispersed in garages in neighborhoods throughout the cities. Members/users can make a reservation for a car at reservation centers or through the Internet. They have a special credit card, and the card then provides them access to the site, the garage, and even the ignition of the car. They can drop the car off at any site when they are done. The US firms suggest savings of half the cost of standard automobile ownership; the Swiss example states the economics demonstrate savings for drivers that drive less than 7,000 miles per year. In Switzerland, the business grew 50 percent the first year and 30 percent the year after. Initially, they assumed their market would be the environmental community, but they have found that the cost-effectiveness has spread users to the population at large. Their new marketing campaigns are planned as mass market, not niche environmentalists. http://www.flexcar.com		Seattle/ King County, Washington, Portland, San Francisco, Vancouver BC, Switzerland, Paris, other.
Improve efficiencies of regulation
Clean screening and high-emitter detection with remote sensing	A minority of cars on the road produces the majority of mobile-source pollutants given off by the entire vehicle fleet. Rather than subject a mostly-clean vehicle fleet to scheduled emission testing with costly, stationary dynamometer equipment, we suggest programs that use lower-cost mobile emission detectors to allow repair efforts to focus on the high emitters, the core of the automobile emissions problem. Clean screening uses both roadside sensors and an understanding of new-car emission characteristics to exempt the bulk of the on-road vehicle fleet from the need for inconvenient, and sometimes costly annual emission testing. Cars less than four years old are unlikely to be high emitters. Studies suggest they are less than 1 percent of the high emitters on the road. Exempting cars newer than four years old removes a large percentage of the vehicle fleet from the test regime, allowing the concentration of effort on the remaining, more-likely high emitters. Using remote sensors to detect which of the cars older than 4 years is clean can also be done with high accuracy, allowing yet more focus on the remaining high-emitters. Finally, roadside sensing of high emissions allows the car to be repaired immediately. An annual test does nothing to repair cars that break a month after their last annual test. Those cars can emit at high levels for another 11 months, even 2 years, before being repaired.
Emission check buy-out	In California, as an example, owners may pay a fee to avoid smog checks for the first five years of owning a new car. This can be an appropriate strategy because the minority of pollution is emitted from new automobiles, and the problem is disproportionately one generated from older vehicles. By paying a fee to bypass the checks (e.g. $4/vehicle in some areas), the fee can be used to lower fees for other vehicles, or other appropriate uses may be made with the funds (contributions to a "smog fee/fund"). This strategy assures that similar emissions will be realized, but at lower cost in terms of administration, time waiting, inconvenience, and inappropriate retrofits to new automobiles.		California
Air quality improvement program	Some agencies have implemented schemes that allow polluters to pay money to avoid meeting their emission requirements, and the funds are used to help reduce pollution through other strategies. This is, in essence, government moderated trading. This strategy can be effective, but direct trading is preferable, without government middlemen. This program has been implemented in South Coast Air Quality Management District in California, and the funds are redistributed through an RFP process to try to fund a variety of innovative strategies that lead to emission reductions.		California

Table 6: Suggested Strategies for Mobile Off-Road
Strategy	Description	Examples
Direct emission pricing based on emission levels and duration of use for registered high-emitting equipment	Though this approach has not been implemented or modeled in depth, there is no theoretical obstacle to the application of emission-pricing approaches to major off-road mobile sources such as generators, cement mixers, tractors, bulldozers, etc. It is likely to be politically preferable to mandated fuel type—for example, requiring all such vehicles to use natural gas, ethanol, or other fuels.
Time-of-day pricing for use of high-emitting equipment	Though this approach has not been implemented or modeled in depth, there is no theoretical obstacle to the application of time-of-day pricing approaches to major off-road mobile sources such as generators, cement mixers, tractors, bulldozers, etc. Under time-of-day pricing, equipment that emits high levels of criteria pollutants could be used freely during times when emissions were not likely to lead to air quality violations, but priced to influence reduced use during periods of air pollutant formation or concentration.
Emission trading for off-road emission based on equipment type and time of day	Though this approach has not been implemented, there is no theoretical obstacle to the application of emission-trading approaches to off-road mobile sources. Under an emission-trading system, a cap would be established on the total use-time of high-emitting, off-road equipment, and permits would be initially allocated to firms according to existing commitments. Permit depreciation would ensure an overall decrease in emissions from such equipment from year to year, while allowing firms to trade such permits would ensure that emission reductions were made in the most economically efficient manner.
Emission budgets, quotas, or incentives for reduced emissions in association with construction contracts	In this option, construction contracts would each have assigned an emission quota or budget that the contractor can meet using tradeoffs they determine to be most cost-effective or efficient. Firms may choose to meet the quota by limiting or shifting construction hours, shifting seasons for construction, by retrofitting heavy vehicles or purchasing lower emitting equipment, or other measures. Another enhancement on this option would be to institute a certification program for construction firms that have fleets that exceed desirable ratios of good to poor emission vehicles. There could also be incentives or credits for using "Good Construction Partners" on projects. We are not currently aware of either of these options in operation anywhere, but few areas are in the same situation as Houston-Galveston.
Incentives and pricing at airports	Boston’s Logan airport has taken a phase approach, implementing voluntary measures and incentives to encourage adoption of alternative fuels for the variety of vehicles and fleets at the airport. This has taken the form of 25 percent discounts on ground-access fees, and considerations of discounted rents and other rates and charges. This, coupled with the recent increases in diesel/gasoline prices has led to significant changes in the proportion of natural gas vehicles in fleets like ground support, de-icing, fueling, etc. In addition, they modified the taxi queuing area to eliminate idling. Instead of vehicles inching up to their place in line, they modified the space to allow parallel parking lines that are released one line at a time (like ferry lines), allowing vehicles to be turned off during the wait. If the problem is big enough, Houston-Galveston regulators can work with other agencies with regulatory responsibilities to amend any considerations that limit approaches.	Boston
Incentives / discounts / distribution programs for improved gas cans	Gas cans for fueling garden equipment, snowmobiles, chain saws, and other uses contribute to air pollution through spills, open-cap evaporation, and evaporation through the can. It has been estimated that each can may contribute 5 pounds of VOC per year and other emissions. Nozzles with advanced designs eliminate this source. Several areas (including California Air Resources Board, Louisiana, Connecticut) have gotten involved in offering SIP credits or have in place programs that encourage their use, ban purchase of old-style cans, provide trade-in benefits or credits, etc. Estimates are that it is a relatively cheap source of pollution reduction, costing on the order of $1,000 per ton of reductions. CARB calculated very large reductions from this source.	California, Louisiana, Connecticut
Incentives for after-market retrofit for heavy duty equipment	Incentives could be developed to encourage adoption of new or retrofit technologies that reduce emissions in on- and off-road vehicles. There have been demonstration projects that show potential to reduce NO_x emissions for diesel and large-emitting vehicles, including construction applications. This includes SCR (selective catalytic reduction) strategies for generators for construction units (and peak power units), and in some trucks. The truck models perform best in new equipment rather than retrofit, although the generators can be successfully retrofitted. Emulsified diesel fuel also shows promise, including marine applications. Increasing the cetane level in the diesel fuel (e.g. through additives) –shortens the time between compression and ignition and improves cold start emissions. Some municipalities are specifying 5 percent improvements in NO_x and 1 cent per gallon cost increases to get PM10 reductions.

Part 4

Summary

As mentioned, Houston-Galveston has significant problems in NOx. In determining the best package of methods to address these nonattainment problems, the government should enforce the outcome of cleaner air rather than implement draconian regulatory controls such as the construction ban, burdensome inspection/maintenance programs, reformulated fuels, or other strategies. Rather than implement such traditional permit-based approaches to stationary source control, an approach that is fraught with difficulties, innovative approaches such as facility-wide permits, industry-wide permits, and emissions trading should be modeled and included in the Houston-Galveston SIP, replacing less effective measures. Such alternative permitting strategies have produced great success in several states, including New Jersey, Massachusetts, and Mississippi.

Given their history of failure and resource wastefulness, mandatory behavioral controls such as mandatory reductions in the speed limit and mandatory restraints on the allowable times for use of construction equipment should be avoided. Both of these proposals, further, are based on a limited understanding of the nature of the emissions to be reduced, and the probability of successful reduction. Such uncertainty makes environmental policy unreliable, risks negative unintended consequences, and diverts limited resources.

Rather than proceed with the elements of the Houston-Galveston SIP that have well-established limitations and negative social and economic impacts, TNRCC should, at the very least, model the potential effectiveness of the innovative approaches discussed here, as well as other innovative approaches that have been studied elsewhere, but that are beyond the scope of this study.

Rather than implement traditional permit-based approaches to stationary source control, innovative approaches such as facility-wide permits, industry-wide permits, and emissions trading should be modeled and included in the Houston-Galveston SIP, replacing less effective measures.

Rather than implement traditional mobile source controls of limited effectiveness and high cost (such as enhanced I/M, reformulated fuels, vanpool, transit, and other similar measures), innovative approaches such as shuttle van transit and vehicle emission pricing should be modeled and included in the Houston-Galveston SIP, replacing less effective measures.

Given their history of failure and resource wastefulness, mandatory behavioral controls, limits, or bans should be avoided as they tend to be more disruptive, inhibit creative solutions, and lead to higher social cost than economic or market strategies.

Preferable strategies are "market-based" and allow for flexibility and innovation in their application.

Vehicle Emissions Pricing uses economic concepts by basing vehicle registration fees on the level of emissions from the vehicle and annual distances driven. Other proxies include strategies to redesign fixed-cost fees associated with vehicle ownership and operation into mileage-based fees, providing disincentives to driving more vs. less.

