Tuesday, June 23, 2009

Stop Waxman-Markey!

Speaker Pelosi has scheduled the Waxman-Markey Bill for a vote this week, even though the ink is barely dry on it. The bill is formally known as H. R. 2454, the American Clean Energy and Security Act.

Politico reports, "House Energy and Commerce Committee Chairman Henry Waxman (D-Calif.) has overcome one of the last big obstacles standing in the path of his landmark climate-change bill, cutting a deal with Agriculture Committee Chairman Collin Peterson, who sought greater protections in the bill for farmers and other rural interests. Their agreement sets the stage for a vote Friday in the House." (h/t Lucianne.com)

The Competitive Enterprise Institute is one of the organizations campaigning against the bill:
"We urge that voters contact their Representative immediately by calling the House switchboard at (202) 225-3121. Tell your Representative to vote No on H. R. 2454, the American Clean Energy and Security Act. Voters may also send their Member an e-mail by going to www.cei.org/1984 and clicking on the link to the action page."

Why do I object to this legislation? Basically, it does nothing to solve the problems it's ostensibly written for, but will inflict huge costs on our country. Whether you believe or not that humans and greenhouse gases (e.g. CO2) will lead to further climate warming, this is a terrible bill.

1. As Hugh Hewitt noted on his radio show this evening, it's not designed to solve global warming, it's designed to raise revenue. Over at MasterResource.org, Chip Knappenberger writes:
Without a large reduction in the carbon dioxide emissions from both China and India—not just a commitment but an actual reduction—there will be nothing climatologically gained from any restrictions on U.S. emissions, regardless whether they come about from the Waxman-Markey bill (or other cap-and-trade proposals), from a direct carbon tax, or through some EPA regulations.
2. The energy taxes will raise prices throughout the economy. Remember $4.00 gasoline? A few years from now that may seem awfully cheap! Many people argue that gas should be at least $10/gallon to "properly" account for its alleged environmental costs. Elon Musk, CEO of Tesla Motors is just the latest example. But this legislation also hits coal and natural gas, which together provide about 70% of our electric supply if my math is right. (Data from Energy Information Administration) So electric cars won't be a bargain either. Naturally, that's made some House member nervous. PlanetGore has background on some of the horse trading here and here.

3. Because of price inflation, economic output (GDP) will less than it would be without the energy taxes. Heritage Foundation has run the numbers and they are staggering:
Higher energy costs create a significantly slower economy and reduce America’s growth potential. Heritage analysis finds that by 2035, a projected 2.5 million jobs are lost below the baseline (without a cap and trade bill). The average Gross Domestic Product (GDP) lost is $393 billion, hitting a high of $662 billion in 2035. The negative economic impacts accumulate, and the national debt is no exception. The increase in family-of-four debt, solely because of Waxman-Markey, hits an almost unbelievable $114,915 by 2035.
4. If you're concerned about our dependence on foreign oil, it would make more sense to encourage development of domestic sources even as alternative sources emerge from the R&D phase over the next couple of decades. But this bill does nothing to encourage domestic production or otherwise increase supply.

Newt Gingrich now heads up American Solutions. They have lots more information and an online petition I've signed:

http://www.americansolutions.com/take-action/petition/index3.php

Tell your Congressional Representative to vote NO and spread the word to your friends. We can't afford this bill.

Posted on both RareKate Writes and Thwarting Murphy blogs.

Wednesday, June 17, 2009

Craving Clarity in Policy Debates

Rabbi Yonason Goldson writes about "The Language of Confusion":
In his essay "The Principles of Newspeak," the appendix to his classic novel, 1984 (published 60 years ago this month), George Orwell describes how the leaders of his totalitarian future have contrived to assure their hold on power by replacing English with Newspeak, a language containing no vocabulary for concepts contrary to the platform of the state-run Party. By controlling language, the Party controls its people's very thoughts.

Intuition suggests that language is a product of thought: if we think clearly, automatically we will speak clearly. Orwell demonstrates the opposite, that thought is a product of language. Because we formulate our thoughts in words and sentences, incompetent use of language guarantees muddled thinking. If there are no words for rebellion, uprising, or discontent people will find it difficult to formulate and articulate the concept of overthrowing even the most corrupt and oppressive government.

