OMB taking comments on the social cost of GHGs

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Biden’s Office of Information and Regulatory Affairs in OMB is taking public comments on the regulatory use of the world’s strangest numbers. These are the so-called Social Cost of Carbon and other Greenhouse Gases (GHG).

The Social Cost is the supposed future climate change economic damage due to our near-term emissions. The numbers are huge because the Biden government projects endless damages for the next 300 years, from every ton of carbon dioxide, methane, etc., emitted now. Yes they have to go out 300 years to get the damages.

This opportunity to comment is important because the issue is the use of these looney SC-GHG numbers to justify massive climate change regulations that will govern our lives. Preventing these huge SC damages is presented as the benefits that justify the regulations in the required cost-benefit analysis. That SC-GHG is junk needs to be made clear, and stopped. It may be up to the courts to do this.

One of the rules of the regulatory game is that if you want to ask the court to stop a regulation, you must have first put your objection on the record, in the comments. When the Agency ignores your objection, then you can sue them. This is called exhausting your administrative remedies.

So here are some objections that people might use. The more comments the better.

To begin with, the SC-GHG computer models are obsolete. The Feds use the results from three different “integrated assessment models” or IAMs. These models are now about 20 years old. The US alone has done something like $30 billion in climate change research since they were developed. The major climate models have been steadily upgraded, with a new generation every five years or so, but not the IAMs.

Thus one could ask the Court to require the Agencies that want to use SCs in their cost benefit analyses to build new IAMs.

But it gets deeper than that, because some of the research calls into question the very feasibility of calculating a likely SC. Some of this research suggests that the models are very wrong, especially when it comes to our CO2 emissions. In fact the damage from our emissions may be negligible. Other research indicates clearly that the future is unpredictable. It follows in either case that a likely SC-GHG amount cannot be found.

The claimed emergency danger and future damages of increasing CO2 is based entirely on climate models. They get dangerous future warming by invoking very strong positive feedbacks from water vapor. Basic greenhouse science says doubling CO2 might produce around 1.2 degrees of warming, but the feedback-loaded models are running 5 degrees or more in the latest IPCC round (CMIP6). That is a huge feedback which is clearly questionable.

Happily we are now 43% of the way to doubling CO2 so we can observe the results. Published observational studies find a projected warming of just 1 degree or so, in keeping with basic GH science. Also recent theoretical studies using newly refined methods show both CO2 and water vapor to be radiation saturated, which may explain the observational results. There is very little warming potential left in increasing CO2. In short there is strong evidence that these proposed strong feedbacks simply do not exist. The hot models may simply be wrong.

The IPCC also suggests, based on hot modeling, that warming of just 1.5 degrees could cause significant climate damage. Here too we find that after about 1 degree of warming there is no observable damage. Given that the hot models are very wrong about temperature sensitivity it makes sense that they also greatly overestimate dangerous climate change. Observation says the models are wrong and there is no emergency. This is how science works — observation falsifies hypotheses. The emergency has been falsified and SC does not exist.

Nor one might simply point out that the expanding range of proposed sensitivities makes a likely SC impossible. If we do not know if doubling the atmospheric CO2 will cause one degree of warming, or five, we certainly cannot know what the damage from doubling is likely to be. The existing SC estimates are therefore a sham.

But the ultimate sham has always been part of the SC modeling. This is the claim that we know what technological development will be for the next 100 to 300 years. This is surely impossible and the economic damages from climate change, or the lack thereof, depend crucially on available technology.

Consider that 300 years ago George Washington was not even born yet. Those people in 1721 could not possible know what our technological capabilities are. The same is true for our knowledge of 2321, which the IAMs claim to know. That we now have computers does not make the future more predictable. In fact if the pace of change is greater today, then we have even less knowledge of what will come in 300 years than they did 300 years ago.

In short there are a number of deep “known unknowns,” as they are called, which invalidate the very idea of a likely social cost of greenhouse gas emissions. There is even evidence that there will be no damage at all!

Massively costly and burdensome new regulations cannot be justified using SC-GHG.

Comments on the absurdity of SC-GHG can be made here:

Note that officially these are just comments on the Biden update of SC-GHG, but all aspects of that nonsensical metric are open for comment. Go for it!

  • David Wojick, Ph.D. is an independent analyst working at the intersection of science, technology and policy. For origins see For over 100 prior articles for CFACT see Available for confidential research and consulting.

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