Emissions Trading reduces emissions from stationary sources, usually within a single industry and pertaining to a specific pollutant, by setting an overall "cap" for an entire area and allowing sources to trade emission credits based upon the costs and benefits as determined by each source. These strategies help by limiting pollution and providing incentives to adopt cleaner technologies on an accelerated schedule.

Industry-wide and facility-wide Permitting would establish similar limits and performance standards for specific industries or companies, thereby allowing them to meet the limits in cost-effective ways or buy and sell, rather than just trade, emission credits. Such alternative strategies as above have produced great success in several states, including New Jersey, Massachusetts, and Mississippi.

Specific incentives for adopting new technologies can help move forward the ultimate adoption of new technologies, replace or retrofit high-polluting fleets, and provide incentives for improved operation of vehicles. As another example, incorporating emission budgets or rewards/preferences into a wide variety of construction contracts can also provide incentives for advancing vehicle turnover or retrofit with newer technologies, reducing emissions. A wide range of mechanisms is available and many have shown promise in other locations.

Employer incentives to encourage employees to use alternatives to commuting, including parking cash-outs, tax incentives, and creative tradeoffs in benefits packages show strong promise in other locations, and provide incentives in the private sector and at needed times of day. This shows particular promise because it addresses workers at both large and smaller agencies and companies, helping provide widespread assistance in reducing emissions and provides benefits at sensitive times of day. Incentives can also be provided that encourage the viability of private automobile-sharing cooperatives that help make it practical to avoid automobile ownership for many.

Incentives or pricing to change commuting patterns, including market-based HOV lanes or toll lanes, and time of day road (and parking) pricing can also be very effective in reducing emissions.

More efficient and discerning methods for inspection and maintenance procedures can maintain improved emission levels at lower costs. Using new technology to find noncomplying vehicles on the road, and focusing inspection efforts on that segment of vehicles expected to have higher emissions (older vehicles), or allowing emission check buy-outs for newer vehicles can provide greatest benefit at lower administrative cost and lower inconvenience to (relative) nonpolluters.

Market and incentive strategies can lead H-G to attainment in a more efficient, equitable, and cost-effective manner. These strategies should be considered for addition, substitution, or inclusion in the list of strategies for Houston-Galveston. Market strategies tend to be self-enforcing and can increase compliance and help reduce the need for enforcement. Most importantly, market strategies allow flexibility and tend reduce the overall (personal and societal) costs of achieving attainment goals.

About the Authors

Dr. Kenneth Green directs the Environmental Program at the Reason Public Policy Institute, a nonprofit, nonpartisan public policy research organization based in Los Angeles. Dr. Green has published several studies on urban air pollution policy, including Rethinking EPA's Proposed Ozone and Particulate Standards, Checking Up on Smog Check, Looking Beyond ECO and Defending Automobility, a Critical Examination of the Environmental, Social Costs of Auto Use.

Dr. Lisa A. Skumatz is an economist and Principal of the research and consulting firm Skumatz Economic Research Associates, Inc. (SERA), 1511 Third Avenue, Suite 1000, Seattle, Washington, 98101, Phone: 206/624-8508. Dr. Skumatz has conducted extensive research on market-based and other incentives in solid waste, and specializes in program evaluation and cost-effectiveness analysis for recycling/solid/hazardous waste, energy conservation, and water conservation programs. Among other assignments, she was an invited participant in the Yale Center for Environmental Law and Policy’s "Environmental Reform: The Next Generation Project," which focused on market-based incentives in environmental policy. She has written several policy papers for Reason Public Policy Institute on solid waste and rate issues.

Related Reason Public Policy Institute Studies

Kenneth Green, D.Env., Rethinking EPA’s Proposed Ozone and Particulate Standards, Policy Study No. 224 (Los Angeles: Reason Public Policy Institute, June 1997).

Ralph Keeney and Kenneth Green, D.Env., Estimating Fatalities Induced by Economic Impacts of EPA’s Ozone and Particulate Standards, Policy Study No. 225 (Los Angeles: Reason Public Policy Institute, June 1997).

Anne E. Smith et al., Costs, Economic Impacts, and Benefits of EPA’s Ozone and Particulate Standards, Policy Study No. 226 (Los Angeles: Reason Public Policy Institute, June 1997).

Kenneth Green, D.Env., Innovative Approaches for Meeting the Georgia Ozone Challenge (Atlanta: Georgia Public Policy Foundation, February 1999).

Endnotes

Per the Clean Air Act Amendments (CAAA), for exceeding the National Ambient Air Quality Standard (NAAQS).
Texas Natural Resource Conservation Commission (TNRCC), Air Quality in Houston-Galveston-Brazoria, GI-185B, companion document, 5/98.
Christopher A. Hartwell, Simplify Simplify: Alternative Permitting at the State Level, Policy Study No. 253 (Los Angeles: Reason Public Policy Institute, February 1999).
Ibid. p. 3
Barry Rabe, "Facilitywide Permits and Environmental Regulatory Integration: Lessons from New Jersey," National Environmental Enforcement Journal, (April 1997).
Hartwell, Simplify, Simplify.
Nita McCann, "Pollution control wants $1 million to maintain progress," Mississippi Business Journal, April 4, 1996, p. 9.
For a good discussion of the pros and cons of emission trading programs see Robert W. Hahn, "A Primer on Environmental Policy Design," in Fundamentals of Pure and Applied Economics (New York: Harwood Academic Publishers, 1989); T.H. Tietenberg, Emission Trading (Washington, DC: Johns Hopkins University Press, 1995); and Robert N. Stavins, Transaction Costs and Markets for Pollution Control (Washington, DC: Resources for the Future, Inc, Spring 1995).
This may make feasible some of the trading schemes of weighted emission trading of ratios of VOC and NO_x proposed in work by Gary Dorris, Stratus Consulting in Boulder, Colorado, as discussed in an interview by Lisa A. Skumatz, March 13, 2000.
Not to be confused with technological transportation demand management initiatives such as traffic-signal synchronization, which have proven to be highly effective and cost-efficient.
For an overview, see Kenneth Green, Looking Beyond ECO, Alternatives to Employer-Based Trip Reduction, Policy Study 185 (Los Angeles: Reason Foundation, March 1995).
Alan E. Pisarski, Commuting in America II: The Second National Report on Commuting Patterns and Trends (Washington, DC: Eno Transportation Foundation, Inc, 1996).
Costs and Effectiveness of Transportation Control Measures (TCMs): A Review and Analysis of the Literature, National Association of Regional Councils (NARC), January 1994.
Kenneth C. Orski, "Evaluation of Employee Trip Reduction Programs Based on California's Experience with Rule 1501, An Informal Report of the Institute of Transportation Engineers," Resource Papers for the 1994 ITE International Conference, January 1994.
Ibid.
Kenneth Green, Looking Beyond ECO, Alternatives to Employer-Based Trip Reduction, Policy Study 185 (Los Angeles: Reason Foundation, March 1995).
This summary of federal and state activity in commuter choice is summarized from very helpful discussions with Scot Spencer, Environmental Defense, interview with Lisa A. Skumatz, March 16, 2000.
Thomas A. Rubin and James E. Moore II, Better Transportation Alternatives for Los Angeles, Policy Study No. 232 (Los Angeles: Reason Public Policy Institute, September 1997); Thomas A. Rubin and James E. Moore II, Rubber Tire Transit: A Viable Alternative to Rail, Policy Study No. 230 (Los Angeles: Reason Public Policy Institute, August 1997).
Robert W. Poole Jr., Shuttle Vans: The Overlooked Alternative, Policy Study No. 176 (Los Angeles: Reason Public Policy Institute, April 1994).
Michael Doherty, "Concerns about Market Instruments," Selling Clean Air Workshop Proceedings (British Columbia, Canada: Public Interest Advocacy Center, October 15-16, 1998).
Winston Harrington, Virginia McConnell, and Anna Alberini, Economic Incentive Policies under Uncertainty:The Case of Vehicle Emission Fees (Washington, DC: Resources for the Future, August 1996).
U.S. EPA, Office of Policy, Planning and Evaluation, Guidance on the Use of Market Mechanisms to Reduce Transportation Emissions, Almost Final Draft (Washington, D.C., May 1996).
Ibid.
Ibid. The EPA / ICF report was well documented and provided citations for each of the numbers.
National Science and Technology Council, Committee on Environment and Natural Resources, Interagency Assessment of Oxygenated Fuels (Washington, D.C., June 1997).
For a more detailed discussion of the limitations of this option, see Kenneth Green, Headed for Costly Failure: An Analysis of the Dallas-Fort Worth Clean Air Plan (San Antonio, Texas: Texas Public Policy Foundation, 1999).
US DOT and US EPA, Clean Air Through Transportation: Challenges in Meeting National Air Quality Standards (Washington D.C., August 1993), p. 19.
California Air Resources Board, California Air Quality, A Status Report (Sacramento, California, 1991).
South Coast Air Quality Management District, 1994 Air Quality Management Plan, Appendix IV-B, District's Mobile Source Control Plan (Diamond Bar, California, 1994) p. MON-7.
Winston Harrington et al., The Enhanced I/M Program in Arizona: Costs, Effectiveness, and a comparison with Pre-regulatory Estimates (Washington, DC: Resources for the Future, June 1999).
Tom Wenzel, et al., Evaluation of the Enhanced Smog Check Program: A Report to the California Inspection and Maintenance Review Committee (Sacramento, California: California Inspection and Maintenance Review Committee, June 19, 2000). (www.smogcheck.org/smogweb/IMRC/).
Huel C. Scherrer and David B. Kittelson, I/M Effectiveness as Directly Measured by Ambient CO Data, SAE Technical Paper Series (Washington, D.C.: SAE International, February 1994).
Patrick Bedard, "Still Smoggy After All These Years," Car and Driver, (April 1995), p. 107.
Gary A. Bishop, Donald H. Stedman and Lowell Ashbaugh, "Motor Vehicle Emissions Variability," Technical Paper, Journal of the Air and Waste Management Association, Volume 46, (July 1996). See also Jerry Aroesty, et al. Restructuring Smog Check: A Policy Synthesis (Draft) (Santa Monica, California: Rand Corporation, October 1994), p. 7.
Joel Schwartz, Smog Check II Evaluation, Part II: Overview of Vehicle Emissions (Sacramento, California: California Inspection and Maintenance Review Committee, June 2000). (http://www.smogcheck.org/smogweb/IMRC/).
Arizona Department of Environmental Quality, Exemption of Vehicles from I/M Requirements in the Phoenix Area: The Arizona Clean Screen Program (Phoenix: Radian International, LLC, December 1996).
Hartwell, Simplify, Simplify, http://www.newenvironmentalism.org/comflex.htm#newjersey.
Ibid, http://www.newenvironmentalism.org/comflex.htm#massachusetts.
Ibid., http://www.newenvironmentalism.org/comflex.htm.
Alexander Volokh et al., Environmental Information: The Toxics Release Inventory, Stakeholder Participation, and the Right to Know, Policy Study No. 246 (Los Angeles: Reason Public Policy Institute, December 1998), http://www. newenvironmentalism.org/comflex.htm#oregon.
These suggestions were provide by Coralee Cooper of NESCAUM, interview by Lisa A. Skumatz, May 5, 2000.
See presentation by Ralph Torrie, Torrie Smith Associates in Panel 3, Case Studies of "Selling Clean Air Workshop Proceedings," October 15-16, 1999, Vancouver, Canada, http://felix.vcn.bc.ca/wcelpub/1000/12729.htm.
Retrofits have been very effective in the Boston/Logan Airport, for example. Interview by Lisa A. Skumatz with Doug Wheaton, Logan Airport, March 17, 2000.
Kenneth Green, Checking Up on Smog Check: A Critique of Traditional Inspection and Maintenance Programs, Policy Study No. 227 (Los Angeles: Reason Public Policy Institute, March 1997), http://www.Reason Public Policy Institute .org/environment/ps222. html.
Note that large-scale commercial/industrial air conditioner applications (stationary applications) can also process considerable quantities of air.
Interview with Chuck Knott of Englehard Corporation, by Lisa A. Skumatz, May 22, 2000.
These suggestions were provide by Coralee Cooper of Northeast States for Coordinated Air Use Management (NESCAUM), interview by Lisa A. Skumatz, March 14, 2000, www.nescaum.org.
Progressive Insurance, according to Deann Upson, United States Environmental Protection Agency, interview by Lisa A. Skumatz, March 14, 2000
Poole Jr., Shuttle Vans: The Overlooked Alternative, http://www.Reason Public Policy Institute .org/transportation/ps230.html.
A Maryland study shows use 1.15 times per year, according to transportation specialist Scot Spencer of Environmental Defense, interview by Lisa A. Skumatz, March 16, 2000.
Green, Checking Up on Smog Check, http://www.Reason Public Policy Institute .org/environment/ps222. html.
According to Doug Wheaton at Logan Airport, they have not increased the fees for non-compliers, but have only provided reductions, stressing the revenue recovery some, but revenue neutral subsidies could be used. Interview by Lisa A. Skumatz, March 17, 2000.
These suggestions were provide by Coralee Cooper of Northeast States for Coordinated Air Use Management (NESCAUM). Interview by Lisa A. Skumatz, May 5, 2000, www.nescaum.org.