Marketers talk about how to "reframe" a problem so the customer will think about it in a different fashion. For example, when showing a house in the country, the potential buyers might be worried about the long commute. A smart real estate agent will soon have them thinking cheery thoughts about being close to nature instead, diverting their attention from one of their reasons for not buying.

C. Edmund Wright lays out the word game underlying the so-called health care legislative push, where "health care" is conflated with "health insurance":
The confusion between "health care" and "health insurance" as public policy issues -- along with the near universal misunderstanding of what health insurance is (or should be) -- is making what should be a rather simple financial planning market solution a national nightmare.

Moreover, the nuanced difference in the language used has turned the issue much more emotional and much less rational, politically. We say we must reform the system to prevent families from going bankrupt over medical bills, then turn around and debate systems that micro-manage the costs of pills and routine check ups. Well, which do we really want to do? Those are entirely different issues.

The problem begins with the almost universal misapplication of the terms. Health insurance does not insure your health, nor was it ever intended to. Health care insurance, formerly called "medical insurance," is merely an instrument of neutralizing risk. Financial risk, that is.
Meanwhile, Hugh Hewitt blows the whistle on the rebranding effort on Capitol Hill:
The Obama/Pelosi/Reid push to take over and nationalize health insurance via the so-called "government option" has received a face-lift this week, with many advocates of the takeover now calling it the "public option," which sounds less intrusive. No matter what you call it, the "government/public option" will destroy private sector insurance very soon after it passes and will push tens of millions of employed and covered Americans from the insurance plans they currently own (and generally like) into the sprawling, top-down, rationing-on-the-sly plan that is just Medicare on steroids, a "public option" that will be just as broke and just as oppressive when it comes to intensive treatment of difficult diseases and conditions as medicare is.
Unless our public policy debates can achieve clarity on exactly what the problems are before trying to craft solutions, the politicians and their staffs will continue to write legislation that promises much but comes with huge costs and unintended adverse consequences like the "stimulus" bill. Kevin Glass blogs:
Preliminary results from Barack Obama's stimulus are coming in. The news is not good.

Four months on from Barack Obama's stimulus package, we're seeing an explosion of analysis of what's actually been happening to the hundreds of billions of taxpayer money being doled out.

Recovery.org has been doing a great job tracking where stimulus money is going and for what, and has worked as a non-partisan alternative counter to the Obama administration's propaganda website Recovery.gov. Recovery.org has a handy and detailed list that includes a list of "most recent" stimulus projects, "most expensive" projects, and what Americans are saying. It's an invaluable and unbiased resource for Americans concerned with Obama's spending projects.

The Reason Foundation has just released the "Taxpayer's Guide to the Stimulus." The guide breaks down stimulus spending by category, department and project. Their findings are depressing.

Rushing bills through Congress is not the answer! David Harsanyi opines in the Denver Post (h/t Corner):

Weren't we promised some methodical and deliberate governance from President Barack Obama? Where is it?

The president claims that we must pass a government-run health insurance program — possibly the most wide-ranging and intricate government undertaking in decades — yesterday or a "ticking time bomb" will explode.

If all this terrifying talk sounds familiar, it might be because the president applies the same fear-infused vocabulary to nearly all his hard-to-defend policy positions. You'll remember the stimulus plan had to be passed without a second's delay or we would see 8.7 percent unemployment. We're almost at 10.

Ahem.

Tying a Gordian Knot

In Greek mythology, the Gordian Knot was infamous for being so complex that it was impossible to untie. (Alexander the Great "solved" the knotty problem by cutting it with a sword.)

Nowadays, our fearless leaders on Capitol Hill seem intent on creating their own masterpieces of knotty complexity that many conservatives fear will be impossible to undo once implemented, just like Medicare. But that's not stopping Congressional solons from trying, even if no constituent group wants their "cures". From The Hill:
The cost of [health care] reform and how to pay for it dominated the discussion Tuesday as Democrats were forced to respond to an unfavorable Congressional Budget Office (CBO) analysis of one incomplete part of an incomplete bill.

