David Montgomery – Testimony for Hearing on EPA’s Greenhouse Gas Regulations

Prof. Montgomery’s prepared testimony is here [PDF]. It’s really excellent, science-based guidance to the politicians — it is worth reading the whole text. Fortunately Judith Curry also took an interest in Montgomery’s testimony so Judith and her commenters offer lots of useful insights. Altogether this is a very long post (26,000 words) but very worthwhile. Included are attempted rebuttals by Georgia Tech colleague Paul Baer.

I am not a fan of the EPA endangerment finding on CO2 – if any GHG policy is to be effective and affordable, regulation is not that tool.

Personally I found the most useful comments were those by Judith Curry , Richard Tol, and “Max Manacker” (you can search for (“curryja”, “richard tol” and “manacker”). I will quote Max Manacker’s summary comment as I agree with Montgomery and Max. For brevity I have excised Max’s comments on the Baer, Heinz rebuttals:

Here is my take on all this, for what it’s worth.

Dr. David Montgomery makes four important points at the start of his written testimony:

First, if the U.S. were to act without solid assurance of comparable efforts by China, India, and other industrialized countries, its efforts would make almost no difference to global temperature, especially if industrial production and associated emissions are simply exported to other countries.

Second, even global action is unlikely to yield U.S. benefits commensurate with the costs it would incur in making steep GHG emission cuts.

Third, globally, even with moderate emission reductions, benefits would not be much greater than costs and,

Fourth, conflicting economic interests will make international agreements on mandatory limits unstable.

Montgomery discounts the idea that regulations will cause companies to take actions to save money, which they would otherwise not do:

Any claim that a regulation or standard will on balance save money should be regarded with a high degree of skepticism unless accompanied by a well researched and peer reviewed demonstration that the specific action will cure a market failure, and do so without administrative costs great enough to wipe out the gains.

He points out why climate policy will not promote a new clean energy export industry in the U.S., citing the experience of the past 10 years. This experience shows that they rather cause the loss of U.S. jobs with the possible addition of a few new jobs located outside the U.S.

Montgomery then addresses the great uncertainties plus the “winners and losers” argument mentioned by Dr. Curry in her testimony before U.S. Congress:

Even if the goal of industrial policy were accepted, mandatory reductions on greenhouse gas emissions are the wrong way to go about it.

The most fundamental error is failing to admit how little is known about the direct causes of damage to human and economic systems that have been attributed to climate change.

Some changes may be beneficial, such as increased growing seasons and carbon dioxide fertilization in high latitudes, and some are negative, such as drought or storms in tropical areas. But the range of possibilities and whether it adds up to a positive or a negative in any particular region is impossible to predict with confidence. Therefore, any economic evaluation of damages is equally uncertain.

He points out how cost/benefit analyses for specific actionable proposals are hardly ever made. Instead the whole palette of possible worst-case scenarios is presented as justification for action.

In analyzing any particular policy the costs of that policy must be compared to the damage it avoids. It is shocking how rarely this fundamental economic principle is violated.

Montgomery makes a good case for his conclusion that attempts to change our planet’s climate will neither change the climate perceptibly nor show cost effective economic benefits, such as creating jobs.

He also points out that they would be totally meaningless without world-wide cooperation, and this is highly unlikely to occur.

{snip Baer, Heinz criticisms}

I’d say the testimony of Montgomery is much more convincing than the rebuttals of either Baer or Heinz.

But then, Montgomery had a lot of time to prepare his testimony, while Baer and Heinz were just “shooting from the hip” in response.