E-brief 105

info@reason.org (Kenneth Green) — Sun, 01 Oct 2000 00:00:00 EDT

Every five years, the Intergovernmental Panel on Climate Change publishes a massive report on global climate change. These "Assessment Reports" become the central touchstone of the debate over climate change, laying out a consensus version of what is known, what is still uncertain, and how various actions might or might not cause changes in future climate conditions.

The last such publication was the IPCC's "Second Assessment Report (SAR),"published in 1995. The 1995 SAR argued that the Earth's climate was changing in ways that seemed unlikely to be of non-human origin, and that the weight of evidence suggested a "discernable" human impact upon the climate. Predicted future temperatures in the SAR ranged from 1 °C to 3.5 °C (1.8 °F to 6.5 °F) degrees centigrade by 2100, and sea level increases of 15 to 95 cm in the same timeframe.

The 1995 report is about to be supplanted by the IPCC "Third Assessment Report, or TAR, to be published early in 2001. The first volume of the TAR, the product of IPCC's Working Group 1 (WG1) reviews the massive body of climate change literature, and attempts to present a consensus view of the current understanding of climate change. This report was reviewed by a panel of experts in late 1999, was subsequently reviewed by governmental entities, was revised according to feedback, and is now undergoing "final government review." After a last round of revisions based on the final government review (which, theoretically will not alter any of the scientific conclusions of the report as it emerged from expert review), the TAR will be published in early 2001.

When the IPCC publishes a new major report, it also publishes a derivative document called the "Summary for Policymakers" (or Summary). These summaries attempt to condense the contents of the IPCC's full Assessment Report, and express findings in a language suitable for moderately educated readers.

Less than two weeks before the U.S. Presidential elections, copies of the draft Summary for Policymakers based on the Third Assessment Report were leaked to the Associated Press and other media commentators. The draft Summary became an instant issue in the election.

Working from more extreme �worst-case' estimates than previous IPCC reports, the Summary suggests a higher range of potential warming by 2100, and higher sea-level rise as well. Global average temperature in the new Summary is modeled to increase from 1.5 to 6.0 degrees Centigrade by 2100 (2.7 to 10.4 degrees Fahrenheit). Predicted sea-level increases under the new scenarios range from 14 to 80 cm by 2100.

But media coverage of the Summary lacks contextual information needed to allow people to decide whether the report was credible. The genesis of the Summary was not explained, and the "findings were not put in context with regard to either the previous assessment report, or the main body of the more scientifically rigorous and more carefully qualified Third Assessment Report.

Climate change is a concern worthy of serious attention, and the best quality scientific research that humanity can muster. It is an issue of great complexity, in which fine details of interpretation, and underlying assumptions are indispensable if sound policy is to be derived from sound use of scientific information.

The purpose of this document is to add some context and balance to the discussion, and to correct some of the mistaken impressions that recent news coverage of the leaked IPCC draft Summary for Policymakers may have created.

1. Predictions of future changes rest upon speculative scenarios that were not reviewed by technical reviewers of the main report.

The claims regarding the potential increase in global average temperatures and sea levels in the year 2100 are based upon "scenarios" about the future that enfold a panoply of assumptions about global development patterns, population growth, energy sources, economic development, technological change, and so on:

It is the addition of more pessimistic scenarios to those used in previous IPCC reports that produces greater estimated future temperatures, more than changes in understanding of past or present climate processes, or theoretical understanding of the relationship between human activity and climate;
Future temperature and sea-level predictions are not modeled with state-of-the-art computer models, but use "simple" computer models that are "calibrated" to the more accurate models. No mention is made of the fact that such simple models imitate their high-powered cousins poorly; have many well-known weaknesses that make them of limited use; and are of limited reliability even for modeling current climate trends;
Only the Summary of the report delineating scenario assumptions is currently available for download which limits analysis, but the new "worst case" scenario assumes that:
- There are no mid-course programs implemented between now and 2100;
- Population peaks at 8.7 billion in 2050, and declines to 7 billion by 2100;
- Global deforestation is not abated;
- The developing world will reach similar levels of development as developed countries;
- World GDP will increase 10 times by 2100;
- Most energy production will be from carbon-based fuels;
- Carbon dioxide emissions will nearly quadruple by 2100;
- Methane emissions will more than double by 2100;
- Carbon monoxide emissions will nearly triple by 2100;
- Volatile organic carbon emissions will nearly triple by 2100; and
- Fluorocarbon levels will rise dramatically by 2100, in some cases by two orders of magnitude.
The assumptions used in these "scenarios" were only published in the Spring of 2000, more than six months after the actual "expert review" cycle was completed; and
Economic and population parameters are not published as part of the peer-reviewed Third Assessment Report, and must be retrieved from another report. This makes simultaneous comparison difficult for experts with access to the full reports, and nearly impossible for others who have only the Summary.

2. The Summary for Policymakers presents findings devoid of vital contextual information.

When discussing the findings of how the Earth's climate has changed in recent years, the Summary for Policymakers presents hard evidence regarding temperature readings, rain measurements, snow measurements, and so on. But the Summary presents this information without vitally important contextual and qualifying information found in the body of the IPCC report:

