After considerable delay, EPA’s proposed HFC phaseout regulations have been posted for public comment. I earlier looked at the serious technical problems with this proposal, which the various adversely impacted industries will have to comment on. Here I want to talk about the climate change aspect, where the deep problems go way beyond this HFC case.
This is the first major EPA regulation to be based entirely on the fantasy of stopping climate change. It is also a cap and trade system, so there is plenty to be concerned about. What follows is just skimming the surface but it introduces a number of the nastiest issues.
My focus is the so-called Social Cost of HFCs (SC-HFC or sometimes just SC). The vast sweep of this concept is breathtaking. Here is how EPA puts it in their Regulatory Impact Analysis:
“SC-HFC includes the value of all climate change impacts, including (but not limited to) changes in net agricultural productivity, human health effects, property damage from increased flood risk and natural disasters, disruption of energy systems, risk of conflict, environmental migration, and the value of ecosystem services.”
Wow! That is a lot to figure out, right? Note that they left out the damages from seal level rise, which they also include in SC. Moreover, EPA claims to measure all these various economic impacts for the next 300 years. I am not making this up.
They come up with stupendous numbers. EPA claims that the regulated reduction in HFC production between now and 2050 will avoid almost $300 billion in far future damages. Mind you that is just the discounted present value of the damages. The actual damages, which must be many trillions of dollars, are never given for consideration. Neither is when they will occur.
So to begin with, the nature and timing of all these fantastic damages is hidden behind a dark curtain. We have no way to assess them, even though the regulations are costly, disruptive and burdensome. For all we know these damages are illusory. In regulation speak they may be arbitrary and capricious, made up numbers. EPA cannot simply say “Here are the total damages discounted to present value. Trust us.” They must show how, when, where and why these enormous damages occur.
Not only does EPA claim to know these numbers, they claim to know them to an incredibly precise amount. So precise that the future damages are highly dependent on the precise year the HFCs are emitted. Still not making it up. They even claim to know it for each different HFC!
So for example, EPA claims that the HFC-125 emitted in the 2022 would cause about $1.3 billion in 3% discounted damages if it were not prevented from being emitted by these regulations. The amount and nature of these damages or when they occur is not given, so we cannot assess the claim.
Then too, the HFC125 emitted in 2050 would cause a whopping $17.9 billion in damages over the next 300 years. It is only 28 years later but there is a huge 14 times increase in damages. Again, we are not told why, where or when this massive increase occurs. How many trillion dollars in HFC-125 caused damages are we talking about?
We can therefore ask EPA questions about all these supposedly avoided damages, along the following lines:
How much of this damage is due to conflict and when and where do these conflicts occur? How does the HFC-125 cause the conflicts? (Note that all the alleged damages are global so they need not occur in America. Which do is another question.)
How much damage is due to disruption of energy systems? How are they disrupted? When and where?
What are “ecosystem services” and how are their value adversely affected by HFC-125?
How is human health affected and how valued?
There are many more questions like that that must be answered before EPA’s claims can even begin to be assessed. It is all behind the dark curtain at this point.
Note that specific avoided damages, over time, are listed for nine different HFCs, so these sorts of questions can be asked of each. And of course we can ask them of all the HFCs taken as a whole.
These are the principal components of the alleged damages, which EPA claims to know in sum, so they must know the values for each component. How else can they get these stupendous sums?
EPA is supposed to reply to all comments so I encourage people to ask a lot of questions along the above lines. As it is, EPA is claiming monster damages that they do not present, much less explain. It is all behind the curtains and that is no way to justify massive new regulations.
You can comment here: https://www.regulations.gov/document/EPA-HQ-OAR-2021-0044-0039
Email comments are also allowed and explained early on in the proposal.
Mind you I do not expect the EPA answers, when we finally get them, to hold up under scrutiny. The monster damages cited in all the Social Cost of Greenhouse Gasses claims come from just three computer models. They are called Integrated Assessment Models or IAMs because they combine projected temperature changes with the then caused climate and sea level changes, followed by the physical damages caused by these changes, and finally the economic costs of these supposed damages. It is all extremely speculative.
In fact one of the three IAMs, Richard Tol’s FUND model, says this pretty clearly on the FUND home page:
“FUND links scenarios and simple models of population, technology, economics, emissions, atmospheric chemistry, climate, sea level, and impacts. Together, these elements describe not-implausible futures. The model runs in time-steps of one year from 1950 to 2300, and distinguishes 16 major world regions.” (See http://www.fund-model.org/)
Simple models lashed together cannot possibly predict the future of all these uncertain features for the next 300 years.
Surely the distant future features of the world are impossible to know at this time. As the quote says, these results are merely “not-implausible”, meaning they are physically possible. They are in no sense even likely, especially given all the other not-implausible futures, including those with little or no damages from HFCs. Clearly these vague possibilities are no basis for massive regulations like the HFC phaseout rules.
EPA must disclose the specifics of these damage predictions so they can be properly assessed. Rational rule making requires this disclosure. The same is true for all SC-GHG damage estimates, especially SC-CO2, used for Federal policy making.
It is time to look behind the curtain on Social Cost.
May 25, 2021 By David Wojick