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Thursday, December 15, 2022

Policy for the Experts or for the People?

Woe to anyone who tries to dig into this new EPA Social Cost of Carbon regulation (see previous post for background). While it's an effort to bring scientific rigor to an important policy, it is the very definition of byzantine. It is the culmination of hundreds of academic studies by thousands of researchers, marshaled by other researchers, bureaucrats, and activists to generate a single number that carries a titanic amount of underlying meaning.

The SCC calculation comprises many steps but, in summary, the objective is to use current projections of the harm that researchers expect will be done to the globe economically and divide that by the total amount of CO2, researchers expect will be emitted. This produces a cost per ton of CO2. Then economics is used to convert that dollar cost, which is incurred in the future, into today's dollars.

The National Academies created a characteristically difficult-to-parse diagram to outline the steps.

A more descriptive chart would look something like this.

Each of these steps, itself has numerous substeps, and is based on a large set of articles and research. It's not an overstatement to say that this process is inscrutable for a layman. It begs the question whether regulatory policy should be so complex that only highly, highly educated people can have any hope to understand it and critique it.

"It begs the question whether regulatory policy should be so complex that only highly, highly educated people can have any hope to understand it and critique it."

There's obviously a conflict here between having highly educated experts in their field produce the best possible answer and having policy-makers creating policy that is open to the public to be challenged and accepted democratically. It's unclear which is better, but we should acknowledge the drawbacks of each. One other drawback that's not immediately obvious to those who favor the expert approach is that experts are often ideologically motivated, their analysis isn't completely objective, nor is it subjected to rigorous skepticism and criticism from other experts who are subject to the same biases.

"Experts are often ideologically motivated, their analysis isn't completely objective, nor is it subjected to rigorous skepticism and criticism from other experts who possess the same biases."

Also, the bureaucrats designing the policy are themselves ideologically motivated, which causes them to favor research that matches their priors and pre-determined preferences. This leads to a multiplier effect that amplifies and enshrines incorrect conclusions.

Sunday, December 11, 2022

Billions of Taxpayer Funds Up in Smoke

Main Takeaways

• IRA spends $369 billion to reduce CO2 emissions.
• The EPA estimates 1 ton of CO2 does $190 worth of damage to world.
• IRA spends $369B to reduce world damage by $125B resulting in $244 billion or 2/3 of the cost being wasted.

The Biden EPA recently released a draft rule which will more than double what is referred to as the social cost of carbon. Essentially, this is an estimate of how much damage carbon dioxide does to the world. More specifically, it's the cumulative damage, in dollar terms that a ton of CO2, if emitted today will wreak. Its purpose is to inform environmental regulations. For example, if the EPA is considering requiring coal plants to install CO2 reducing methods, they are required to conduct a cost/benefit analysis and can only pass regulations that pass it. So, if a regulation is going to cost energy producers $5 billion, and it reduces CO2 by only 1 ton, then the regulation fails the cost/benefit test and can't be implemented. Conversely, if it only costs $1, but reduces CO2 by 100 million tons, then it passes and can be implemented.

There are a number of questionable assumptions made to generate the new estimate, but the process is extremely complicated and impenetrable so for now, I leave it to others to scrutinize it. But it is instructive to assume it's correct and apply it to recent environmental regulations to determine if the Democrats' energy policy as implemented through legislation would pass Biden's historically liberal cost/benefit analysis.

I have found energy policy to be extremely opaque. For instance, the best (only?) analysis of the IRA's effect on emissions that I can find is from the Rhodium Group, but most of the reporting is in percentage terms, and aggregates. The analysis I provide is surely not exact, and I push others who are more experienced to do better, but it does get the work started and hopefully provides some useful takeaways.

Just as a starting point, the IRA energy provisions' total cost is $369 billion from 2023 to 2031. The Rhodium analysis predicts that the IRA will reduce US emissions by between 439 and 660 million metric tons by 2030.1 This leads to an estimated cost of between $559 and $840/ton of CO2--i.e. Americans will pay between $559 and $840 to reduce CO2 emissions by one ton. Biden's EPA, on the other hand, says that it is worthwhile to spend up to, but not to exceed $190 per ton. Consequently, the IRA seems to be a huge waste of money, by Biden's EPA's own standards.

Several caveats should be noted here, and I again point them out in the interest that someone will take this and run with it to provide a better analysis. First, the IRA may have longer-run impacts than are estimated by Rhodium through 2035. If the IRA, for example, converts all energy production to solar, CO2 emissions will be reduced beyond 2035. Additionally, the $369 billion may not all be used to reduce carbon emissions. This will be addressed below, to some extent. Contrarily, in many ways, the IRA only accelerates processes that will happen no matter what, so these CO2 reductions are finite. In other words, if the economy were destined to transition to 100% solar power by 2075 without the IRA, but with the IRA, that year moves up to 2060, then the IRA would have no effect after 2075. Also, the time window applies to the money as well. Some of the programs might require additional funds after 2031 to maintain lower emissions which aren't accounted for.