Increases in temperature are presented without pointing out that:
- The majority of physically observed warming since 1860 happened from 1910-1945, and the majority of that early warming is attributed to non-human climate forces in the body of the report;
- The warming observed since 1860 was not continuous, but happened in two bursts;
- Twice as much of the observed warming since 1860 appears as warming of nighttime low temperatures in the coldest parts of the Earth, rather than increases of daytime highs in the warmer parts of the Earth;
- The difference between ground-level temperature readings and high-altitude readings from balloons and satellites reveals a critical weakness of the climate models used to predict future impacts discussed later in the Summary; and
- Estimated increases in temperature for the last 1000 years, are based on disputed climate reconstructions rather than observed data. No mention is made that evidence documents sharper temperature shifts in the climate record from before humans existed, suggesting that recent changes could be of non-human origin.
Decreases in global ice extent (glaciers, icebergs, etc) and snowfall trends are presented without explaining that:
- Measurements of historical snow depth and extent are extremely limited;
- Glaciers in some regions are growing, not shrinking;
- Reductions in snow and ice are not happening in the seasons where increased warmth has actually been observed;
- Estimates of Arctic sea ice thickness show a wide range, from 1 to 4 centimeters of shrinkage per year because the sampling of evidence is too small to be conclusive; and
- Antarctic sea ice has been stable or shows what seems to be a slight increase in extent since the 1970s.
Evidence of sea level rise of 0.1 to 0.2 meters during the 20th Century is presented without reference to the fact that:
- Sea level has been rising for nearly 20,000 years, by about 120 meters since the last glacial maximum;
- The rate of sea level rise is not steady, but fluctuates;
- Sea level rise did not speed up during the 20th Century, though theoretically, global average temperatures were increasing; and
- While sea level rose between one-tenth and two-tenths of a meter during the 20th Century, the body of the report attributes only two-hundredths to six-hundredths of a meter to human activity from 1910 to 1990.
The claim that human activities "continue to alter the atmosphere in ways that affect the climate system" is made without mentioning that:
- This conclusion, unlike those regarding actual climate changes, are purely based on still-developing theories and highly uncertain computer modeling, not on any measurable cause-and-effect relationship between any particular activity and global climate;
- Greenhouse gases including both carbon dioxide and methane rose and fell along with global average temperatures before human beings were around to influence their concentrations;
- At least two of these human activities expected to contribute to greater warming in the future are pollution reduction initiatives to reduce sulfur aerosols, and to eliminate the use of ozone-destroying chlorofluorocarbons;
- While computer models agree that human activities have some role in observed 20th Century warming, individual models give very different estimates for the extent of the human role;
- Uncertainties are still large in key modeling areas that underpin the entire claim of human causality in observed changes. These uncertainties involve the role of water vapor, cloud formation, and aerosol impacts in climate regulation.

3. The leaked "Summary for Policymakers" is not peer-reviewed, the author is anonymous, the document is created independently of the actual Assessment Report, and the Summary is so short that issues are overly simplified.

Unlike the main body of the IPCC Third Assessment Report which represents an herculean effort to assess the current state of knowledge about climate change, and which speaks with great credibility because of extensive peer-review, the leaked Summary for Policymakers is not reviewed by the main body of IPCC experts and thus lacks the credibility of the technical reports they claim to summarize.
The author of the summary is not identified, and there is no explanation of the process that generated the Summary, nor specifies whether it was or was not reviewed by the main authors, contributing authors, or expert reviewers that vetted the body of the Third Assessment report.
The Summary for Policymakers is 12 pages long, and theoretically summarizes the Working Group I report (which) is over 1000 pages long as well as parts of the not-yet-finalized Working Group II report, which will probably be over 1000 pages.

Summary

News coverage of the recently leaked "Summary for Policymakers" from the pending Third Assessment Report of the Intergovernmental Panel on Climate Change lacks information vital to putting the leaked document in meaningful perspective.

Specifically, the leaked report:

Does not explain that increases in predicted future temperatures from the last IPCC report are due to added worst-case scenarios generated outside the careful, peer-reviewed publication process of the Third Assessment Report rather than changes in gathered evidence or empirically documented trends in climate, energy use, or greenhouse gas production;
Does not spell out how extreme the worst-case scenarios are;
Does not explain that predictions of future climate were generated not with state-of-the-art models, but with simple climate models that cannot reliably reproduce known temperature changes of recent years.
Does not provide the contextualizing information needed to accurately communicate what scientists have learned about past climate changes, current climate function, or future climate expectations;
Does not mention that observed climate changes are only partially due to human activity; and
Was not peer-reviewed by the same experts who reviewed the technical reports from which it is ostensibly extracted.

The forthcoming Third Assessment Report of the Intergovernmental Panel on Climate Change will serve as the central touchstone of climate change debate for the next five years. Climate change is a serious and important subject, and concerns about rapid changes in climate � whatever the cause might be — should not be treated lightly. Accuracy in the understanding of the underlying science is equally critical, and should not be misrepresented or politicized by partisans of any particular control approach.

Activities which weaken the credibility of the TAR impede not only the search for knowledge, but insure greater divisiveness in the debate over whether the report represents a scientific consensus, or is a document biased by political forces outside of the scientific process of discovery.

The leak of the Summary report of the IPCC Third Assessment Report may be seen, by some, as a way of creating a short-term ripple in the political landscape of the United States Presidential campaign. But in the long term, this leak can only harm the search for a consensus statement of knowledge, and the search for appropriate responses to the risks posed by climate change.

Related Publications

Dr. Kenneth Green is Director of the Environmental Program at Reason Foundation.

Mopping up After a Leak

info@reason.org (Kenneth Green) — Sun, 01 Oct 2000 00:00:00 EDT

Working from more extreme ‘worst-case' estimates than previous IPCC reports, the Summary suggests a higher range of potential warming by 2100, and higher sea-level rise as well. Global average temperature in the new Summary is modeled to increase from 1.5 to 6.0 degrees Centigrade by 2100 (2.7 to 10.4 degrees Fahrenheit). Predicted sea-level increases under the new scenarios range from 14 to 80 cm by 2100.

1. Predictions of future changes rest upon speculative scenarios that were not reviewed by technical reviewers of the main report.

It is the addition of more pessimistic scenarios to those used in previous IPCC reports that produces greater estimated future temperatures, more than changes in understanding of past or present climate processes, or theoretical understanding of the relationship between human activity and climate;
Future temperature and sea-level predictions are not modeled with state-of-the-art computer models, but use "simple" computer models that are "calibrated" to the more accurate models. No mention is made of the fact that such simple models imitate their high-powered cousins poorly; have many well-known weaknesses that make them of limited use; and are of limited reliability even for modeling current climate trends;
Only the Summary of the report delineating scenario assumptions is currently available for download which limits analysis, but the new "worst case" scenario assumes that:
- There are no mid-course programs implemented between now and 2100;
- Population peaks at 8.7 billion in 2050, and declines to 7 billion by 2100;
- Global deforestation is not abated;
- The developing world will reach similar levels of development as developed countries;
- World GDP will increase 10 times by 2100;
- Most energy production will be from carbon-based fuels;
- Carbon dioxide emissions will nearly quadruple by 2100;
- Methane emissions will more than double by 2100;
- Carbon monoxide emissions will nearly triple by 2100;
- Volatile organic carbon emissions will nearly triple by 2100; and
- Fluorocarbon levels will rise dramatically by 2100, in some cases by two orders of magnitude.
The assumptions used in these "scenarios" were only published in the Spring of 2000, more than six months after the actual "expert review" cycle was completed; and
Economic and population parameters are not published as part of the peer-reviewed Third Assessment Report, and must be retrieved from another report. This makes simultaneous comparison difficult for experts with access to the full reports, and nearly impossible for others who have only the Summary.

2. The Summary for Policymakers presents findings devoid of vital contextual information.

Increases in temperature are presented without pointing out that:
- The majority of physically observed warming since 1860 happened from 1910-1945, and the majority of that early warming is attributed to non-human climate forces in the body of the report;
- The warming observed since 1860 was not continuous, but happened in two bursts;
- Twice as much of the observed warming since 1860 appears as warming of nighttime low temperatures in the coldest parts of the Earth, rather than increases of daytime highs in the warmer parts of the Earth;
- The difference between ground-level temperature readings and high-altitude readings from balloons and satellites reveals a critical weakness of the climate models used to predict future impacts discussed later in the Summary; and
- Estimated increases in temperature for the last 1000 years, are based on disputed climate reconstructions rather than observed data. No mention is made that evidence documents sharper temperature shifts in the climate record from before humans existed, suggesting that recent changes could be of non-human origin.
Decreases in global ice extent (glaciers, icebergs, etc) and snowfall trends are presented without explaining that:
- Measurements of historical snow depth and extent are extremely limited;
- Glaciers in some regions are growing, not shrinking;
- Reductions in snow and ice are not happening in the seasons where increased warmth has actually been observed;
- Estimates of Arctic sea ice thickness show a wide range, from 1 to 4 centimeters of shrinkage per year because the sampling of evidence is too small to be conclusive; and
- Antarctic sea ice has been stable or shows what seems to be a slight increase in extent since the 1970s.
Evidence of sea level rise of 0.1 to 0.2 meters during the 20th Century is presented without reference to the fact that:
- Sea level has been rising for nearly 20,000 years, by about 120 meters since the last glacial maximum;
- The rate of sea level rise is not steady, but fluctuates;
- Sea level rise did not speed up during the 20th Century, though theoretically, global average temperatures were increasing; and
- While sea level rose between one-tenth and two-tenths of a meter during the 20th Century, the body of the report attributes only two-hundredths to six-hundredths of a meter to human activity from 1910 to 1990.
The claim that human activities "continue to alter the atmosphere in ways that affect the climate system" is made without mentioning that:
- This conclusion, unlike those regarding actual climate changes, are purely based on still-developing theories and highly uncertain computer modeling, not on any measurable cause-and-effect relationship between any particular activity and global climate;
- Greenhouse gases including both carbon dioxide and methane rose and fell along with global average temperatures before human beings were around to influence their concentrations;
- At least two of these human activities expected to contribute to greater warming in the future are pollution reduction initiatives to reduce sulfur aerosols, and to eliminate the use of ozone-destroying chlorofluorocarbons;
- While computer models agree that human activities have some role in observed 20th Century warming, individual models give very different estimates for the extent of the human role;
- Uncertainties are still large in key modeling areas that underpin the entire claim of human causality in observed changes. These uncertainties involve the role of water vapor, cloud formation, and aerosol impacts in climate regulation.

