17 Jun 2008
Carbon Taxes and Auctions:
What to do with $7 trillion, part 2
by Richard Belzer
in Regulatory Economics, Regulatory Policy, Legislation
In a story summarizing an in depth interview with Sen. Barack Obama, Wall Street Journal reporters Bob Davis and Amy Chozick provide news insights concerning how he or Sen. John McCain would propose to spend trillions of dollars in new government revenue that would be collected by auctioning carbon emission allowances. More...
1 Feb 2008
Objectivity in Risk Assessment:
The National Intelligence Estimate on Iran, Part 4
by Richard Belzer
in Regulatory Policy, Regulatory Science
The subject of the 2007 National Intelligence Estimate of Iran's nuclear weapons program is not the dominant subject of news reporting that it was when we first posted on it. However, a conventional narrative has developed to the effect that Iran's nuclear ambitions and developmental efforts are no longer a legitimate concern.
Today we hope to finish our series on this subject showing why this narrative is based on value-based preferences that various people and interest groups hold, and is not supported by the NIE itself.
More...
6 Dec 2007
Objectivity in Risk Assessment:
The National Intelligence Estimate on Iran, Part 3
by Richard Belzer
in Information Quality, Regulatory Policy
The web is chock full of commentary on the recently released summary of the National Intelligence Estimate on Iran. (We emphasize summary because the body of the NIE remains classified.) We've posted here and here on the NIE as a risk assessment document, noting that it claims to be an objective assessment not confounded by risk management (i.e., policy or political) concerns.
We've read much (but by no means all) of this news and commnetary and drawn some inferences we hope are useful. More...
4 Dec 2007
Objectivity in Risk Assessment:
National Intelligence Estimate of Iran's Nuclear Weapons Program
by Richard Belzer
in Regulatory Science
An unusual example of risk assessment appeared today in the news: the disclosure of an unclassified summary of the November National Intelligence Estimate (NIE) concerning Iran's nuclear weapons program. The document, which for obvious reasons is not transparent and reproducible, nevertheless is remarkably clear about the uncertainties which underlie its estimates. More...
19 Sep 2007
OMB's Principles for Risk Analysis:
OMB's initial response to the National Academy of Sciences
by Richard Belzer
in Regulatory Policy, Regulatory Science
Today the Office of Management and Budget issued a memorandum to agency heads directing them to adhere to certain principles of risk analysis. The memorandum is OMB's initial response to the report of a National Research Council panel that OMB asked to review a 2006 proposed bulletin on risk assessment. That report called the proposed text "fundamentally flawed" and gave seven recommendations, one of which was that it be withdrawn.
A fair reading of the new memorandum is that OMB followed this specific recommendation. More...
21 May 2007
Comprehensive Immigration Reform:
Text of the Secure Borders, Economic Opportunity and Immigration Reform Act of 2007
by Richard Belzer
in Legislation, Regulatory Policy
Earlier today we posted a comment on the comprehensive immigration bill that was negotiated by the Bush administration and selected Members of Congress. A Google News search yields over 3,000 hits, but the bill itself has not been published for public review. That makes regulatory analysis impossible, yet advocates were seeking passage this week.
Through the courtesy of Wall Street Journal reporter John Fund, who published a commentary this morning on the bill and unearthed the text, we now have a copy of the discussion draft of the bill.
Readers should beware: the text is 326 pages. More...
11 May 2007
Government-wide Information Quality Guidelines:
Does journal peer review achieve "adequate" objectivity?
by Richard Belzer
in Glossary, Information Quality, Peer Review
Federal guidelines require information disseminated by federal agencies to satisfy a few broad criteria, one of which is objectivity. These guidelines give a "rebuttable presumption" to scientific information published in scholarly journals.
- Do all scholarly journals transmit this rebuttable presumption of objectivity? What about scholarly journals that also have an advocacy mission?
- What is the burden of proof for mounting a successful rebuttal?
More...
9 May 2007
Federal Agency Guidance Documents:
What's "significant"?
by Richard Belzer
in Regulatory Policy
OMB has new procedures for agencies to follow in making significant guidance documents transparent.
We posted an extensive discussion on OMB's Bulletin on Good Guidance Practices, and recently OMB issued an implementation memorandum. Yesterday we commented on the first task facing federal regulatory agencies: assembling and publishing online lists of guidance documents.
Today we address another fundamental question: What constitutes a "significant" guidance document, an d how is this determination made? More...
8 May 2007
Federal Agency Guidance Documents:
Building the inventory
by Richard Belzer
in Regulatory Policy
Executive Order 13422 and OMB's Bulletin on Good Guidance Practices will lead to major changes in the way federal agencies issue guidance.
The first step for each agency is to develop and publish inventories of their significant guidance documents. The deadlines for agency compliance are July 24, 2007 (for significant guidance documents issued on or after January 25, 2007) and August 23, 2007 (for all significant guidance documents). More...
7 May 2007
The New OMB Regulatory Review Procedures:
A primer on implementation
by Richard Belzer
in Regulatory Policy
On April 25 OMB issued guidance to agencies concerning the implementation of Executive Order 13422. More...
