[There is evidence] that a straight-out command and control approach might [be more efficient than] cap and trade …
It is well established that the lack of immediate financial benefits leads companies to underinvest in R & D …
[This is because the benefits of] pollution prevention [are poorly] reflected in the market price of goods and services … the incentives for private investment are weak.
Competitive forces just don't provide enough justification for the long-term investment required …
[When] government establishes a regulation, it creates demand [and companies respond with innovation.]
[There] may even be cost savings … as obsolete technologies are replaced with state-of-the art ones [— something companies would not have done] had they not been forced to.
(p 105, emphasis added)
The empirical evidence shows that … regulation provides a strong and continuous stimulus for invention.
Necessity is the mother of invention, and regulatory compliance is a powerful form of necessity.
(p 106)
Naomi Oreskes (1958)
Professor of the History of Science and Affiliated Professor of Earth and Planetary Sciences, Harvard University.
- Merchants of Doubt: How a Handful of Scientists Obscured the Truth on Issues from Tobacco Smoke to Global Warming, Bloomsbury, New York, 2010.
Naomi Oreskes & Erik Conway.
Sowing the Seeds of Doubt: Acid Rain
[The] Hydrological studies at Hubbard Brook had been pioneered by a US Forest Service scientist named Robert S Pierce, who teamed up with F Herbert Bormann, a biology professor at Dartmouth College … biologist Gene E Likens and geologist Noye M Johnson.
In 1963 … they discovered acid rain in North America.
[Naturally] acidic rain caused by volcanoes and other natural phenomena … had been known since the Renaissance …
[Man-made] acid rain had been recognized since the nineteenth century in areas [affected by] industrial pollution in the British Midlands and central Germany.
(p 66)
“Preservationist" environmentalism was broadly popular and bipartisan …
Roosevelt was a progressive Republican, Rockefeller a captain of industry.
[It] was mostly driven by aesthetics and moral values, and by the desire for restorative recreation.
It did not depend on science. …
(p 67)
Studies in Sweden suggested that acid precipitation was reducing forest growth.
Studies in the United States and elsewhere documented the damaging effects of acidity on plant growth, leaf tissue development, and pollen germination.
In Sweden, Canada, and Norway, acidification of lakes and rivers was correlated with increased fish mortality.
(p 67)
[By 1979] basic science of acid rain was [well] understood.
Scientists had been working steadily on the question for nearly twenty-five years, demonstrating the existence of acid rain, its causes, and its effects on soils, streams, and forests.
Major articles had been published in the world's most prominent scientific journals, as well as in many specialist journals and government reports.
(p 72)
Political Action and the US-Canadian Rift
In 1979, the United Nations Economic Commission for Europe passed the Convention on Long-range Transboundary Pollution.
[In] 1985, they set firm limits on sulfur emissions, mandating 30 percent reductions.
(p 73)
… Environment Canada concluded that more than half the acid rain falling in Canada was coming from US sources …
[In 1980, President Carter] established the National Acid Precipitation Assessment Program (NAPAP), a comprehensive ten-year research, monitoring, and assessment program to determine the effects of sulfur and nitrogen oxides on the environment and human health.
Skepticism in the Reagan White House
In 1980, Ronald Reagan came to power …
Government, the new president insisted, was not the solution but the problem.
(p 74)
In 1983, the technical working groups established under the 1980 Memorandum of Intent affirmed that acid rain caused by sulfur emissions was real and causing serious damage.
The solution was to reduce these emissions [using technology that] already existed …
At the last minute [the US representatives] backpedaled.
The Canadian government asked the Royal Society of Canada to review the documents compiled by the working groups. …
(p 75)
There had been numerous “changes in scientific content" as the report went through successive drafts, changes that made the summaries more ambiguous than the reports themselves. …
[The US version] did not accept that cause and effect had been established, on the grounds that the relative importance of different contributing factors had not been quantified, and potentially off-setting processes had not been fully investigated. …Environment Canada:
(p 76)
In each country independent peer review experts have indicated the need for action based on what we now know. …
(The Acid Rain Story, 1984)
Pollution went across the border in both directions, but by far the larger share came from the United States, which would therefore bear most of the burden of cleanup.