Unlike the main body of the IPCC Third Assessment Report which represents an herculean effort to assess the current state of knowledge about climate change, and which speaks with great credibility because of extensive peer-review, the leaked Summary for Policymakers is not reviewed by the main body of IPCC experts and thus lacks the credibility of the technical reports they claim to summarize.
The author of the summary is not identified, and there is no explanation of the process that generated the Summary, nor specifies whether it was or was not reviewed by the main authors, contributing authors, or expert reviewers that vetted the body of the Third Assessment report.
The Summary for Policymakers is 12 pages long, and theoretically summarizes the Working Group I report (which) is over 1000 pages long as well as parts of the not-yet-finalized Working Group II report, which will probably be over 1000 pages.

Summary

Specifically, the leaked report:

Does not explain that increases in predicted future temperatures from the last IPCC report are due to added worst-case scenarios generated outside the careful, peer-reviewed publication process of the Third Assessment Report rather than changes in gathered evidence or empirically documented trends in climate, energy use, or greenhouse gas production;
Does not spell out how extreme the worst-case scenarios are;
Does not explain that predictions of future climate were generated not with state-of-the-art models, but with simple climate models that cannot reliably reproduce known temperature changes of recent years.
Does not provide the contextualizing information needed to accurately communicate what scientists have learned about past climate changes, current climate function, or future climate expectations;
Does not mention that observed climate changes are only partially due to human activity; and
Was not peer-reviewed by the same experts who reviewed the technical reports from which it is ostensibly extracted.

The forthcoming Third Assessment Report of the Intergovernmental Panel on Climate Change will serve as the central touchstone of climate change debate for the next five years. Climate change is a serious and important subject, and concerns about rapid changes in climate – whatever the cause might be – should not be treated lightly. Accuracy in the understanding of the underlying science is equally critical, and should not be misrepresented or politicized by partisans of any particular control approach.

Related Publications

Dr. Kenneth Green is Director of the Environmental Program at Reason Foundation.

A Plain English Guide to Climate Change

info@reason.org (Kenneth Green) — Tue, 01 Aug 2000 00:00:00 EDT

Few people would dispute that the concept of Global Climate Change is one of the most complex science-derived issues to wind up at the center of political discourse. The section of the landmark Second Assessment Report of the Intergovernmental Panel on Climate Change (IPCC) dealing with the science of climate change is over 500 pages long by itself, containing 75 pages of references alone. Documentation from outside the IPCC is equally voluminous.

The terrific complexity of climate change research poses a challenge for the decision-making apparatus in democratic societies, since it is simply unrealistic to expect the public, policymakers or the media to read and understand the full body of climate change literature. Instead, they must rely on publications put out by pressure groups with a position for or against climate change, or on the verbal summation of a small number of high-profile experts. But thirty second sound bites don’t leave much room for qualifications, and, just as the devil is in the details, the quality of science is in the qualifications. The first thing to be lost in science-policy discussion is a clear representation of the complexity of the issue which accurately depicts both the certainties and the uncertainties involved.

The importance of having accurate portrayals of the nature, magnitude, certainty and imminence of environmental hazards is hard to overstate. As a society, we have a limited amount of resources with which to address these hazards, whether we address them through environmental improvement programs such as air quality controls, or whether we address them through other public health improvement efforts. Wasting our resources by ranking our problems poorly costs lives, and quality of life, that we could otherwise preserve.

The purpose of this guide, then, is to translate the evidence regarding global climate change from the arcane language of science into the mainstream language of English, so that the weighing of evidence can be put back into a public debate that all too often weighs only the sound bites of pundits, politicians, industry representatives and celebrity scientists.

This guide is not intended to be a comprehensive treatment of every facet of global climate change research. Rather, this guide is offered to facilitate independent evaluation of what I hope is an unbiased selection of the relevant evidence in order to enhance the quality of public policy debate.

Do not believe in anything simply because you have heard it. Do not believe in anything simply because it is spoken and rumored by many. Do not believe in anything simply because it is found written in your religious books. Do not believe in anything merely on the authority of your teachers and elders. Do not believe in traditions because they have been handed down for many generations. But after observation and analysis, when you find that anything agrees with reason and is conducive to the good and benefit of one and all, then accept it and live up to it.

- Gautama Buddha

Part 1

Global Warming Theory

Global warming theory is really just the planet-wide application of a much more humble theory called the "greenhouse effect." This theory, first quantified by a Swedish chemist named Arrhenius in 1896, is relatively simple, relies on well defined and tested laws of thermodynamics, and has been repeatedly validated by not only laboratory experiments, but by millions of greenhouse owners.

The core greenhouse effect theory is simple: When sunlight reaches the surface of the earth, some of its energy is absorbed by the ground, some of it is reflected back unchanged, and some of the energy absorbed is re-emitted by the ground in the form of heat. Over a bare patch of ground, there would be no net increase in the temperature over time because the heat absorbed during the day is given up overnight. This re-emission of heat is familiar to most people who have ever asked why snakes seek out highways at night: it’s to stay warm in the re-radiated heat flowing out of the pavement.

If there is a greenhouse located on the patch of ground discussed above, things are a bit different. The sunlight enters as usual, and some of it is reflected back out as usual, but part of the incoming sunlight that was held by the surface and re-emitted as heat does not pass back out through the glass, and the greenhouse warms up a bit. That warming tends to free some water vapor from the ground and the plants, and that water vapor traps yet more of the re-radiated heat coming up from the surface. In fact, the water vapor traps much more of the retained heat than the glass which started the process. That’s the greenhouse effect in a nutshell.

Scientists have known for a long time that the greenhouse effect applies not only to greenhouses, but to the Earth as a whole, with certain "greenhouse" gases playing the role of the glass in the example above. When applied to the whole planet, this relationship between certain gases in the atmosphere and the temperature of the atmosphere is called "global warming theory." The global greenhouse effect is a natural aspect of Earth’s environment, crucial for the maintenance of life on Earth. Without Earth’s natural greenhouse effect, and the global warming that goes with it, the Earth would be a much colder planet, inhospitable to life as we know it.

Part 2

Climate Change Theory

Climate change theory is an attempt to understand how global warming might affect the planetary environment as a whole while focusing only on humanity’s impact on the Earth’s climate.

Concern over climate change is not actually about the warming of the Earth’s climate, per se, nor is it about the natural temperature variations that the Earth has shown over its four billion year climate history—which are extensive—as seen in Figure 1.

It is widely acknowledged that the potential temperature changes predicted by global warming theory do not pose a direct threat to human life. Human beings, and a myriad of other organisms, exist quite comfortably in areas with temperature ranges more extreme than those predicted by global warming models. Rather, the major concerns about climate change focus on the second- and third-hand impacts that would theoretically accompany global warming.

Climate change theory suggests that warming of the overall environment could lead to a variety of changes in the patterns of Earth’s climate as the natural cycles of air currents, ocean currents, evaporation, plant growth and so on change in response to the increased energy levels in the total system. The most commonly predicted primary impacts of global warming are increased activity in the hydrologic, or water cycle of the Earth, and the possible rise of oceans due to thermal expansion and some melting of sea ice, ice sheets, or polar icecaps. More dynamic activity in the water-cycle could lead to increased rainfall in some areas, or, through increased evaporation rates, could cause more severe droughts in other areas. Rising sea levels could inundate some coastal areas (or low-lying islands), and through salt-water intrusion, could cause harm to various freshwater estuaries, deltas, or groundwater supplies.

Some have also predicted a series of third-hand impact to occur if the climate actually warms and becomes more dynamic. Wildlife populations would be affected (positively and negatively), as would some vegetative growth patterns. The "home-range" of various animal and insect populations might shift, exposing people to diseases that were previously uncommon to their area, and so on.

Finally, the concern over climate change is not about non-human impacts on the climate, but is specifically a concern about human potential to alter the climate through activities such as the emission of fuel combustion by-products, or through land-use decisions that alter the Earth’s vegetation patterns. Such human-induced changes in climate are called anthropogenic.

While greenhouse effect theory is a relatively uncontroversial issue in the scientific sense, the theory of global, human-driven climate change is at a much younger stage of development. Although there are very few articles appearing in science journals that contradict either the overall theory or details of the core greenhouse effect, the same can not be said for the theory of man-made climate change. Indeed, studies jockey back and forth about key elements of anthropogenic climate change nearly every month on the pages of leading science journals including America’s premier science journal, Science. Even the IPCC report on the Science of Climate Change leaves the question open, saying:

Finally, we come to the difficult question of when the detection and attribution of human-induced climate change is likely to occur. The answer to this question must be subjective, particularly in the light of the large signal and noise uncertainties discussed in this chapter. Some scientists maintain that these uncertainties currently preclude any answer to the question posed above. Other scientists would and have claimed, on the basis of the statistical results presented in Section 8.4, that confident detection of a significant anthropogenic climate change has already occurred.

This is not to say that man-made climate change theory is either right or wrong, proven or not proven, looming catastrophe or massive hoax—only that it is not, as various groups have implied, nearing a final verdict. Indeed, the vigorous flow of publications and the acknowledged controversy within the IPCC documentation of the science of climate change imply that the question is still quite open.

Part 3

Atmospheric Changes

Human activities (as well as non-human biological, chemical, or geological processes) release a variety of chemicals into the atmosphere, some of which, in accordance with climate change theory, could exert a warming effect, and others which, according to the same theory, could exert a cooling effect.

1. Carbon Dioxide

Carbon dioxide, considered a warming gas, comprises about 0.034% of the atmosphere by volume. Carbon dioxide levels have increased as a component of the atmosphere by nearly 30% from the late 18^th century to the present. Carbon dioxide is released into the environment by human activities such as fuel burning, cement production and land use. Carbon dioxide in the atmosphere is part of a larger carbon cycle in which carbon is changed from gaseous to non-gaseous forms over the course of time by a variety of organic and inorganic processes. Table 1 shows the tonnage of carbon exchanged between various sources and sinks in the environment, as they are relevant to a potential role for carbon dioxide climate change.

