Maryland’s plan to address global warming is based on a
flawed process, which produced unreliable science.
The Greenhouse gas Reduction Act of 2009 requires Maryland
to reduce GHG emissions 20% from a 2006 baseline by 2020. Both the
GGRA
draft plan report and the
Maryland
Commission on Climate Change—the report on which the General Assembly
approved the GGRA—base their assessments and recommendations on the United
Nations Intergovernmental Panel on Climate Change. The final plan is due to the General Assembly in December.
However, The InterAcademcy Council, a multinational
organization of science organizations,
reviewed
the IPCC’s process and procedures* and
found serious flaws and problems, which cast serious doubt on the soundness and
reliability of “science” of the IPCC, and therefore the conclusions of the
Maryland’s climate commission and GGRA process.
The IAC found such problems as a lack of a formal process or
criteria for selecting authors, lack of a conflict of interest disclosure
policy, and problems with transparency.
Scientists from developing nations reported “frustration”
that their governments did not always appoint the best scientists and that “political considerations are
given more weight than scientific qualifications.”
Reviewer
comments were not adequately addressed by lead authors, in particular the fallacious statement in the IPCC’s 4th
Assessment Report stating that the Himalayan Glaciers could melt by 2035. It turns out the IPCC relied on a 2005 report
from the World Wildlife Fund, not peer-reviewed science. Alternative views were not cited in a chapter,
if “the Lead author does not agree with them.”
The IAC also found severe flaws
with how the IPCC handled issues of uncertainty and probability. For example, the IAC found:
Many
of the 71 conclusions in the ‘Current Knowledge about Future Impacts’ section
of the Working Group II Summary for Policy Makers are imprecise statements made without reference to the time period
under consideration or to a climate scenario under which the conclusions would
be true… In the Committee’s view, assigning probabilities to imprecise
statements is not an appropriate way
to characterize uncertainty. If the confidence scale is used in this way,
conclusions will likely be stated so vaguely as to make them impossible to
refute, and therefore statements of “very high confidence” will have little
substantive value [emphasis mine].
The report also noted that the Summary for Policy Makers,
the report widely cited by the media and climate activists, drew “more concerns
and suggestions for improvement…than any other part of the IPCC assessment
process.” Many respondents to the IAC
survey noted concern that reinterpretations of the scientific assessment report
in the Summary for Policy Makers “might be politically motivated.” Nor is the the Summary for Policy Makers
written and approved in a transparent manner.
The report is approved in a marathon session lasting several days,
ending with an all night session, “Thus, the individuals with the most
endurance or the countries that have large delegations can end up having the
most influence on the report.”
The IAC also noted the variance in content between the
Summary for Policy Makers and the underlying scientific assessment reports, and
the political reasons for that variance.
Another concern of respondents to the Committee’s questionnaire
was the difference in content between
the Summary for Policy Makers and the underlying report. The
distillation of the many findings of a massive report into the relatively
brief, high-level messages that characterize the Summary for Policy Makers
necessarily results in the loss of
important nuances and caveats that appear in the Working Group report.
Moreover, the choice of messages and
description of topics may be influenced in subtle ways by political
considerations. Some respondents thought that the Summary for Policy
Makers places more emphasis on what is known, sensational, or popular among
Lead Authors than one would find in the body of the report. A recent review by
the Netherlands Environmental Assessment Agency, for example, observed that the
Working Group II Summary for Policy Makers in the fourth assessment is more focused on the negative impacts of
climate change than the underlying report, an approach agreed to by
participating governments (PBL, 2010) [emphasis mine].
Similar problems were noted with the Synthesis Report, which
is intended to synthesize the finding of three different working groups. “Scientists” the IAC wrote, found the
Synthesis Report “too political.”
The disturbing problems noted by the IAC mirror the flawed,
opaque process I’ve been following in Maryland over the last five years.
The process started in 2007 when Governor O’Malley signed
and executive order creating the Maryland Commission on Climate Change.
O’Malley’s order
outsourced
climate policy to an outside advocacy group Center for Climate Strategies. From day one, the O’Malley administration tried
to keep details of the process hidden from public scrutiny. The Maryland Department of the Environment
withheld documents from
my colleague Paul Chesser’s Public Information Act request seeking documents
pertaining to the state’s dealing with CCS. The process was clearly slanted from the
beginning. One of the documents Chesser
did obtain, a memo from CCS to MDE stated, “participants will not debate the
science of climate change."
I followed up with my own PIA request and MDE told me I
could have the documents Chesser wanted, now ballooning to 3,700 pages from the
original 11 it withheld from him …
for
a hefty fee of $1,381. After the
legislature passed the GGRA, Environment Maryland, chief Brad Heaver boasted
about being
“lead
policy/lobbying group” to get it passed. I submitted another PIA request to MDE to find
out if Heavner and any other environmental advocacy groups were involved in
writing the regulations. All I got was
another bill, this time for $1,353.
Perhaps O’Malley’s MDE doesn’t want the public to know that
his climate commission and climate law were paid for and written by the radical
environmentalists at The Town Creek Foundation located in Easton, MD. According to its
latest IRS tax return Town Creek has investments in several oil and gas companies, including Exxon-Mobil.
1. CCS failed to quantify benefits in a way that they
can be meaningfully compared to costs;2. When estimating economic impacts, CCS often
misinterpreted costs to be benefits;3. The estimates of costs left out important factors,
causing CCS to understate the true costs of its recommendations…For policymakers, the CAP report offers no worthwhile
guidance. The report fails to quantify the monetary benefits of reduced GHG
emissions rendering its cost savings estimates implausible if not downright
unbelievable. The faulty analysis contained
in the CAP report leaves policymakers with no basis on which to judge the
merits of the CAP report’s recommendations for action on the mitigation
of GHG emissions [emphasis mine].
Nor did lawmakers heed the
skeptical
analysis of the non-partisan Department of Legislative Services.
DLS found that the commission’s recommendations were
“largely command-and-control policies rather than incentive-based policies.”
Like the Beacon Hill report, DLS also found similar flaws in the commission’s
economic analysis such as omitted costs, improper benefit-cost valuation, and
forecast errors.
However, despite a significant amount of research,
considerable uncertainty remains over the ultimate economic impacts of such a
policy. In addition, the choice and design of the specific mitigation programs
implemented will affect the magnitude and distribution of GHG mitigation costs.
Policies that are not incentive-based (i.e., command-and-control) and/or do not
implement economy-wide regulations will be much more costly. The distribution
of costs within the economy will depend on several key factors, including the
energy- and carbon-intensity of energy consumed by each sector.In Maryland, the manufacturing sector will likely experience a greater amount of
employment and output losses relative to the rest of the economy as a
result of GHG reduction policies. However, policies that attempt to mitigate
these losses and exempt the manufacturing sector will only increase the total
cost of GHG mitigation and shift the burden to other economic sectors. Ultimately, the cost of GHG mitigation
policies, even those imposed on businesses, will be borne by individuals
[emphasis mine].
Like the IPCC, the Maryland Commission on Climate
Change represents the creation of a political consensus through a
non-transparent process based on shaky science, and even shoddier
economics.
*The IAC
revised
its original report watering down the severity of its initial conclusions. Why? That question has never been answered. Still, even the watered down findings cast
serious doubt on the process.