Getting a Third Opinion
In 1982 … the White House Office of Science and Technology Policy (OSTP), under the direction of physicist George Keyworth, commissioned its own panel to review the evidence on acid rain.
The National Academy of Sciences had already reviewed the available evidence the previous year …
(p 77)Committee on the Atmosphere and the Biosphere [Board on Agriculture and Renewable Resources, Commission on Natural Resources, National Research Council]:
A major EPA report the following year agreed. …
The Committee believes that continued emissions of sulfur and nitrogen oxides at current or accelerated rates, in the face of clear evidence of serious hazard to human health and to the biosphere, will be extremely risky from a long-term economic standpoint as well as from the standpoint of biosphere protection.
(p 3)
[Based] on the evidence we have examined, that the picture is disturbing enough to merit prompt tightening of restrictions on atmospheric emissions …
(Atmosphere-Biosphere Interactions, National Academy Press, 1981, p 7)
The administration's outright rejection of the conclusions of the nation's most distinguished and qualified experts caused considerable consternation in scientific and regulatory circles.
[The man the OTSP] asked to assemble and chair the panel was … Marshall Institute cofounder and SDI defender William A Nierenberg.
[Someone] who had never worked on acid rain, but was well-known to the Reagan White House …
(p 78)
{at the time,] Nierenberg was putting the finishing touches on a major report of the National Academy of Sciences on the impact of carbon dioxide on climate …
Its conclusions were fully in line with the position of the administration — that no action was needed other than more scientific research …
[Back in] 1965, Nierenberg [had been appointed] director of the Scripps Institution of Oceanography in La Jolla, California [which was involved] in research linked to underwater surveillance of Soviet submarines and targeting submarine-launched ballistic missiles.
Like Seitz and Teller, Nierenberg hated environmentalists [in particular, because of] their opposition to nuclear power …
He had been a fierce defender of the Vietnam War. …
[He was also] a highly respected scientist and administrator …
(p 79)
The Nierenberg Acid Rain Peer Review Panel
[The panel] affirmed that acid rain was serious and sufficiently documented to warrant [immediate] policy action …
… S Fred Singer, who had been suggested to Nierenberg by the White House Office of Science and Technology [contributed] an appendix suggesting that, despite the conclusions of the Executive Summary, we really didn't know enough to move forward with emissions controls.
(p 81)
Fred Singer was a physicist [involved in rocketry research] who owed his career to the Cold War.
(p 82)
Through out the 1960s, Singer had been an environmentalist.
(p 83)
Somewhere between 1970 and 1980 [he converted to Cornucopianism].
(p 84)
[In 1981 he predicted] that by the 1990s, the world would be using “less than half of the oil it uses today," and by 2000 the US "oil dependence on the Middle East" would “become a thing of the past."
(p 85)
He was affiliated with the conservative Heritage Foundation … which advocated- unrestricted offshore oil development,
- transfer of federal lands to private hands,
- reductions in air-quality standards, and
- faster licensing of nuclear power plants.
[At the outset, the panel had] agreed that any conflicting or dissenting views would be included in the report [and] there was no discussion of any appendices.
(p 86)
The strongest part of the [draft] press release [announcing the report] was perhaps [two paragraphs] that dealt with long-term damage.
The first noted that the damage being discussed might not be irreversible in an absolute sense, but that it was legitimate to use that term when discussing damage that could take more than a few decades to repair.
The second paragraph dealt with the [risk] that soil damage might set off a cascade of effects at the base of the food chain. …
[These] two paragraphs [were] struck out [by the White House.]
[Someone] at the OSTP — probably senior policy analyst Tom Pestorius [— also suggested] that the remaining paragraphs be presented in a different order.
[The] White House version would not begin by stressing the problem massive sulfur emissions that caused acid rain — but by stressing that pollution was already partially controlled, and then moving straight on to the uncertainties that might … suggest that further controls were not justified.
