by Richard Belzer

in Peer Review, Regulatory Science

Last week, unknown hackers broke into the computer at the University of East Anglia's (UK) Climate Research Unit, downloaded a trove of emails and other documents, then posted them on the web for all to see.

21 Nov 2009

Government as Competitor:
Eliminating the 'public option' produces a market

by Richard Belzer

in Regulatory Economics

Local governments across the country arte having to cut services to balance their budgets. Roanoke (VA) has cut curbside leaf collection, and the result is a vibrant private market.

13 Oct 2009

Cap and Trade, Part 5:
How Pigouvian taxes turn into mere revenue generators

by Richard Belzer

in Legislation, Regulatory Economics

Economic incentive schemes are popular among economists and increasingly embraced by legislators. Cap-and-trade to control greenhouse gas emissions is perhaps the most visible of these incentive schemes. Pigouvian taxes are the other, and news today from an unexpected source provides useful and interesting lessons in how such taxes can work -- and how they can degenerate into plain vanilla taxes.

10 Jul 2009

Conflating Risk Assessment and Risk Management:
The G-8 Communique on climate change

by Richard Belzer

in Regulatory Policy, Regulatory Science

The summer G8 meeting is over, and the press is reporting that leaders were unable to reach agreement on climate change. For example:

• Reuters: "G8 leaders failed to persuade India and China to join a push to cut greenhouse emissions by 50 percent by 2050," and "a G8 deal to reduce its greenhouse gas emission by 80 percent by 2050 was thrown into doubt within hours of being announced."
• Wall Street Journal: "The world's richest and its largest developing economies made a little progress in bridging the gaps that divide them Thursday, agreeing on the ultimate goal for climate change negotiations, and a relaunch of stop-start trade talks that have dragged on for eight years."
• New York Times: "The world’s biggest developing nations, led by China and India, refused Wednesday to commit to specific goals for slashing heat-trapping gases by 2050, undercutting the drive to build a global consensus by the end of this year to reverse the threat of climate change."

However, the G8 leaders were able to reach an agreement that scientists are in charge of climate change policy-making and that the benefits of mitigation far outweigh the costs.

7 Jul 2009

Cap and Trade, Part 3:
Waxman-Markey moves to the Senate

by Richard Belzer

in Legislation, Regulatory Policy

The Obama Administration's "cap and trade" bill to regulate greenhouse gas emissions (HR 2454, Waxman-Markey) has moved to the Senate, where the leadership hopes to have a bill ready to bring to the floor by September. The Washington Post reports that the bill is 15 to 20 votes short.

27 Jun 2009

Cap and Trade, Part 1:
Compensating tariffs or trade war?

by Richard Belzer

in Legislation, Regulatory Economics

The House leadership plans to amend Waxman-Markey to impose trade sanctions on countries that do not reduce greenhouse gas emissions. International adherence to effective restrictions is essential for the bill to have any effect on global emissions. However, trade sanctions would have the effect of significantly reducing international trade and protect energy-sensitive US industries and their workers from foreign competition. This amendment would compel other nations (chiefly China) to adhere to US emission standards if they want to continue exporting to the US. These nations likely would interpret such demands as trade restrictions impermissible under existing WTO agreements.

7 Jun 2009

Greenhouse Gas Endangerment Finding, Part 4:
Scientific causation

by Richard Belzer

in Regulatory Science

A careful look at parts of EPA's proposed endangerment finding show the causal chain that the Agency believes is scientifically sufficient. This causal chain has interesting implications for air pollution policy more generally.

5 May 2009

Greenhouse Gas Endangerment Finding, Part 3:
Distinguishing between 'public health' and 'welfare' effects

by Richard Belzer

in Regulatory Science

EPA's proposed endangerment finding asserts that greenhouse gas emissions from US mobile sources cause or contribute to public health harm. However, the Clean Air Act distinguishes between "public health" and "welfare." EPA proposes to count some welfare-related effects as public health effects.

1 May 2009

Greenhouse Gas Endangerment Finding, Part 2:
The mysterious disappearance of last year's advance notice of proposed rulemaking

by Richard Belzer

in Regulatory Policy

In July 2008, the Environmental Protection Agency published an advance notice of proposed rulemaking that raised numerous issues concerning the regulation of greenhouse gas emissions through the Clean Air Act.  Regulations.gov reports over 17,000 entries labeled as public comments.

In the April 2009 proposed endangerment finding, this ANPRM makes only a cameo appearance.

28 Apr 2009

Greenhouse Gas Endangerment Finding, Part 1:
EPA's technical support document

by Richard Belzer

in Regulatory Science

EPA's proposed endangerment finding for greenhouse gas emissions from motor vehicles relies on a small number of references, primarily this technical support document (TSD).

24 Apr 2009

Greenhouse Gases:
EPA proposes to regulate under the Clean Air Act

by Richard Belzer

in Regulatory Policy

Today, the Environmental Protection Agency proposed to use authority in Section 202(a) of the Clean Air Act to regulate US emissions of six greenhouse gases.

30 Mar 2009

Forecasting Economic Depression:
Illustrating the pitfalls of expert elicitation

by Richard Belzer

in Information Quality, Regulatory Science

In recent years there has been a notable increase in the use of expert elicitation in human health risk assessment. The method usually involves empaneling a group of experts and, through a carefully crafted and complex set of procedures, asking each panel member to provide a subjective probability that some phenomenon that cannot be directly observed is true or false. The Environmental Protection Agency has an informative external review draft white paper on the subject.

In environmental health, expert elicitation has been used to quantify the risk of cancer from drinking water disinfection byproducts, the likelihood that routine exposure to particulate matter in air causes premature mortality, and the magnitude of uncertainties related to climate change. Each is a tough scientific question. For example, the risk involved may be quantitatively small, and hence hard to discern, or the scientific uncertainties may be very large. Judgment is required, and the judgments of scientists inevitably reflect a mixture of scientific expertise and nonscientific opinion.

The need for discerning science from policy in expert judgment has been recognized for decades, at least since the 1983 National Research Council Red Book. No consensus yet exists concerning how to do this in practice. As a result, practitioners of expert elicitation typically acknowledge the problem but not much else. The EPA external review draft white paper mentioned above, for example, says that Agency technical support documents relying on expert elicitation should address "[p]ossible correlations with non-elicited components of the overall analysis or policy question" -- a phrase that, when translated into plain English, means the inflitration of experts' policy views into their characterization of science.

Today's Wall Street Journal has an example drawn from a very different arena -- macroeconomic forecasting -- that offers a wealth of insight about the problems with expert elicitation.

15 Mar 2009

Gray Wolves:
When does science end and policymaking begin?

by Richard Belzer

in Information Quality, Regulatory Policy, Regulatory Science

Washington Post environmental reporter Juliet Eilperin has a Page One story about Department of the Interior Secretary Ken Salazar's decision to ratify the Bush Administration's decision in December 2008 to delist the gray wolf as an endangered species in parts of the West.

His decision is controversial. Those who support it (including of course Secretary Salazar) say it was based on science. Those who oppose it say the Bush Administration's decision was based on politics and that Salazar should have changed it to reflect the policy views of the Obama Administration. One thing is clear: it is difficult to discern where science ends and policy begins with respect to decisions made under the Endangered Species Act.