The CBO looked at one portion of a draft bill written by the Senate HELP Committee and found, among other things, that it would cost more than $1 trillion while providing a net decrease in the number of uninsured people of 16 million.

The CBO also threw cold water on a promise by a coalition of healthcare industry groups to reduce healthcare spending by $2 trillion over 10 years. Obama announced their promise to much fanfare, but the CBO found that while a few of the cost-cutting measures would save money, others would cost money. In sum, they would not have a big impact on federal spending, the CBO concluded.
Or consider the proposed financial regulation reform. Larry Kudlow writes at The Corner:

The Fed in Charge of Systemic Risk? What a Mess [Larry Kudlow]

The big winner of the Obama financial-regulation plan appears to be the Federal Reserve, which becomes the consolidated supervisor of large, systemically important banks.

This is like the fox guarding the henhouse. After all, the Fed’s overly loose money policies created the asset bubble — including housing, commodities, and energy — in the first place. Near-zero interest rates, huge money growth, and total disregard for the plunging dollar are what set up the housing boom and the unfortunate overleveraging by consumers, mortgage borrowers, and Wall Street securitizers.

It also set up the astronomical $150 oil shock, which came alongside the Fed’s overly tight money policies to offset the prior loose policies that would cause this credit crunch and deep recession. In fact, looking back to the last two bubbles — the tech bubble of 1999-2000 and the housing/energy bubble after that — it was the Fed’s pillar-to-post go-stop-go-stop lurches that deserve the principal blame for the economic messes that ensued.
If mismanaging economic policy doesn't make you nervous, how about the Waxman-Markey environmental legislation being written? From Steve Haywood at Planet Gore:

May the Farce Be With You [Steve Hayward]

While most of us are concentrating our fire on the costs and bureaucracy that Waxman-Markey entails, no one has noticed one salient political fact: Had the Bush administration and the GOP Congress proposed the current language back in, say, 2005, all of the leading green groups would have vehemently opposed it as an ineffective sellout to corporate interests. (See, for example, the latest estimate from the Breakthrough Institute that Waxman-Markey will only reduce GHG emissions by about 0.5 percent by 2020.) But the greens are so in-the-bag for Obama and Pelosi, and so desperate to pass something — anything — before Copenhagen in December, that they're willing to become shameless hypocrites.

And Paul Driessen warns in an IBD Editorial Op-Ed:

If the pending Waxman-Markey energy and climate bill (HR 2454) becomes law, utility bills will soar. Farm and business energy costs will skyrocket — and be passed on to consumers, or defrayed by layoffs. Everything Americans grow, make, buy and do will be far pricier. And bureaucrats will control our lives.

Compared to no cap-and-tax regime, Waxman-Markey would cost the United States a cumulative $9.6 trillion in real GDP losses by 2035, concludes a study by the Heritage Foundation's Center for Data Analysis. The bill would also cause an additional 1.1 million job losses each year, raise electricity rates 90% after adjusting for inflation, provoke a 74% hike in inflation-adjusted gasoline prices, and add $1,500 to the average family's annual energy bill, says Heritage.

[Heritage's report is here.]

Fortunately, some members of Congress are interested in untying some of the existing Federal Gordian Knot. Rep. Michele Bachmann (R-MN) blogs about the newly-formed Sunset Caucus:
The Sunset Caucus is designed to shrink our ballooning government budget by eliminating federal programs, offices, and agencies that are duplicative or obsolete.

As Ronald Reagan once said, “a government bureau is the nearest thing to eternal life we'll ever see on this earth.”

As a member of the Sunset Caucus, I will select some program or agency that has outlived its usefulness, duplicates other government programs or that Congress never had any business creating in the first place. The fight for the taxpayers has to start somewhere.

The average federal program duplicates five other programs. For example, there are about 60 separate welfare programs, approximately 160 job training programs, and over 300 economic development programs. When American families are struggling to make ends meet, Congress should be looking for ways to tighten the government’s belt too, and this is a good place to start.