A second document, “Overall Recommendation of the Acid Rain Review Panel," also came back to Nierenberg with suggested revisions [by Singer.]
(p 87)S Fred Singer:
This might have been a reasonable recommendation [but] it was not what the peer review panel had said. …
Acid Deposition (AD) is a serious problem, but not a life threatening one. …
- Scientifically: we are not certain of all the causes of A.D. …
- Control technologies are still costly and unreliable …
- Institutionally: the Clean Air Act, and successive amendments, have wrestled with the problem of setting air standards to protect human health and property. …
We would recommend a middle course:
Removing a meaningful percent age of pollutants by a least-cost approach and observing the results, before proceeding with a more costly program.
Throughout the panel deliberations, Singer … presented views that echoed those promoted or circulated by the electric power industry. …
(p 88)- That the science was uncertain,
- that more research was needed,
- that the economic consequences of controlling acid rain would be too great, and
- that acid rain might be caused by natural sources
Time magazine:
Singer found himself out on a limb among his scientific colleagues …
[The utility industry] vociferously opposed to any emission control program without further research into the causes of acid rain [and insisted that] installing scrubbers could break the economic backbone of the Midwest. …
[Furthermore, his views were] seen as irrelevant to the panels charge to summarize the science.
(p 89)
Writing on Heritage Foundation letterhead, Singer asked [the committee's executive secretary] to distribute … a long document that “set forth the Administration's general perspective and policy on global issues." …S Fred Singer:
(p 90)
[Although] important 'global' problems do exist, recent [projections] are less alarming than most previous studies. …
[These problems] all seem amenable to solution … and promising new approaches and technologies are emerging. …
[The administration wishes to stress the] importance of the market place for achieving environmental quality goals. …
(Global Environment, Resources and Population Issues, Federal Policy in the 1980s, 15 February 1983)
William Nierenberg:
Even in the absence of precise scientific knowledge, you just know in your heart that you can't throw 25 million tons a year of sulfates into the Northeast and not expect some … consequences.
In September 1983 [the panel's vice-chair] presented the committee's interim conclusions to the House of Representatives Committee on Science and Technology.
Singer wrote … to the committee chair [claiming that that testimony] was unsupported by sufficient data. …
He argued that …- that acidification might in some cases be beneficial …
- that some soils are naturally acidic [— which was] true, but irrelevant [and]
- that the evidence of potential soil damage was "insufficient" [— without mentioning that] he was the only member of the committee who held [that] opinion …
The committee was divided … 8-1, with the dissenter appointed by the Reagan White House.
Singer was supposed to be writing the final chapter of the report, on the feasibility of estimating the economic benefits of controlling acid pollution.
[It] turned into the claim that if you did nothing, it cost you nothing [— that] the value of nature [was] zero. …
When the report finally appeared [Singer's chapter had been relegated to an appendix.]
While the rest of the report was jointly authored — the norm for National Academy … panel reports — Singer's appendix was all his own.
(p 91, emphasis added)
Singer [considered that the only cost of acid rain was] the cost of pollution control — ignoring the cost of ecological damage. …
Singer's appendix did not actually include the [cost-benefit] analysis he insisted was needed.
[Instead he argued] that both the costs and the benefits were extremely difficult to quantify, and [then] jumped to his preferred conclusion: that the most practical approach would be a market-based one.
(p 92)
Without any analysis of the details or an example of a successful market-based pollution control scheme, he simply asserted that a system of transferable emissions rightswould guarantee that the market will work in such a way as to achieve the lowest-cost methods of removing pollution.
For a man who worried enormously about scientific uncertainties, he was remarkably untroubled by economic ones.
