EPA Holds Listening Sessions on Carbon Regulations – But Who Are They Listening To?

The EPA recently held 11 sessions for public input on the agency’s new rules to restrict carbon emissions from existing power plants. While large coal interests and major labor unions were represented, the vast majority of attendees represented environmental advocacy groups (or themselves) and favored regulation. Some might suggest that this indicates broad support for strict emissions targets – I’m not so sure. For one, environmental organizations tend to have small groups of constituents and narrow donor bases. While some, such as the World Wildlife Fund, maintain a large number of members, the bulk are small operations. Tactics vary dramatically at these events–regulation advocates tend to show up en masse, emptying the organization’s offices to demonstrate a strong presence. Opposition groups, such as the coal industry, the Chamber of Commerce, and impacted labor unions focused on manufacturing, tend to send one individual to represent all their members.

Additionally, as noted by AAF (and pointedly mentioned by several speakers at the event), the agency neglected to hold listening sessions in major coal-producing areas. This may be excusable – it is likely the agency held sessions at large existing offices for convenience –but it has the effect of downplaying the interests of those most directly impacted by the regulations. There is a location bias favoring environmental organizations as well as one punishing coal interests. Sessions were held predominantly in large cities on workdays, making it difficult, if not impossible, for miners or power-plant workers to attend.

Given these broader influences, we can move on to specifics. I attended the D.C. listening session two weeks ago and was able to observe the representatives of the public first-hand. Notable attendees included:

  • A man in an Albert Haynesworth Redskins jersey, which I can only assume was a subtle protest against wasteful spending and poor decision-making
  • A man who sang his testimony (several minutes worth), including lyrics implying that we might never hear birds again (he favored regulation)
  • A photographer with several pictures of Polar Bears and a long story about how great they are. Apparently they’re a lot like dogs and can play fetch – news to me, as I, like most people, can’t afford to hang out with Polar Bears
  • Multiple individuals with children, used as props for a never-ending stream of ‘what will our children think if we don’t act now’ arguments

It’s sort of touching to see small children ask for the EPA’s help, even if their parents obviously put them up to it. Unfortunately their logic is a bit childish: they argue that, because climate change will have a much larger impact on later generations, we have a moral duty to act now. Sounds reasonable, but there’s another side to it: won’t our children also want to a continually rising standard of living? I expect so. The burden is on advocates of regulation to prove that the benefits of action, calculated using reasonable assessments of risk, will exceed the costs, both to present and future generations. It’s a higher burden of proof than most climate activists (and their children) realize.

So, let’s think about risk. I admit that I’ve been focusing on particularly extreme supporters of regulation so far, but I think we can all agree on several general facts: global warming is real, humans cause it, it will have a negative impact and, finally, carbon emissions contribute to it. However, all of this does not mean that regulation is the obvious solution. The issue with all regulations is striking a sensible balance between risks and costs. For example: it is possible to eliminate all risk of car accidents. We’d simply have to ban cars (and busses and trucks and any other large, wheeled vehicle). Clearly no agency would suggest this–the costs exceed the benefits.

While scientific evidence demonstrates that global warming is real, it isn’t so clear what the precise impact will be. Spending too much time with rabid environmentalists can skew one’s perception of the actual range of potential damage estimates. In a perhaps related point, a surprisingly large number of religious figures were also represented at the D.C. listening session, all favoring regulation. One speaker (representing herself) suggested that the film Deep Impact might actually happen if regulations are not considered. Needless to say, not even the most zealous climate scientists have suggested anything near this level of damage. You wouldn’t know that from supporters’ rhetoric.

It’s good that the EPA is taking time to listen to people’s concerns. I worry, however, that they’re spending too much time listening to the wrong people. If all you hear is hyperbole, you might start to believe crazy things, or at least start to consider the crazy things to be a valid perspective.