Benjamin Zycher response to Bicameral Task Force on Climate Change

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The following is a letter from AEI visiting scholar Ben Zycher to Sen. Sheldon Whitehouse, D-R.I., and Rep. Henry Waxman, D-Calif., of the Bicameral Task Force on Climate Change in response to their request for "ideas for action the federal government can take to address climate change." The letter from lawmakers  to Zycher and his response are attached at the right.

Bicameral Task Force on Climate Change letter to AEI President Arthur Brooks

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February 11, 2013

Honorable Henry A. Waxman
2204 Rayburn House Office Building
Washington, DC 20515

Zycher letter to Bicameral Task Force on Climate Change

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Honorable Sheldon Whitehouse
Hart Senate Office Bldg. Room 717
Washington, DC 20510

Dear Congressman Waxman and Senator Whitehouse,

I write in response to your letter of January 31 to Dr. Arthur C. Brooks asking for ideas with respect to “actions the federal government can take to address climate change. Thank you for your inquiry, and I hope that the thoughts that follow prove useful; more broadly, I look forward to ongoing interactions with you and your colleagues as we jointly pursue public policies yielding both improved economic conditions and environmental improvement, as well as a regulatory process constrained by the rule of law as reflected in executive authority actually enacted by the Congress. Please note that the ideas offered here are mine alone and should not be interpreted as those of the American Enterprise Institute.

The evolution of federal policy with respect to emissions (or ambient concentrations) of carbon dioxide and other “greenhouse” gases (GHG) is crucially important, as it has the potential to impose large adverse effects upon the U.S. economy while engendering environmental improvements that at best are speculative. The United Nations Intergovernmental Panel on Climate Change (IPCC) in its most recent published analysis projected a “likely” range of 2 to 4.5 degrees celsius for the temperature effect by the year 2100 of a doubling of carbon dioxide concentrations, “with a best estimate” of about 3 degrees.[1]  As an aside, a growing body of peer-reviewed literature suggests that this range and best estimate may be substantially higher than further analyses will project.[2] At a minimum, scientific opinion is diverse on the long-term temperature and ancillary effects of anthropogenic GHG emissions, and the range of estimates is sizeable. Apart from the basic truth that scientific inquiry is not majoritarian, this reality---an absence of scientific consensus---provides a strong argument for caution in terms of policymaking, both by the Congress and a fortiori by the regulatory agencies.

Whatever the actual magnitude of the prospective effects of changes in ambient concentrations of GHG, what is not in dispute is the international nature of those anthropogenic impacts. The policy inquiry in your letter is limited specifically to actions and legislation at the federal level. U.S. emissions of GHG are about 18 percent of global emissions, a proportion that is declining steadily. [3] If we ignore that ongoing decline in the U.S. proportion, the U.S. would contribute about 0.5 degrees of the IPCC best estimate of 3 degrees. Suppose that U.S. policies over time reduce our contribution by half, an outcome that could be achieved only in the face of massive economic dislocation.  In that case, the reduction in the U.S. contribution would be about 0.2-0.3 degrees, a change that no climate model predicts would yield measurable effects in terms of climate patterns and attendant impacts upon weather and other parameters.

 In short, federal policies aimed at reducing these effects are likely to impose very substantial economic costs without yielding benefits even remotely commensurate.  One answer might be a renewed emphasis upon international actions adopted through negotiations; but the uniform record of the Kyoto Protocol and the United Nations/Doha effort does not provide grounds for any expectation that a useful agreement might emerge. It is likely to be the case that a policy of watchful waiting, intensified analysis subject to a rigorous and impartial peer-review process, and, above all, adaptation through market processes rather than centralized decisionmaking will prove most effective in terms of addressing the effects of anthropogenic changes in GHG concentrations.[4]

Your letter claims that “the consequences of climate change are disruptive and wide-ranging, from extreme heat and sea level rise to droughts and wildfires. There also is a reference to “Superstorm Sandy. Further serious analysis and inquiry by policymakers are necessary, because this general assertion is not obviously supported by the facts. As of this coming June 1 (the outset of the Atlantic hurricane season), it will have been over seven and a half years since a Category 3 or higher hurricane landed on the U.S. coast; that long a period devoid of an intense hurricane landfall has not been observed since 1900. An increase in such hurricane activity over the next few years is far more likely to reflect a reversion toward the mean rather than the effects of GHG concentrations.[5]With respect to sea level increases, the evidence from the last century is that there is substantial variation across decades in the rate of increase, without a long-term trend despite rising atmospheric concentrations of GHG.[6] The Palmer Drought Severity Index shows no trend over the record period beginning in 1895 in terms of drought; more areas in the U.S. have experienced an increase in soil moisture than a decline.[7]

As a final observation: Policymaking, whatever the virtues of its goals, inexorably has the effect of transferring wealth among groups, industries, and geographic regions. Unlike voluntary transactions in free markets, which, however unintentionally, unite the parties in pursuit of mutually advantageous exchange, the wealth transfers that are the unavoidable product of political processes are adversarial by their very nature. This is a hidden outcome inconsistent with the civility and social cohesion necessary for a strengthening of democratic institutions. To the extent that policymaking must be undertaken, it is far better that it emerge from the implicit and complex bargaining process inherent in Congressional lawmaking, rather than in the form of the edicts at which our regulatory agencies are so practiced. A renewed emphasis on Congressional action rather than executive authority will preserve our constitutional institutions of self-government generally, and the separation of powers in particular.

Again, I look forward to a continuing exchange of ideas. Thank you for the opportunity to offer my views.


Benjamin Zycher
Visiting Scholar

[1] See Intergovernmental Panel on Climate Change, “Climate Change 2007: Synthesis Report,” p. 38, at

[2] See, e.g., J.C. Hargreaves, et. al., “Can the Last Glacial Maximum Constrain Climate Sensitivity?” Geophysical Research Letters, Vol. 39, Issue 24, (December 2012), at

[3] See the estimates published by the Energy Information Administration at  Similar estimates have been published by the World Resources Institute at

[4] See, e.g., Kenneth P. Green, “Climate Change: The Resilience Option,” American Enterprise Institute, Energy and Environmental Outlook No. 4, October 2009, at

[5] See, e.g., Ryan N. Maue, “Recent Historically Low Global Tropical Cyclone Activity,” Geophysical Research Letters, Vol. 38, Issue 14 (July 2011), at

[6] See, e.g., S.J. Holgate, “On the Decadal Rates of Sea Level Change During the Twentieth Century,” Geophysical Research Letters, Vol. 34 (2007), at

[7] See, e.g., Konstantinos M. Andreadis and Dennis P. Lettenmaier, “Trends in 20th Century Drought Over the Continental United States,” Geophysical Research Letters, Vol. 33, Issue 10 (May 2006), at
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