(p 93)
The acid rain panel report was supposed to be a scientific peer review …
… Singer had placed within it a policy view consistent with that of the Reagan administration, but seemingly at odds with the science that had been reviewed. …
In May [1984, three months before the final report was released,] the House subcommittee voted 10-9 against the legislation, effectively killing congressional action on the issue. …
The Wall Street Journal ran a piece on its editorial page by a [business consultant who previously had worked for the tobacco industry] named Alan Katzenstein … questioning the scientific evidence …
(p 94)
Manipulating Peer Review
Changes were made after the report was finished [‒ some] without the agreement of the full panel [‒ which weakened] the message. …
(p 95)
[Two] sets of changes were made-one set in the [March 1984], and a second set in [August].
Fred Singer had played a role in these changes ‒ and so had Bill Nierenberg.
[When] the panel realized what had happened, they protested loudly.
(p 96)
[Singer's chapter was move to the appendix by the OTSP, apparently] to avoid the obligation of getting the committee to sign off on what Singer had done — something they had already refused to do.
(p 97)
[Furthermore, the President's science adviser, physicist George Keyworth] had told Nierenberg what changes [to make to the Executive Summary] and Nierenberg had made them. …Kenneth Rahn [Atmospheric Chemist]:
(p 98)
[Our] report has been altered since we last saw it …
'Tampered with' may not be too strong …
… I suspect that we would not have approved it if we had been given the chance. …
Gene Likens:
I am very distressed to learn that the Executive Summary for our Report from the Acid Rain Peer Review Panel has been rewritten and changed from the version our Panel prepared and authorized last spring …
These revisions were done without informing the members of our Panel and without gaining their approval …
My understanding is that these unapproved changes in the Executive Summary originated within the White House/OSTP.
Frankly, I find such meddling to be less than honest and extremely distasteful.
Republicans in general were pleased with Nierenberg's work. …
In September [he] received an autographed photograph of President Reagan.
(p 100)
[In] a pattern that was becoming familiar, the scientific facts were published in a place where few ordinary people would see them, whereas the unscientific claims — that acid rain was not a problem, that it would cost hundreds of billions to fix — were published in mass circulation outlets. …
[Fortune] misrepresented the science and the situation.
Business Week attacked the EPA as “activist” for trying to take action on acid rain — in effect, for doing its job.
(p 101)
In 1990 [George H W Bush] established an emissions trading [system which] resulted in a 54 percent decline in sulfur dioxide levels [by] 2007 …
[The] inflation-adjusted price of electricity declined during the same period.
In 2003, the EPA reported … that the overall cost of air pollution control during the previous ten years was between $8 billion and $9 billion, while the benefits were estimated from $101 billion to $119 billion …
Singer's “billion-dollar solution to a million-dollar problem" was just plain wrong.
The energy industry had often accused environmentalists of scare mongering, yet this is just what they had done with their claims of economic devastation. …
Cap and trade to control sulfate emissions was widely considered a success and is now the leading model for controlling the greenhouse gases that cause global warming.
(p 103)Gene Likens:
[Forest decline has continued in the face of multiple insults:]
Since 1982, the forest has not accumulated biomass.
[And] since 1997, the accumulation … has been significantly negative.- climate change,
- alien species invasion,
- disease,
- mercury and salt pollution,
- landscape fragmentation, and
- [principally,] continued acid rain.
Gene Likens:
The cap and trade system [failed to reduce acid rain] sufficiently to stabilize the situation. …
[Research] suggests that by 2076, the 300th birthday of the United States, sugar maples will be extinct in large areas of the northern forest. …
[The] real issue … is where you set the cap, and whether or not you have a mechanism to adjust it … if future information suggests you should.
(p 104)
We took modest steps [(based on distorting the science to minimize the risk)], and then did nothing to strengthen them as time went on, even as the science increasingly indicated that we needed to.
We went on faith that the ["Invisible Hand" of the] market would [weave] its "magic."
Magical thinking still informs the position of many who oppose environmental regulation.
(p 105)
[The] doubt-mongering about acid rain [led to delay, and in] the years that followed, the same strategy would be applied again [and again — often] by the same people.
[Furthermore,] they would not merely deny the gravity of the problem; they would deny that there was any problem at all.
[They] wouldn't just tamper with the peer review process; they would reject the science itself.
(p 106)