If we can’t make the easy decision to cut this kind of wasteful spending, is it is any wonder the American people are doubtful of Washington’s intentions to make the so-called “difficult choices.”
Break out the swords!

Tuesday, June 16, 2009

Space Poop

One of the challenges a designer should think about is that the real end-user may not fit the assumptions. Take the toilets on the International Space Station, for instance. From Pravda:

Until recently, Russian cosmonauts and US astronauts did not distinguish between their toilets and used the one that was closer. However, the food, which space researchers eat, differs greatly. The Russian space food is more savoury, more natural and more diverse, which US astronauts acknowledge too.

The menu of the Russian crew has over 300 dishes. Here is the daily menu of Valery Korzun, the commander:

Breakfast: curds and nuts, mashed potatoes with nuts, apple-quince chip sticks, sugarless coffee and vitamins.

Lunch: jellied pike perch, borsch with meat, goulash with buckwheat, bread, black currant juice, sugarless tea.

Supper: rice and meat, broccoli and cheese, nuts, tea with sugar.

Second supper: dried beef, cashew nuts, peaches, grape juice.

It just so happens that the consistency of fecal matter turns out to be rather thick against the background of such a diet.

The menu of US astronauts is nutritious as well, but it looks more like a diet ration and presumably consists of exotic fruit, vegetables, sea food and low-fat meat. That is why, their waste is much softer. Engineers took account of these peculiarities when designing the sewage system for the ISS. It just so happens that the solid Russian waste ruined the US toilets in space.

The astronauts were sick and tired of toilet breakdowns and unpleasant odors. NASA was eventually forced to order a toilet system from Russia. US tax payers paid $19 million for the space toilet. The new construction was installed in the US department of the ISS.

(H/T The Corner)

I don't really care if the story is completely factual or not. The fact remains that end-users seldom care about the design specs, and will find novel ways to use and abuse products over time.

Cross-posted at Thwarting Murphy.

Saturday, May 30, 2009

Pixie dust and magic wands

[Editor's note: Compuserve is closing down its OurWorld website hosting after many years. So I decided to resurrect some articles I had online there. This one dates from 1994. Not much has changed about organizational behavior in the intervening 15 years.]

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Fads and why they fail.

Lots of management theories have come and gone during the past century. When I was a supervisor at Ohio Bell in the late '70s, Management by Objectives was the hot theory that would solve all the company's ills, reduce labor strife, and guarantee that we focused on the important issues. Nowadays, MBO is old hat (even if recycled in The One Minute Manager) and Total Quality Management (TQM) books fight for shelf space with those for re-engineering corporations, reinventing government, activity-based costing (ABC), teaming, zero defects, and learning organizations.

Why do managers keep seeking the Holy Grail of management theory? Because the last technique no longer works, if it ever did. Managers understand that insanity is trying the same thing over and over and expecting different results. The logical conclusion, then, is that something else is needed. What managers seldom look at, though, is the way they seek to implement change.

Most management books are written for upper management, who are viewed as the ones who can direct change to occur within their organizations. They're also the ones who have the budgets to hire the consultants who write the books. The result of this focus is a top-down approach to creating change.

In the usual top-down approach, management become the cheerleaders for the new paradigm that will save their collective skins. They ensure that people get training in the new techniques. They lead very visible large-scale efforts that require lots of studies, lots of time, and lots of consultants and facilitators. Sometimes, they get lucky and get the results they want. More times, they don't.

The problem is that the fad du jour is treated like pixie dust or a magic wand. You wave it over the organization and wait for the magic to happen by itself. Yet substantial change only happens when people throughout the organization buy into, understand, and apply the prescribed theory. Change has to happen at the grass roots as well as at the top.

How you go about creating change is as at least as important as the change itself.

Stephen Covey tells us that creating new habits requires mastering the new skills, knowing when to use them, and having the desire to do so. Creating organizational change is akin to creating new corporate habits: the same rules apply. The management theories tell you what to accomplish, what skills you need to master. They seldom tell you how to get there.

Knowing and doing are two different things.