To get around some of these complications, we could try to perform the same exercise on specific items in the bill. The Congressional Research Service provided the best breakdown of provisions I could find. According to it, the energy production provisions total $149B, transportation $49B, and industry $44B.2. By sector and scenario, not one of the areas will be cost effective.

The single estimate that comes closest to being cost effective are the energy provisions.

There is admittedly, much more work that can and should be done to determine whether the IRA is actually cost effective at reducing carbon reductions, but these estimates that are available publicly suggest not, and that's even using the proposed EPA regulations which are higher than any regulator in the world, even the Obama administration, thinks are appropriate.

Notes

1 Note that the highest reduction comes from the central emission scenario. It is unusual that the highest reduction isn't in the highest emission scenario and that the central emission scenario doesn't produce an estimate between low and high, but Rhodium does not provide their model or an explanation, only the results.
2 I excluded loans from the total and a list of my divisions and inclusions is available upon request.

Saturday, August 6, 2022

Vote-A-Rama Suggestions: Inflation Reduction Act Edition

The Inflation Reduction Act is getting close to passage, and one of the final steps is what's called a vote-a-rama in the Senate. In short, these are opportunities for Senators to propose amendments to the reconciliation bill. The vote-a-rama imposes few restrictions on what amendments can be proposed, and consequenctly, one of the common uses of these is for the minority party to force uncomfortable votes for the majority party. For example, in this case, the Republicans may push for an amendment to promote fracking or pipeline construction, policies that Democrats oppose yet are popular.

I would propose some actually beneficial amendments. It's likely that Democrats won't like them, but they are all in the interest of good governance and conservative principles. I would encourage Republicans to consider the policies that this bill will be implementing and propose amendments that would seek to measure the success of these programs and modify them if they're unsuccessful. Here are some examples:

IRS Funding

There is much uncertainty (particularly among the left) about how much revenue generation the IRS funding bump will provide. The CBO estimates it will reduce the deficit by $203 billion, the Tax Foundation estimates it will reduce the deficit by $186 Billion.Treasury estimates the savings to be around $400 billion and Larry Summers says "even Treasury['s] estimate is far too conservative" and would be more than double Treasury's estimate. On top of that, Summers says that IRS commissioners estimate the provisions would be double Summers's estimate!

In light of this large range of estimates, it would be quite beneficial to add amendments that will require some reporting on this going forward and possibly even modification of funding if targets aren't hit. For example, if not already reported, IRS should be required to report its audit rates by income range, costs of audits incurred, win/loss ratio, and taxes recovered. These should be reported regularly, perhaps every two years. Surely $124 billion is enough to add a few employees to do this, or alternatively, it would be worth adding $5 million.

Not only that, but the IRA package more than doubles the funding to business services modernization. Presumably, that is to update their technology and make the IRS more efficient and includes better software systems. Not only does this create more opportunities for good-governance and performance-tracking amendments (for example, reports on what systems are being updated, how much time they saved, etc.), but it should make reporting performance to the public easier and cheaper.

Lastly, it is often argued that modernizations like these make staffs more productive and reduce long-term costs. That is reasonable, but I have always argued that investments that save money should also lead to lower long-termfunding. I have no problem investing funds today to save money in the future, but if taxpayers provide an additional $4 billion in funding to IRS specifically to reduce long-term costs, then it should result in more than $4 billion in long-term tax-payer funding.

Climate Provisions

The major selling point for the left of the IRA is its climate provisions. There are many provisions here that would lend themselves to productive, good-governance amendments. Their should be reports as to where the money goes--what industries, what companies, what states--and how that money is used. How much of it goes abroad? What are the effects on carbon dioxide in the atmosphere. Some estimate that it will reduce carbon emissions by 40%! I find this highly dubious, but the vote-a-rama presents a wonderful opportunity to evaluate that claim.

Conclusion

To sum up, Republicans should use the vote-a-rama, not just to embarrass Democrats, but to force transparency on the government and push it to perform one of its most important tasks--providing information to the public. The embarrassing amendments may feel good in the moment, but they rarely pass, and I doubt have much impact on voters. Thinking long-term, Republicans can generate talking points they'll be able to use in the future. I encourage them to go through the IRA's provisions again, consider their own criticisms of the provisions, and craft amendments that will test those criticisms and expose the problems that the policies create.