TCS Daily

From Garden State to Greenhouse State

By Roy Spencer - October 22, 2004 12:00 AM

The state of New Jersey's Department of Environmental Protection appears to be following in the steps of California, ready to classify carbon dioxide as a pollutant in anticipation of future regulation of its production within the state. Carbon dioxide is the second most important "greenhouse gas", after water vapor, that helps keep the Earth habitable by retaining infrared (heat) radiation and warming the Earth. This is a natural process that occurs with or without help from humans. Additionally, life on Earth depends on carbon dioxide, which is used by the biosphere for food. The concern is that the extra CO2 produced by burning petroleum, coal, and natural gas will cause the climate system to react in negative ways.

As is the case for any proposed policy change based upon science, one must evaluate the confidence in that science, as well as the total societal impact of the policy change. In their proposal for this new rule, the New Jersey Department of Environmental Protection clearly states that,

"prior to regulating CO2 as an air pollutant, the Department would need to make a formal determination and advise the public that regulating CO2

is in the best interest of human health, welfare, and the environment".

Their reasoning draws heavily from scientific reports from the U.N. Intergovernmental Panel on Climate Change, the U.S. National Research Council, and the U.S. State Department, and the EPA. All of these reports and assessments rely on computerized climate model simulations that estimate how the Earth's climate will change with increasing carbon dioxide concentrations in the coming century.

While the language of the proposed change mentions (1) what we (think we) know about the science, and (2) what the negative societal impacts of potential global warming are, it conveniently downplays or omits (3) the many uncertainties in the science, and (4) the negative impacts on society from the cost increases for goods and services that will result from regulating carbon dioxide.

In light of the negative economic, and therefore societal, consequences of regulating the production of CO2, here are a few reasons New Jersey's regulatory course of action needs to be critically examined.

First, about all science knows is that CO2 is necessary for life (primarily by the biosphere, and therefore by humans), that its atmospheric concentration has increased from about 0.025% to 0.038% in the last hundred years due to mankind's use of fossil fuels. The increase would have been twice as large if not for the fact that vegetation has been feasting on the extra CO2. We are reasonably confident that the average temperature of the Earth's atmosphere has increased by as much as 1 degree F during the same period of time. But, it is not known how much of this warming has been due to the CO2 increase, as it happens to coincide with the exit from the "Little Ice Age" of the previous few centuries. So many climate researchers simply assume it is due to the increased levels of carbon dioxide.

Second, climate models can only crudely estimate what the atmosphere might do in the future based upon our current understanding of climate change, and our assumptions about how much fossil fuel will be used in the coming decades. We still have little understanding of how clouds, precipitation systems, the ocean, or the biosphere might help stabilize climate. The climate system goes through natural oscillations, which inherently implies stability (otherwise, the climate would run away to increasingly warm or cool conditions). In contrast, it has taken many years of work to keep climate models from drifting toward unrealistic climate states. This suggests that climate models are not as stable as nature is, and will tend to drift away from stability if they are exposed to (for instance) increased concentrations of carbon dioxide. Nevertheless, it is common for scientists to emphasize what they know (or think they know) over what they don't. Ultimately, people tend to form their own beliefs about how stable or fragile the Earth is, which then tends to dominate their thinking about how serious global warming will be. This includes the protagonists of climate model predictions.

On the policy side of the equation, in order to determine whether "regulating CO2 is in the best interest of human health, welfare, and the environment", wouldn't it be necessary to determine the negative impacts of that regulation as well? Failure to do so would add up to the classic, mindless application of the precautionary principle, wherein if something we do has the potential of negative consequences, then it should be avoided. But we don't live our lives abiding by this principle....why should we allow regulations to mandate it? All human decisions involve risks and benefits, and the known, obvious benefits of inexpensive energy to the health and welfare of society should not be sacrificed lightly based upon theories about how climate might change in the future. Costs of virtually all goods and services will rise as carbon dioxide production is regulated simply because energy is needed for everything we do. This will impact the poor the most, those who are already living on the economic margin.

The proposed New Jersey amendments to their rules quote the state definition of "air pollution". I would like to modify that definition slightly, and propose a similar definition of "excessive regulation". "Excessive regulation means the presence in society of one or more regulations in such quantities and duration as are, or tend to be, injurious to human health or welfare, animal or plant life, or property, or would unreasonably interfere with the enjoyment of life or property throughout the state and in those areas of the state as shall be affected thereby...". Maybe in addition to environmental regulation, California and New Jersey need to have a "Department of Regulations Regulation".


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