Even as scientists are reporting a cooling of more than 2 degrees C in Antarctica over the last 35 years, 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: 
- 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:
- 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.
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.
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.
Dr. Kenneth Green is senior fellow at Reason Foundation and Chief Scientist at Frasier Institute.
 Peter T. Doran, et al., —Antarctic Climate Cooling and Terrestrial Ecosystem Response,— Letters to Nature, Nature (Online), January 13, 2001.
 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.
 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).
 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.
 Kenneth Green, —Exploring the Science of Climate Change,— Plain English Guide No. 3, (Los Angeles: Reason Foundation) August 2000.
 Kenneth Green, —Seeking Safety in a Dangerous World: A Risk-Reduction Framework for Policymakers,— —Policy Study No. 261 (Los Angeles: Reason Foundation) August 1999.