11 Mar 2007
The Continuing Battle Between CO2 Puritans and Pragmatists
An update on Al Gore's carbon neutrality
by Richard Belzer
in Regulatory Economics
In July 2006, we posted an article in response to news stories about a speech former vice president Al Gore delivered at the Chautaqua Institution. According to Associated Press reporter Carolyn Thompson, Gore's "conscience is regularly challenged by a consumerism that contributes to the global warming he has made it his mission to reverse. After saying that he and his wife, Tipper, had adopted a "carbon neutral" lifestyle, he acknowledged that it was a difficult thing to do. " 'We've fallen into this pattern of consuming more and more and more and I'm part of it, I understand,' he said."
We were intrigued by the acknowledgment of personal responsibility in the news article (the speech itself does not appear to be online. So we did some research and learned that there is no generally accepted definition of "carbon neutrality." Nevertheless, the but the premise is simple. For every ton of carbon dioxide you emit, whether directly by your actions or indirectly by your consumption decisions, you undertake a compensating action or consumption decision that reduces carbon dioxide emissions by the same amount. In principle, your ledger of carbon debits would equal your ledger of carbon credits.
It's a pragmatic personal response to global warming that enables individuals to choose the optimal mix of actual CO2 reductions they want to make and how much cash they are willing to forgo instead. This is the standard economic theory prescription for solving a host of public policy problems that are defined by the existence of a negative externality in which the market price of an activity does not capture the full social cost.
We provided links to several nonprofit organizations that sell "carbon offsets" to people who want to mimic Gore's pragmatic approach. We noted that there are many other environmentalists who are highly critical of this pragmatic approach to global warming abatement. In their view, only actual reductions in CO2 emissions are legitimate and purchasing carbon offsets is not. We described this argument as being between CO2 Pragmatists and CO2 Puritans. The pragmatists are happy paying others to reduce greenhouse gas emissions on their behalf. It is no more a moral issue than paying someone else to mow the lawn. For CO2 Puritans, however, everyone must make a personal sacrifice in lifestyle, to personally share in the burden of reducing greenhouse gas emissions even if that means reducing energy consumption by (say) 60%.
The subject arose again in August when Peter Schweitzer published a commentary in USA Today claiming that Gore's professed carbon neutrality was hypocritical. Schweitzer was raising the banner of the CO2 Puritans (though it seems unlikely that he is one) because Gore had not actually reduced his "carbon footprint" in a manner consistent with his policy recommendations. Schweitzer's objections appear to have focused on the apparent disconnect between Gore's actions (which befit a CO2 Pragmatist) and his moralist rhetoric (which often tends toward CO2 Puritanism). Indeed, there is a significant disconnect between moral issues and economic remedies such as carbon offsetting, which are unambiguously amoral.
We were curious how well Gore was doing as a CO2 Pragmatist, so we posted an article estimating, based on limited information, what it required of the Gores to achieve a pragmatic form of carbon neutrality. For residential carbon-neutrality, we calculated that an annual payment of about $2,400 to one of these nonprofits would be sufficient, and noted that such an expenditure should not be a burden for Gore. For air-travel carbon neutrality, we used the conservative assumption that Gore's private air travel utilized an aircraft as fuel efficient as a Piper Seneca V. [A commenter doubts that Gore travels by Seneca V or its equivalent because it's a non-pressurized piston-driven aircraft. He also says corporate jets carrying 8 to 30 people burn 320 to 385 gallons per hour versus the 22 gph for the Seneca V. These changes would significantly increase our rule of thumb estimate of CO2 emissions from private aircraft, and of course, Gore's carbon footprint from air travel and the cost of carbon offsets necessary to neutralize it.]
Gore's carbon footprint is back in the news since the Tennessee Center for Policy Research distributed a press release containing actual electricity and natural gas consumption for the Gores' Nashville home. Subsequently, the political aspects of the story have been covered more than adequately.
Now that that aspect of the story has died down, we use it to address -- again -- the dispute between CO2 Puritans and CO2 Pragmatists. This dispute has serious ramifications for public policy on global climate change.
14 Feb 2007
Executive Order 13422, Part 5a
The House subcommittee oversight hearings
by Richard Belzer
in Regulatory Policy
Today we start a series summarizing the testimony from all eight witnesses who appeared yesterday before two separate House oversight subcommittees. More...
13 Feb 2007
Executive Order 13422, Part 4b
An update on today's congressional hearings
by Richard Belzer
in Regulatory Policy
The previously scheduled joint subcommittee hearing has been split into a back-to-back marathon double hearing. See our event record for links to witness testimony.
The full witness list is below.
| Committee | Administration Witnesses |
Majority Witnesses |
Minority Witnesses |
| Science |
Sally Katzen David Vladeck Rick Melberth |
William Kovacs | |
| Judicary | Steven D. Aitken |
Curtis W. Copeland Sally Katzen Peter L. Strauss |
Paul R. Noe |
More...
8 Feb 2007
Executive Order 13422, Part 4
Partisan opposition erupts
by Richard Belzer
in Regulatory Policy
We thought we'd finished discussing Executive order 13422, President Bush's recent amendment to the Clinton-era Executive order on centralized regulatory review.
On Tuesday, February 13, a pair of House subcommittees will hold a hearing to criticize the Executive order.
More...6 Feb 2007
Good Guidance Practices
Definitions, requirements, and consequences
by Richard Belzer
in Regulatory Policy
On January 18, the Office of Management and Budget issued final
government-wide guidance on the issuance of guidance in lieu of
rulemaking. OMB's Bulletin for Agency Good Guidance Practices is
rich with content. Today we begin a series intended to educate the
public about this Bulletin and its implications for regulatory policy
and process.
More...