Table 1: Exchangeable Flows of Carbon in the Environment
Natural Sources	Range (Gtons/yr)	Percent of Total (out of 158 Gtons/yr)
Oceans	90–92	57–58
Land biota	60–61	36–39
Natural Source Total	150–153	93–97
Human Sources
Burning fossil fuels	5.0–6.0	3.4–3.8
Deforestation	0.6–2.6	0.01–0.02
Human Source Total	5.6–8.6	3.5–5.4
Total	157–160	100%

Since highly accurate, direct measurement of carbon dioxide levels only began in the late 1950s, most of our understanding of carbon dioxide’s historical patterns of fluctuation come from indirect measurements, such as the analysis of gas bubbles trapped in glaciers and polar ice caps. Though such indirect measure-ments carry greater uncertainty than direct measurements of carbon dioxide levels, they have contributed to rapid growth in our understanding of the Earth’s carbon cycle in recent years. Still, significant gaps in our understanding remain, specifically involving questions of time lag, the impact of world vegetation on atmospheric carbon dioxide levels, other processes that might lock carbon dioxide away from the atmosphere, and the role of carbon dioxide as a causal agent of climate change.

2. Methane

Methane is a greenhouse gas several times more powerful as a warming agent than carbon dioxide, though with a considerably shorter life-span in the atmosphere. As an atmospheric component, methane is considered a trace gas, comprising approximately 0.00016 percent of the atmosphere by volume. Methane levels in the atmosphere have increased nearly 150 percent since the beginning of the 19^th century, with current levels being the highest ever recorded, though the pattern of methane emissions is highly irregular and has actually shown recent downturns for reasons which are not clear.

Methane comes from a variety of sources, only some of which are directly man-made. Table 2 shows the sources of methane found in the atmosphere.

Table 2: Sources of Methane Found in the Atmosphere
Natural Sources	Range (Mtons)	IPCC Value	Percent of IPCC total
Wetlands	100–200	115	22
Termites	10–50	20	4
Ocean/freshwater	6-45	15	3
Methane hydrates	0–5	5	1
Natural Source Total	117–325	150	30
Human Sources
Energy Use	70–120	100	19
Rice paddies	20–150	60	12
Enteric fermentation	65–100	80	15
Human / Animal wastes	20–60	50	10
Landfills	20–70	30	6
Biomass burning	20–80	40	8
Human Source Total	215–580	360	70
Total	332-905	515	100

NOTES:

An Mton, or megaton, is one million metric tons.
Column three shows the values deemed most likely by the IPCC.
"Enteric Fermentation" constitutes gaseous emissions from animals. The IPCC considers all animal emissions as being caused by activities of mankind.
Calculations of percent contribution by author, using IPCC 1992 data. The 1995 report did not break out the individual contributions, important information for understanding the relative contributors of methane to the atmosphere. Changes in the actual numerical assessment of the methane budget, however, are not substantial in the newer report.

3. Nitrous Oxide

Nitrous oxides are long-lived warming gases with about 200 times the relative warming strength of carbon dioxide. Nitrous oxides are, like methane, considered a trace gas in the atmosphere, but at considerably lower levels, between 0.000001 percent and 0.0000000001 percent of the atmosphere by volume. With the exception of a downturn attributed to the eruption of Mt. Pinatubo, nitrous oxide concentrations have increased in recent years, though not beyond the levels seen in previous decade-long averaging periods

Nitrous oxides come from a variety of sources, only some of which are directly man-made. Table 3 shows the sources of nitrous oxides found in the atmosphere.

Table 3: Sources of Nitrous Oxides Found in the Atmosphere
Natural Sources	Range (in Mtons)
Oceans	1.4–2.6
Tropical Soils	Uncertain
Wet forests	2.2–3.7
Dry savannas	0.5–2.0
Temperate soils	Uncertain
Forests	0.5–2.0
Grasslands	Uncertain
Natural Source Total	4.6–10.3
Anthropogenic Sources
Cultivated soils	0.3–3.0
Biomass burning	0.03–1.0
Combustion	0.1–0.3
Mobile sources	0.2–0.6
Acid production	0.5–0.9
Anthropogenic Source Total	0.13–5.8
IPCC Total	5.2–16.1

4. Chlorofluorocarbons

Chlorofluorocarbons (CFC) are man-made compounds used as cooling agents and propellants in a broad range of applications. Since CFCs are a class of many different long-lived chemicals, some of which have been banned, characterizing their concentration in the atmosphere is difficult. Ozone-depleting CFCs can exert either warming or cooling effects, depending on where they are found. In the lower atmosphere, ozone-depleting CFCs exert a warming effect through the absorption of heat re-radiated from the Earth’s surface. In the upper atmosphere, ozone destruction exerts a cooling effect by destroying some of the high-altitude ozone that can either warm or cool the surface in different circumstances. On a net basis, our current understanding is that the ozone-depleting CFCs (now banned by the Montreal Protocol) exerted a cooling effect. Replacement chemicals for the ozone-depleting CFCs are considered pure warming gases, but with a considerably lower warming potential than the chemicals they displaced. Because of the huge complexities of ozone chemistry in the atmosphere and uncertainties regarding the warming or cooling potential of remaining ozone-depleting CFCs and replacement compounds, the ultimate impact of CFCs on climate change is highly uncertain.

5. Aerosols

Aerosols are not gases, but are liquid or solid particles small enough to stay suspended in the air. Aerosols are generated by both man-made and natural processes. Some aerosol particles tend to reflect light, or cause clouds to brighten, exerting a cooling effect on the atmosphere. Other aerosol particles tend to absorb light and can exert a warming effect. Most man-made aerosols exert a cooling effect on the climate. On a global basis, this cooling effect offsets about 20 percent of the predicted warming from the combined greenhouse warming gases, but it’s not uniform: the offsetting impact varies geographically depending on local aerosol concentrations. Table 4 shows the origin and flow rates of aerosol particulates in the atmosphere.

The omission of aerosol considerations in earlier climate models led to considerable over-prediction of projected global warming and predicted regional impacts, though newer models have done much to internalize the cooling effect of aerosols. Aerosols act as cooling agents through several mechanisms, however, some of which are only poorly understood. Besides directly scattering incoming sunlight, most particulates also increase the reflectivity, formation, and lifetime of clouds, affecting the reflection of incoming solar radiation back to space.

Table 4: Aerosol Particulate Types and Flow Rates in the Atmosphere
Natural Sources	Flux (in Mtons/yr)
Primary
Soil dust	1,500
Sea salt	1,300
Volcanic dust	33
Biological debris	50
Secondary
Sulphates from natural precursors	102
Organic matter from biogenic VOC	55
Nitrates from NOx	22
Total from Natural Sources	3,062
Anthropogenic Sources
Primary
Industrial dust	100
Soot (elemental carbon) from fossil fuels	8
Soot from biomass burning	5
Secondary
Sulphates from SO₂	140
Biomass burning	80
Nitrates from NOx	36
Total from Anthropogenic Sources	369
Combined Total	3,431

6. Summary of Atmospheric Changes

It is clear that human action affects the level of several atmospheric components, including five of the six constituents considered to be the major greenhouse gases: carbon dioxide, methane, nitrous oxides, ozone, and CFCs. The sixth major greenhouse gas is water vapor, and while it’s almost certain that human action influences the amount of water vapor in the atmosphere, the role of water vapor in climate change is still highly uncertain, as will be discussed later.

It is also clear that human action is not the only factor involved in determining the atmospheric concentrations of these gases. For all gases except methane, sulfur-based aerosols, and CFCs, the human contribution is, by far, the smaller part of the total.

Part 4

Climate Changes

art of the concern about global climate change stems from the human tendency to seek meaning in events which may or may not be more than simply a random event. A particularly cold winter, a particularly hot summer, an especially rainy season, or an especially severe drought will all send people off on a search for the greater meaning of the phenomenon. Is it a pattern, or a one-time event? Must we build a dike, or has the danger passed? Since the summer of 1988, virtually all unusual weather events seem to trigger questions about global climate change.

Our ability to really know what the climate is doing is limited by a short observational record, and by the uncertainties involved in trying to figure out what climate was like in the past, or might be like in the future, for comparison with recent climate changes. While the Earth’s climate has been evolving and changing for over four billion years, recordings of the temperature only cover about 150 years, less than 0.000004% of the entire pattern of evolving climate. In fact, temperature records are spotty before about 40 years ago and only cover a tiny portion of the globe, mostly over land. In addition to that 150-year conventional surface temperature record, temperature readings taken from weather balloons cover the last 30 years, and satellite temperature readings cover the last 18 years. Modern, reliable measurements of greenhouse gases are an even newer source of data, beginning with carbon dioxide measurements at the South Pole in 1957, at Mauna Loa in 1958, and later for methane, nitrous oxides and chlorofluorocarbons.

Aside from temperature readings, other climate trends proposed as secondary effects of global warming carry information about the state of the climate. Changes in absolute humidity, rainfall levels, snowfall levels, the extent of snowfall, the depth of snowfall, changes in ice caps, ice sheets, sea ice, and the intensity or variability of storms have all been proposed as secondary effects of global warming. But because the history of recording such climate trends is extremely short, most evidence regarding non-temperature-related changes in Earth’s climate and atmospheric composition prior to the recent history of direct measurements is gathered from indirect sources such as air bubbles trapped in polar ice, or the study of fossils. This evidence, while interesting as a potential "reality check" for global anthropogenic climate change models, is considered far less reliable than direct observational data.

These limitations in our evidence make it difficult to draw hard and fast conclusions regarding what changes have actually occurred recently in comparison to past climate conditions. More importantly, these limitations make it difficult to determine whether those changes are beyond the range of previous climate trends, happening at a faster rate than previous climate trends, or are being sustained for longer than previous climate trends, all critical questions when evaluating whether humanity is causing changes to Earth’s normal climate patterns.