My boss and I were returning from yet another TQM training class when he bemoaned, "You know, TQM is a great theory. I just wish I knew how to apply it!"

We were liberally dosed with pixie dust. We learned a lot about TQM—except for the most important lesson of all: learning how to use it in the real world! Supervisors had "incentives" written into their performance plans (i.e. MBO) declaring that they would promote the use of TQM. Top management sported buttons showing an inverted organizational pyramid, declaring that they were there to support the front line people at the "top". People in the organization could truthfully say that they were aware of TQM, and that management generally promoted its use. But no one ever asked them if they were finding applications, integrating the TQM philosophy into their daily work.

There were some success stories. The most notable was the effort to revamp the entire process for submitting travel requests and processing the claims for reimbursement. This was a large project that involved several organizations. The head of the effort was our executive officer, someone with enough clout to authorize the changes once the new system was designed.

But there were also horror stories. One "Process Action Team" was so gung-ho that they dared to implement changes, without getting a by-your-leave from the department head first. He fully supported their studying the processes in the department, but taking action was another matter. The Process Action Team became a Process Study Team. Oddly enough, enthusiasm for TQM dropped sharply. The pattern repeated in other departments.

The department head knew about TQM. But he hadn't figured out how to unleash it without colliding with his values and beliefs about the proper way to enforce the "chain of command". The philosophy hadn't sunk in.

Tuesday, May 26, 2009

TNSTAAFL*

*There's no such thing as a free lunch.

Ralph Ellis, in an essay posted at Watts Up With That, outlines the challenges of dependency on renewable energy sources:
However, it is my belief that this sublime day-dream actually holds the seeds for our economic decline and for social disorder on an unprecedented scale. Why? Because no technical and industrial society can maintain itself on unreliable and intermittent power supplies. In 2003 there were six major electrical blackouts across the world, and the American Northeast blackout of August 14th was typical of these. The outage started in Ohio, when some power lines touched some trees and took out the Eastlake power station, but the subsequent cascade failure took out 256 power stations within one hour.

The entire Northeast was down onto emergency electrical supplies, and the result was social and economic chaos. Nothing, in our integrated and automated world, works without electricity. Transport came to a grinding halt. Aircraft were grounded, trains halted and road traffic was at a standstill, due to a lack of traffic lights and fuel. Water supplies were severely disrupted, as were telecommunications, while buildings had to be evacuated due to a lack of fire detection and suppression systems. Without any available transport, many commuters were forced to sleep in offices or in Central Park, and while the summer temperatures made this an office-adventure to remember, had this been winter the results of this electrical failure could have been catastrophic.

This is what happens to a major technical civilisation when its life-blood, its electrical supply, is turned off. Chaos looms, people die, production ceases, life is put on hold. Yet this was just a once-in-a-decade event, a memorable occasion to laugh about over dinner-parties for many years to come, but just imagine what would happen to a society where this happened every week, or if the power was cut for a whole fortnight or more. Now things are getting serious. Without transport, refrigeration, computers and key workers, food production and distribution would cease. Sleeping in Central Park on a balmy summer’s night is a memorable inconvenience, whereas fifty million empty bellies is getting very serious indeed. In fact, it is a recipe for violence and civil unrest.
He goes on to illustrate the costs associated with "free" renewable energy sources, due to the costs associated with a) converting them into electricity, and b) creating the spare generating capacity or energy storage systems required to match supply and demand. (He's from the U.K., so many of his examples relate to Britain or the European Union.)

Of course the costs for developing, installing, and operating those renewable energy resources mean green jobs, beloved of posturing politicians. However, Spain's experience should give us pause because those green jobs meant significant job losses elsewhere in the economy plus high taxes to subsidize them.

My problem with the green push is the rush to spend lots of other people's money in ways that bring little benefit to those paying for it other than feeling good that we're "doing something". As charities go, I'd rather get more bang for my buck. That's why I appreciate the work being done by Bjorn Lomborg.

