Isaac Orr on Justice and Drew
Policy fellow Isaac Orr appeared on Justice and Drew this week to discuss Governor Walz’s decision to impose California car mandates in Minnesota. His interview starts at about the 40-minute…
The Minnesota Pollution Control Agency doesn’t want to tell you how much global warming would be averted by the California car mandates that are being driven by an executive order from Governor Tim Walz.
We know this because MPCA admitted that the temperature impacts of the California car mandates would be small in their reply to the 46-page comments submitted by Center of the American Experiment. The agency then argued that the Next Generation Energy Act established goals for emissions, not global temperatures.
This is the kind of asinine logic only a bureaucrat could believe. The only reason to reduce emissions is to reduce future temperatures. Therefore, the people of Minnesota deserve to know what temperature reduction benefits they would receive for enduring higher vehicle costs if the regulations become a reality.
Here is what MPCA wrote in their reply comments.
A.4. Comments about the impact on global temperature
Commenters stated that the MPCA should not adopt the proposed rule because climate change is a large-scale global problem and, compared with global emissions, Minnesota’s contribution is relatively small. Commenters also suggested that the MPCA should not adopt the proposed rule because the GHG emission reductions it might achieve would not substantively reduce the average global temperature. Commenters stated that the MPCA should evaluate the impact on global temperature of the estimated GHG emission reductions achieved by the proposed rule. For instance, a comment from Center of the American Experiment states that “MPCA should publish estimated temperature impacts of all GHG regulations” (Center of the American Experiment, pg. 29). The comment goes on to state that the proposed rules “…will
have no measurable impact of global temperatures” (Center of the American Experiment, pgs. 29-30). Similarly, a comment from the Institute for Energy Research asserts that the estimated reduction in GHG emissions resulting from this rule is small and insignificant relative to the global total of GHG emissions, specifically that MPCA’s projected annual GHG emissions by 2034 “…would bring global totals down by less than one-hundredth of one percent” (Institute for Energy Research, pg. 1).
The MPCA agrees that climate change is a complex global problem. The Agency disagrees, however, with the premise that the scale and complexity of the problem should mean that Minnesota should not act to address it. As we state in the Statement of Need and Reasonableness (SONAR), “The need for broad efforts does not alleviate the need for incremental actions; in fact, it requires them. While no single action can turn the tide of climate change, the accumulation of many actions will be required to address this complex challenge. Each action spurs progress and further action. In this case, we must act to reduce GHG emissions from passenger cars, light-duty trucks, and medium-duty vehicles because transportation is the largest source of GHG emissions in Minnesota, and these vehicle types are the largest source of GHG emissions within that sector” (SONAR, pg. 14).
The direct impact on global temperature of any one single GHG regulation will inevitably be small; however, the MPCA’s statutory authority allows the Agency to act to reduce emissions of air pollutants. In addition, the NGEA sets emission reduction goals, not global temperature goals. It is therefore reasonable to assess the emission reductions associated with the proposed rule and unnecessary to assess the impact on global temperature (emphasis added).
MPCA pretends the public doesn’t deserve to know what the actual expected temperature reduction of the California car mandates would be because they know the public wouldn’t be willing to pay an extra $1,140 to purchase a vehicle when it would result in a reduction in future temperatures of 0.000033 degrees C by 2100, an amount far too small to measure.
The agency’s refusal to have a candid conversation about the costs and temperature benefits of the rules is one reason why thousands of Minnesotans have such little faith in this rulemaking process and have signed American Experiment’s petition saying NO to the rules.
MPCA tries to skirt the issue by discussing the benefits of this rule using a metric called the social cost of carbon, or SCC. MPCA wrote:
Instead, as is described in the SONAR (pgs. 78-79), the MPCA used the federal social cost of carbon (fSCC) values produced by the Interagency Working Group (IWG). The fSCC is the most credible estimate of the global damages from the emissions of one ton of carbon in any given year and is used by the federal government as well as local and state governments (including by Minnesota’s Public Utility Commission) to estimate the avoided climate change damages from regulations that will reduce GHG emissions. It puts the effects of climate change into economic terms to help policymakers and other decision-makers understand the economic impacts of decisions that would increase or decrease emissions. Because the social cost of carbon is an estimate of the economic damages that would result from emitting one additional ton of GHG into the atmosphere, it essentially addresses the same issue as avoided temperature impacts from reduced GHG emissions, but in dollars instead of units of temperature.
A major problem with using the SCC is that the “benefits” are minuscule when we consider that they are spread over the timespan of 80 years. MPCA notes:
A.5. Comment on the timescale related to federal social cost of carbon estimates
A comment from Center of the American Experiment refers to MPCA’s estimate that the proposed rule would lead to about $500 million (in 2018 dollars) in avoided climate damages” over the first ten years of implementation (SONAR, pg. 79). The comment goes on to ask “What is the timescale the agency is assuming for the avoided damages? By 2100? Which year, specifically?” (Center of the American Experiment, pg. 30)
MPCA response: The MPCA explains in the SONAR (pgs. 78-79) how the Agency used the IWG’s fSCC values to estimate the avoided climate damages resulting from the proposed rule. In producing its fSCC estimates, the IWG used three different integrated assessment models that relate emissions of GHG to climate damages. Each of these models considers a time horizon of 2300 in estimating the total climate damages (discounted to present value terms) in estimating the damages of a ton of GHG emitted today. Because of discounting, however, any climate damages beyond 2100 are very small when considered in present value dollars.
If we take MPCA’s claim at face value, they are suggesting that the “avoided climate damages” from the first ten years of the California car mandates would be worth $500 million. However, there are massive problems with the way MPCA is framing this number.
One: These are global numbers, not numbers that will be realized in any measurable way in Minnesota. By forcing Minnesotans to pay more for their cars, Governor Walz will be forcing Minnesota families to finance the “benefits” that are spread out globally over the next 79-279 years!
Two: Even if we incorrectly assumed all the benefits would be realized by Minnesotans, the benefits are far outweighed by the costs. Because these hypothetical “climate benefits” are the result of less carbon dioxide in the atmosphere, the benefits would be evenly spread to all 5.64 million Minnesotans. This produces a per capita “climate benefit” of $89 per person from now through 2100.
In other words, Governor Walz and MPCA want to force you to pay between $1,140 and $2,500 more for a new vehicle to receive “climate benefits” of $89 per person, spread out over 79 years, an annual “benefit” of just $1.13 from now until 2100. This is ludicrous.
With this understanding, it isn’t surprising that the Walz Administration doesn’t want the public to know how little global warming will be averted with the California car mandates, and how minuscule the benefits are, relative to the massive costs. If the Walz administration came clean on the costs and benefits of the California car mandates, few people would support them.
Doesn’t democracy die in darkness?