Nevertheless, we do have evidence at hand regarding recent changes in both atmospheric composition and global climate trends that suggest that humanity has at least changed the Earth’s atmospheric composition in regard to greenhouse gases and other pollutants, which may, or may not, be contributing to recently observed changes in global warmth. A quick review of the climate changes which are suggested by the available evidence follows.

1. Temperature Trends

Besides readings of Earth’s surface temperatures taken with standard glass thermometers, direct readings of atmospheric temperatures have been taken with satellites and weather balloons. In addition to the direct measurements of the Earth’s recent temperatures, proxy measurements of temperatures from farther in the past can be derived from bore-hole temperature measurements, from historical and physical evidence regarding the extent and mass of land and sea ice, and from the bleaching of coral reefs.

This information is in relatively good agreement regarding what seems to be happening to global temperatures, at least in the recent periods of change spanning the last few hundred years, though there are discrepancies between some of the data sets. According to the IPCC, temperatures recorded at ground-based measuring stations reveal a mean warming trend ranging from 0.3 ° C to 0.6 ° C since about 1850, with 0.2 – 0.3 ° C of this warming occurring over the last 40 years. The warming is not uniform, either in chronology or distribution. More of the change occurs over land than over water. More of the warming happens at night, resulting in warmer night-time temperatures, rather than hotter daytime temperatures. More of the warming is noticeable as a moderation of wintertime low temperatures, rather than as an increase in summertime high temperatures. Temperatures taken from weather balloons (also called radiosondes) and from satellites span a much shorter period of time (though arguably, a more rigorously standardized measuring technique), and there is controversy over what they indicate, and how much weight should be given to such a short data set. Some analysts contend that the satellite and balloon recordings show a slight cooling trend in the tropics (about 0.10 ° C/decade) over the last 18 years, while others contend that the discrepancy is only an artifact caused by a limited data set, and the recent, unrelated increase in the strength of the El Niño Southern Oscillation.

And even here, taking the simplest of physical measurements, uncertainties are present. Temperature readings (satellite or ground station) were not taken specifically for the sake of evaluating the climate patterns of the entire Earth. Consequently, the readings were taken from a variety of locations, cover only selected parts of the atmosphere, and are not necessarily well-placed to be most informative about the climate as a whole. Further, measurement techniques and stations varied over the course of the temperature record, with data adjustments of a full degree occasionally needed to make the different sets of data compatible with each other. Satellites and balloons measure a different part of the atmosphere than ground stations do, making the comparability of such records questionable, and the shortness of the satellite data record, punctuated as it has been by impacts of volcanic eruptions and the El Niño Southern Oscillation further complicate the evaluation of temperature data.

Some people interpret the observed changes of temperature as being evidence supporting the theory that human action has caused changes in the global climate. Others find the evidence regarding observed changes in temperature insufficient to allow a sound conclusion regarding the validity of that theory because of the historical volatility of climate variations. While the last 10,000 years have been abnormally placid as far as climate fluctuations go, evidence of prior climate changes show an Earth that is anything but placid, climatically. Some 11,500 years ago, for example, there is evidence that temperatures rose sharply over short periods of time. In Greenland, temperatures increased by as much as 7 ° C over only a few decades, while sea surface temperatures in the Norwegian Sea warmed by as much as 5 ° C in less than 40 years. There is also evidence of about 20 rapid temperature fluctuations during the last glaciation period in the central Greenland records. Rapid warmings of between 5 and 7 ° C were followed by slow returns to glacial conditions over the course of 500 to 2000 years. In interpreting current climate changes, the broadest view of past climate changes lends important perspective.

2. Precipitation Trends

Changes in precipitation trends are, potentially, a form of indirect evidence reflecting whether the Earth is currently experiencing man-made climate change. As the IPCC report observes, "an enhanced greenhouse effect may lead to changes in the hydrologic cycle, such as increased evaporation, drought, and precipitation." But the section on precipitation changes as an indirect measure warns that "our ability to determine the current state of the global hydrologic cycle, let alone changes in it, is hampered by inadequate spatial coverage, incomplete records, poor data quality, and short record lengths."

According to the IPCC, the global trend in rainfall has shown a slight increase (about 1 percent) during the 20^th century, though the distribution of this change is not uniform either geographically or over time. Rainfall has increased over land in high latitudes of the Northern Hemisphere, most notably in the fall. Rainfall has decreased since the 1960s over the subtropics and tropics from Africa to Indonesia. In addition, some evidence suggests increased rainfall over the Pacific Ocean (near the equator and the dateline) in recent decades, while rainfall farther from the equator has declined slightly.

Global warming would also be expected to influence things like snowfall, snow depth, and snow coverage (or extent), but studies examining changes in such aspects of the climate are quite mixed. Consistent with the indications of slight warming of the global climate, snow cover has declined in recent years, with a higher percentage of precipitation in cold areas coming down as rain, rather than snow. But while the annual mean extent of snow cover over the Northern Hemisphere has declined by about 10 percent over the past 21 years of study, snowfall levels have actually increased by about 20 percent over northern Canada, and by about 11 percent over Alaska. Between 1950 and 1990, snowfall over China decreased during the 1950s, but increased during the 1960s and 1970s. Snowfall over the 45–55 degree latitude belt has declined slightly. Snow depth levels, which respond both to atmospheric temperature and to the ratio of rainfall to snowfall show equally mixed changes. Snow-depth measurements of the former Soviet Union over the 20^th century show decreased snow depth of about 14 percent during the Soviet winter, mostly in the European portion of the ex-Union, while snow depth in the Asian sectors of the former Soviet Union has increased since the 1960s.

3. Ice and Sea Level Trends

Changes in sea level and the extent of ice sheets, sea ice, and polar ice caps are still another form of indirect evidence reflecting whether the Earth is currently undergoing anthropogenic climate change. Climate change theory would suggest that rising global temperatures would cause sea levels to rise due to a combination of the thermal expansion of water and melting of glaciers, ice sheets, ice caps, and sea ice.

Recent studies of sea levels alone indicate a rise of 18 cm over the last 100 years, with a range of uncertainty of 10–25 cm, though there is little evidence that the rate of sea level rise has actually sped up during that time period, in theory, the rate of warming has been accelerating.

But thermal expansion of water is only one contributor to sea level changes. Glaciers, ice sheets, and land water storage all play a role—a highly uncertain role.

The IPCC sums up the changes in water level trends this way: "The current estimates of changes in surface water and ground water storage are very uncertain and speculative. There is no compelling recent evidence to alter the conclusion of IPCC (1990) that the most likely net contribution during the past 100 years has been near zero or perhaps slightly positive, with an uncertainty of about +/- 6 cm."

With regard to glaciers and ice caps, the state of knowledge is even more limited: Glaciers and ice caps may have accounted for 2-5 cm of the observed sea level rise, but the range of uncertainty is high. Finally, with regard to ice sheets, data are contradictory: there is not enough evidence to know whether the Greenland and Antarctic ice sheets are shrinking, hence contributing to sea level rise, or growing, and hence retarding sea level rise. They may even be doing both, growing on top, and shrinking at the margins.

The IPCC report sums up the situation thus: "In total, based on models and observations, the combined range of uncertainty regarding the contributions of thermal expansion, glaciers, ice sheets and land water storage to past sea level change is about –19 cm to +37 cm."

4. Extreme Weather Intensity or Variability Trends

Finally, increases in the intensity or variability of weather is considered another form of indirect evidence reflecting whether the Earth is currently undergoing anthropogenic climate change.

Predictions of increased incidences of extreme temperatures, tornadoes, thunderstorms, dust storms and fire weather have been drawn from basic global anthropogenic climate change theory.

Figure 2: Summary of Temperature and Hydrological Changes

Source: IPCC, Figure 3.22, p. 180.

But evidence has not, so far, borne out these predictions on a global scale. The IPCC concludes that:

...overall, there is no evidence that extreme weather events, or climate variability, has increased, in a global sense, through the 20^th century, although data and analyses are poor and not comprehensive. On regional scales, there is clear evidence of changes in some extremes and climate variability indicators. Some of these changes have been toward greater variability; some have been toward lower variability.

5. Summary of Climate Changes

As Figure 2 indicates, evidence regarding changes in Earth's climate in the 20^th century is mixed, and encompasses a range of uncertainties.

While the IPCC report holds that there is a discernible human influence on climate, this conclusion is not dependent on the evidence of actual changes in the Earth’s climate as shown in this Figure. On that note, the IPCC says, "Despite this consistency [in the pattern of change], it should be clear from the earlier parts of this chapter that current data and systems are inadequate for the complete description of climate change." Rather, this conclusion is based on mathematical modeling exercises and "reality checked" with what hard evidence we have. The IPCC sums up the question of attributing observed climate changes to human action, thus: "Although these global mean results suggest that there is some anthropogenic component in the observed temperature record, they cannot be considered as compelling evidence of a clear cause-and-effect link between anthropogenic forcing and changes in the Earth’s surface temperature."

Part 5

Uncertainty and Future Research Needs

While recent studies of climate have contributed a great deal to our understanding of climate dynamics, there is still much to learn. The process of searching for evidence of man-made climate change, in fact, is both a search for new discoveries about how climate works, and continuing refinement of our understanding of the underlying theories we already have.

Many areas of uncertainty remain. Current climate change models have acknowledged weaknesses in their handling of changes in the sun’s output, volcanic aerosols, oceanic processes, and land processes which can influence climate change.

Some of those uncertainties are large enough, by themselves, to potentially become the tail which wags the dog of climate change theory. Three of the major uncertainties which remain are discussed below.