Bjorn Lomborg, also known as "The Skeptical Environmentalist" and a frequent op-ed contributor, is Director of the Copenhagen Consensus Center. They "promote the use of sound economic science – especially the principle of prioritization – to make sure that with limited resources, we achieve the most ‘good’ for people and the planet." While they agree that global warming is a problem, their 2008 consensus ranked it far down the priority list of how to spend $75 billion over 4 years:
The experts considered four solutions in this area: investing only in mitigation; investing in mitigation and research and development into low‐carbon energy technology; investing only in research and development into low‐carbon energy technology; investing in a combination of mitigation, research and development and adaptation. Mitigation only and a combination of mitigation and R&D were given the lowest two rankings by the expert panel, due to their very poor benefit/cost ratio. The option including adaptation was discarded, as the adaptation is essentially included in nearly every other option presented to the Copenhagen Consensus. An
investment into research and development in low‐carbon energy technologies was ranked 14th by the expert panel.
(His related WSJ op-ed is here.)

I'm a fan of clean air, clean water, and a healthy biosphere. I remember when the Cuyahoga River caught fire in 1969 due to pollution. And that ten years later, biologists were astounded how many species of fish had returned once the pollution was cleaned up. In many ways, however, I think the environmental movement in the US has lost its bearings as it's won its case on egregious pollution. But it fights on, seeking more and more expensive remedies for less and less benefit.

Tuesday, April 28, 2009

Free Association

I've been thinking lately that the Republicans need a new message, focused on the positive and aspirational, rather than righteous indignation at the latest outrage committed by the Administration and Congress. And it has to answer "What's in it for me?"

A public that has been lulled into complacency, victimhood, and dependency on the munificence of the government needs to relearn the joys of the freedoms we inherited from the Founding Fathers and renewed each generation by legions of patriots.

I came across a couple of articles today, on entirely different topics, that still make powerful cases for freedom as a way of life. The first is a Newsbusters blog post about Senator Jim DeMint's commenting on Arlen Specter changing parties. Mr. DeMint said,
"We're seeing across the country right now that the biggest tent of all is the tent of freedom and what we need to do as Republicans is convince Americans that freedom can work in all areas of their life - for every American, whether it's education, or health care or creating jobs. [snip]

"What it means is what has worked in America are free people, free markets for years," DeMint said. "And what we see now is a government expanding into all areas of our economy, increasing spending and debt at levels we never talked about. Americans who are normally not even political are coming out to tea parties and protesting. These aren't Republicans or Democrats. These are just concerned Americans."
Over at Big Hollywood, Russ Dvonch waxes eloquent in his essay Heroic Hollywood: American Exceptionalism and the Hollywood Hero:

Freedom is fundamental to American Exceptionalism. The central moral idea of America is that individuals, by right, should be free to choose their own destiny and that the purpose of government is to insure the freedom of individuals.

And freedom is fundamental to the Hollywood Hero. Hollywood filmmaking assumes that the hero has free will. The Hero is presented with numerous moral choices during the course of the movie, just as we are faced with moral choices in life. When he makes the wrong moral choice, things go badly. When he makes the right moral choice…well, things may still go badly and it will be a tough fight, but in the end the good will win out.

The blessings of Freedom are the “opportunity and hope” that America (sic) Exceptionalism brings to humanity. And freedom is the inspirational message behind the Hollywood Hero.

Hugh Hewitt's favorite anonymous ad man isn't sanguine about the GOP getting its act together soon to craft a more compelling message:
If the momentum from the Tea Parties is to continue, it's up to individuals to continue it. Waiting for the GOP to pick up the ball and run could not only cost momentum - it could cost the game. The Tea Parties indicate that although the GOP still hasn't figured out 21st Century communications, conservative Americans most certainly have.
Sigh.

Monday, April 20, 2009

Carbon Insanity

The EPA has finally issued its proposed endangerment finding on greenhouse gases:

The Administrator signed a proposal with two distinct findings regarding greenhouse gases under section 202(a) of the Clean Air Act:

  • The Administrator is proposing to find that the current and projected concentrations of the mix of six key greenhouse gases—carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6)—in the atmosphere threaten the public health and welfare of current and future generations. This is referred to as the endangerment finding.
  • The Administrator is further proposing to find that the combined emissions of CO2, CH4, N2O, and HFCs from new motor vehicles and motor vehicle engines contribute to the atmospheric concentrations of these key greenhouse gases and hence to the threat of climate change. This is referred to as the cause or contribute finding.

