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EPA Proposed Auto-Rule: What We Said At The Agency’s Zoom Meeting Today


Today and tomorrow, the Environmental Protection Agency (EPA) is organizing a Zoom public meeting on the motor vehicle offered by the agency greenhouse gas emission standards for passenger cars and light trucks of model year 2023-2026. My colleagues Devin Watkins, Sam Kazman, Patrick Michaels and I each had their three minutes of fame.

Devin criticized the EPA for refusing to correct one of the “undeclared, untested, unverified or erroneous assumptions” identified by the agency’s Clean Air Scientific Advisory Council – irregularities and errors that inflate the benefits to the community. health of the collateral reductions of the proposed fine particulate matter rule (PM2.5) emissions.

Sam responded to the EPA’s restricted request for public comment on three stringent alternative emission standards, as well as the agency’s depreciation of safety risks resulting from austerity-induced reductions in vehicle weight and size. increasing regulatory.

Pat took issue with the proposal’s purported $ 91 billion climate benefits by 2050, noting that even under favorable assumptions, the standards would avoid between 0.001 ° C and 0.002 ° C of warming by mid-century, a effect far too weak to be detected or verified.

Rather than summarizing my spiel, I present it here:

My name is Marlo Lewis. I am a senior researcher in energy and environmental policy at the Competitive Enterprise Institute.

My comments relate to the EPA’s use of the social cost of greenhouse gases to estimate the net benefits of the rule proposed by the agency.

The EPA estimates that over the calendar years 2023-2050, the proposed greenhouse gas emission reductions will deliver $ 91 billion in climate change mitigation benefits.

These benefits are a mirage. Since 2010, the Interagency Working Group, or IWG, has selected assumptions and inputs to produce hugely inflated social cost estimates. The IWG averages the results of three integrated assessment models, two of which ignore the immense agricultural benefits of atmospheric carbon dioxide fertilization. The IWG relies on estimates of climate sensitivity derived from other models that project approximately three times more warming in the tropical atmosphere bulk than what has been observed over the past 40 years.

The most glaring methodological bias, however, is the selection by the IWG of the reference emission scenarios. Four of its baseline scenarios assume that coal will grow rapidly to become the world’s main energy source after 2050, with consumption continuing to rise until the 23rd.rd century.

These scenarios result in cumulative carbon dioxide emissions after 2100 far greater than the estimated fossil fuel reserves, as the Electric Power Research Institute highlighted in its 2014 technical review of the work of the IWG.

“To even approach” the massive cumulative emissions projected in the baselines of the IWG, professor at the University of Colorado Roger Pielke, Jr. explains, “The world should make it a political goal to burn as much coal as possible in the centuries to come. It seems unlikely.

Indeed, the procedure of the IWG is to take the 21st century forcing the trajectory called RCP8.5 then extend it until the year 2300.

As it is well known, RCP8.5 carbon dioxide emissions in 2050 are more than double the level projected by the International Energy Agency’s baseline emissions scenarios. RCP8.5 is no longer a plausible emission channel for the 21st century. There is no evidence that the world will “go back to coal” in the next eight decades, let alone the next 280 years.

The IWG’s social cost estimates are a methodological house of cards. Using these values ​​to estimate the net benefits of the proposed rule violates basic standards of scientific integrity.

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