The Natural Variability of Climate

Despite the extensive discussion of climate modeling and knowledge of past climate cycles, only the last 1000 years of climate variation are included in the two state-of-the-art climate models referred to by the IPCC. As discussed earlier, however, the framework in which we view climate variability makes a significant difference in the conclusions we draw regarding either the comparative magnitude or rate of climate changes, or the interpretation of those changes as being either inside or outside of the envelope of normal climate change variations. The IPCC report summarizes the situation succinctly:

Large and rapid climatic changes occurred during the last ice age and during the transition towards the present Holocene period. Some of these changes may have occurred on time-scales of a few decades, at least in the North Atlantic where they are best documented. They affected atmospheric and oceanic circulation and temperature, and the hydrologic cycle. There are suggestions that similar rapid changes may have also occurred during the last interglacial period (the Eemian), but this requires confirmation. The recent (20^th century) warming needs to be considered in the light of evidence that rapid climatic changes can occur naturally in the climate. However, temperatures have been far less variable during the last 10,000 years (i.e., during the Holocene).

Until we know which perspective is more reflective of Earth’s climate as a whole—the last 10,000 years, or a longer period of time—it will be difficult to put recent warming trends in perspective, or to relate those trends to potential impacts on the climate, and on the Earth’s flora and fauna.

2. The Role of Solar Activity

At the front end of the climate cycle is the single largest source of energy which is put into the system, namely, the sun. And while great attention has been paid to most other aspects of climate, little attention has been paid to the sun’s role in the heating or cooling of the Earth. Several recent studies have highlighted this uncertainty, showing that solar variability may play a far larger role in the Earth’s climate than it was previously given credit for by the IPCC. If the sun has been heating up in recent times, researchers observe, the increased solar radiation could be responsible for up to half of the observed climate warming of the past century. Astrophysicist Sallie L. Baliunas attributes up to 71 percent of the observed climate warming of the past century to increased solar irradiance. Other researchers such as climatologist T.M.L. Wigley, however, rank the influence of solar activity on climate warming much lower, at "somewhere between 10 percent and 30 percent of the past warming." But as with satellite measurements of Earth’s temperature, the short time line of satellite measurements of solar irradiance introduces significant uncertainty into the picture. Most researchers believe that at least another decade of solar radiation measurement will be needed to clearly define the influence of solar input on the global climate.

3. Clouds and Water Vapor

Between the emission of greenhouse gases and change in the climate are a range of climate and biological cycles that can influence the end-result. Such outcome-modifier effects are called "feedbacks" or "indirect effects" in the climate change literature.

One such feedback is the influence of clouds, and water vapor. As the climate warms, more water vapor enters the atmosphere, but how much? And, which parts of the atmosphere, high or low? And how does the increased humidity affect cloud formation? While the relationship between clouds, water vapor, and global climate is complicated in and of itself, the situation is further complicated by the fact that aerosols exert a poorly understood influence on clouds. Earlier computer models, which omitted the recently validated cooling effect of aerosols, overestimated the global warming that we would have expected to see by now, based only on the levels of greenhouse gases which have been emitted. As discussed earlier, aerosols themselves may offset 20 percent of the expected impact of warming gases. In addition, though direct cooling impacts of aerosols are now being taken into account by climate models, aerosol impact on clouds remains a poorly defined effect with broad implications, given a range of additional cooling potential of up to 61 percent of the expected warming impact from the warming greenhouse gases.

As the IPCC report acknowledges: "the single largest uncertainty in determining the climate sensitivity to either natural or anthropogenic changes are clouds and their effects on radiation and their role in the hydrological cycle…At the present time, weaknesses in the parameterization of cloud formation and dissipation are probably the main impediment to improvements in the simulation of cloud effects on climate."

4. The Impacts of Climate Change

As discussed earlier, the crux of the debate over climate change is not the question of direct changes in average global temperatures, but centers on the second- and third-hand effects of that change. One need not wade far into the IPCC’s 880-page volume on the potential impacts of climate change, however, before encountering an admission that uncertainty dominates any discussion of such potential impacts.

Impacts are difficult to quantify, and existing studies are limited in scope. While our knowledge has increased significantly during the last decade and qualitative estimates can be developed, quantitative projections of the impacts of climate change on any particular system at any particular location are difficult because regional scale climate change projections are uncertain; our current understanding of many critical processes is limited; and systems are subject to multiple climatic and non-climatic stresses, the interactions of which are not always linear or additive. Most impact studies have assessed how systems would respond to climate changes resulting from an arbitrary doubling of equivalent atmospheric carbon dioxide concentrations. Furthermore, very few studies have considered greenhouse gas concentrations; fewer still have examined the consequences of increases beyond a doubling of equivalent atmospheric carbon dioxide concentrations, or assessed the implications of multiple stress factors.

The IPCC report goes on to point out that this extreme uncertainty is likely to persist for some time, since unambiguous detection of man-made climate change hinges on resolving many difficult problems.

Detection will be difficult and unexpected changes cannot be ruled out. Unambiguous detection of climate-induced changes in most ecological and social systems will prove extremely difficult in the coming decades. This is because of the complexity of these systems, their many non-linear feedbacks, and their sensitivity to a large number of climatic and non-climatic factors, all of which are expected to continue to change simultaneously. The development of a base-line projecting future conditions without climate change is crucial, for it is this baseline against which all projected impacts are measured. The more that future climate extends beyond the boundaries of empirical knowledge (i.e., the documented impacts of climate variation in the past), the more likely that actual outcomes will include surprises and unanticipated rapid changes.

Uncertainties of this scale do not imply, as some analysts have asserted, that there is no reason to fear negative change, nor does it imply that we must fear drastic impacts. Rather, uncertainties of this scale indicate the need for a sustained research program aimed at clarifying our understanding of Earth’s climate, and how human activities might or might not translate into negative environmental impacts.

Part 6

The Role of Consensus and Evidence in Science and Public Policy

The debate over national climate change policy exemplifies an increasingly frequent rhetorical approach of media and political figures involved in the handling of scientific issues in public policy debate: the inappropriate assertion that scientific issues can be resolved by reference to lists of scientists—not necessarily trained in the subject at hand, or involved in research about that subject—who are willing to attest to their belief one way or another regarding the certainty of a scientific theory.

The argument of EPA administrator Carol Browner, for example, comes down to: I’m not a scientist, but we have a list of 2,500 scientists who say this is a serious problem. In the meantime, those arguing against urgent action wave their own list of 4,000 scientists in opposition.

But both approaches are inappropriate for evaluating evidence in a scientific framework. The degree of certainty surrounding a scientific issue is not decided by the number of scientists willing to make broad statements of their belief, nor by celebrity endorsements, nor by the repeated sound-bites of politicians or political appointees. It’s decided by the weight of evidence, issue by issue, and nothing more.

While politics might be a numbers game, science is not. As commentator Ted Koppel put it so eloquently: "The measure of good science is neither the politics of the scientist nor the people with whom the scientist associates. It is the immersion of hypothesis into the acid of truth." The rightness or wrongness of a scientific theory is not determined by the speaker’s fame, majority rule, or celebrity endorsement, but by the ability of an idea to withstand challenges in an open process of inquiry in which validation is based on the weight of evidence interpreted according to the rules of inquiry that we call Science.

Violating this process of inquiry with inappropriate use of "consensus" to stifle debate can lead to some torturous justifications for drastic actions. Earlier in this century, for example, Italian philosopher Benedetto Croce used the same "decision by consensus" reasoning to defend the Inquisition, saying: "The inquisition must have been justified and beneficial, if whole peoples invoked and defended it, if men of the loftiest souls founded and created it severally and impartially." Such a rationale was wrong then, and it’s wrong now.

While the consensus of high-profile scientists can give an issue a certain cachet, we should remember that before each new theory emerges, the majority of scientists or experts believe something else, and that belief is wrong. Before Copernicus gave us a sun-centered solar system, most scientists thought we had an earth-centered solar system. Before the Wright brothers flew at Kittyhawk, most aeronautic experts thought that heavier-than-air craft would never fly. Before Darwin defined evolution, most biologists believed in the inheritance of acquired characteristics. This is, in fact, the heroism of science—that individual scientists go on to make new discoveries precisely because they are unwilling to accept what "most scientists" think is the end of the story.

In the climate change discussion, the process of inquiry is still, in many respects, in its infancy. While we know some things, many relevant questions still remain unanswered. Our best tool for the resolution of these questions is science and a scientific evaluation of evidence. These tools may not rest well with those in a policy process that wants fast answers to complex questions, but they are the tools we have.

Part 7

About the Author

Dr. Kenneth Green is Director of Environmental Studies and Senior Policy Analyst at the Reason Public Policy Institute. Dr. Green has published five previous studies on air quality policy: Looking Beyond ECO, Defending Automobility, Checking Up on Smog Check, Rethinking EPA's Proposed Ozone and Particulate Standards, and Estimating Fatalities Induced by Economic Impacts of EPA's Proposed Ozone and Particulate Standards (co-authored). Green received his doctorate in environmental science and engineering (D.Env.) from UCLA in 1994.

Policy Study No. 237, December 1997

Table of Contents

Why a Plain English Guide?

Global Warming Theory

Climate Change Theory

Atmospheric Changes

1. Carbon Dioxide

2. Methane

3. Nitrous Oxide

4. Chlorofluorocarbons

5. Aerosols

6. Summary of Atmospheric Changes

Climate Changes

1. Temperature Trends

2. Precipitation Trends

3. Ice and Sea Level Trends

4. Extreme Weather Intensity or Variability Trends

5. Summary of Climate Changes

Uncertainty and Future Research Needs

1. The Natural Variability of Climate

2. The Role of Solar Activity

3. Clouds and Water Vapor

4. The Impacts of Climate Change

The Role of Consensus and Evidence in Science and Public Policy

About the Author