Today’s proposed action, as well as any final action in the future, would not itself impose any requirements on industry or other entities. An endangerment finding under one provision of the Clean Air Act would not by itself automatically trigger regulation under the entire Act.

Of course not! But it certainly sets the stage for Congressional, administrative, and judicial mischief. Over at the Competitive Enterprise Institute, there's a letter from the Free Market Coalition to the EPA Administrator outlining some of the likely consequences:
That the endangerment finding will trigger a regulatory cascade threatening the economy is abundantly documented in EPA’s July 2008 Advanced Notice of Proposed Rulemaking (ANPR) and numerous comments on it. The endangerment finding will compel EPA to establish GHG emission standards for new motor vehicles under CAA §202, which in turn will make carbon dioxide (CO2) a pollutant “subject to regulation” under the Act’s Prevention of Significant Deterioration (PSD) pre-construction permitting program. In addition, the finding will be precedential for the endangerment test that initiates a National Ambient Air Quality Standards (NAAQS) rulemaking.

No small business could operate under the PSD administrative burden, even apart from any technology investments the firm might have to make to qualify for a permit. An estimated 1.2 million previously unregulated entities (office buildings, big box stores, enclosed malls, hotels, apartment buildings, even commercial kitchens) would become “major stationary sources” for PSD purposes. All would be vulnerable to new regulation, monitoring, paperwork, penalties, and litigation, the moment they undertake to build new facilities or modify existing ones. The flood of PSD permit applications would overwhelm EPA and State agency administrative resources, subjecting “major” sources to additional costs, delays, and uncertainties. A more potent Anti-Stimulus package would be difficult to imagine.

Since EPA plans to find endangerment on both health and welfare grounds, the Agency could be compelled to establish “primary” (health-based) NAAQS for GHGs. Logically, the standard would be set below current atmospheric levels. Even very stringent emission limitations applied worldwide over a century would likely be insufficient to lower GHG concentrations. Yet the CAA requires EPA to ensure attainment of primary NAAQS within five or at most 10 years—and it forbids EPA to take costs into account. Regulate CO2 under the NAAQS program and there is, in principle, no economic hardship that could not be imposed on the American people. (Emphasis added.)

The Washington Post, in an editorial, says it prefers Congressional action over piecemeal regulations:
Rep. John D. Dingell (D-Mich.), then-chairman of the House Energy and Commerce Committee, predicted last year that seeking to control climate change with such piecemeal regulation would lead to a "glorious mess."

The best way to stop this from happening is for Congress to adopt a more rational scheme, by putting a price on carbon with a tax (ideally) or a cap-and-trade market. Next week, Rep. Henry A. Waxman (D-Calif.), the current chairman of the Energy and Commerce Committee, will hold hearings on the discussion draft of comprehensive energy legislation that he and Rep. Edward J. Markey (D-Mass.), chairman of the energy and environment subcommittee, released before the Easter recess. While the proposal details many ambitious programs for renewable energy and efficiency, it is noticeably mute on the contours of a cap-and-trade system. Specifically, it doesn't say whether the pollution allowances would be auctioned or a portion given away to industry to ease the transition to a carbon-constrained economy. This is an important question, one whose answer will have a profound impact on the way Americans live -- one of many basic issues that should be settled by their representatives in Congress.

But the WAPO makes it sound as if regulating carbon by Congress is better than regulating carbon by the EPA. Why should carbon dioxide and the other 5 "greenhouse gases" be regulated more than they are now anyway?

I'll grant that human activity is the cause of anthropogenic global warming (AGW), because that's what "anthropogenic" means. However, is AGW a major driver of climate change?
Lots of questions that the political class in Washington doesn't seem interested in having answered. Meanwhile, check out the many ways CO2 benefits our lives. Beer anyone?