I have sent these comments to the House Select Committee on the Climate Crisis this afternoon. Thank you, Union of Concerned Scientists for your work in messaging out to the scientific community to ensure that our voices our heard on important climate policy steps that are responsive to good scientific information, and human impacts of human actions (and inactions) on climate change.
Pursuant to your request for comments, please find my personal comments embedded within your questions. They represent my personal opinions and are not to be considered representative of my employer or any agency or entity that I currently work with. Thank you very much.
Sincerely, Paul Ruscher, PhD, 20 November 2019 (pruscher@gmail.com).
House Select Committee Preamble
The climate crisis already is harming communities across America. The costs and impacts to the United States in the coming decades could exceed hundreds of billions of dollars annually. To limit global warming to no more than 1.5°C above pre-industrial levels, global net carbon pollution must fall by roughly 45% below 2010 levels by 2030 and must ultimately reach net zero by mid-century. Developed countries may need to reach this target even sooner.
To meet this aggressive goal, the U.S. government needs to lead an ambitious transition to clean energy and resilience that puts Americans to work, builds a just economy, unleashes American ingenuity, and prepares communities for the impacts of climate change. This transition must involve local, state, and tribal governments, businesses, academic institutions, non-profits, and all residents of the United States, including a rising generation of young people who are demanding climate action now.
The U.S. House of Representatives created the Select Committee on the Climate Crisis to “investigate, study, make findings, and develop recommendations on policies, strategies, and innovations to achieve substantial and permanent reductions in pollution and other activities that contribute to the climate crisis, which will honor our responsibility to be good stewards of the planet for future generations.”
The Select Committee has received recommendations from young climate leaders, policy specialists, business leaders, and state and local officials at meetings and hearings held in Washington, D.C. and around the country. To supplement our ongoing work, the Select Committee is seeking additional detailed input from a broad range of stakeholders.
To inform the policy recommendations of the Select Committee, please provide responses to the questions below by November 22, 2019 by emailing ClimateCrisisRFI@mail.house.gov. *This request is optional, and you need only reply to the questions that are relevant to your organization or expertise. Please submit your response as both a Word document and PDF.*
Myresponses are provided in green italics below. They are informed by over 30 years of professional work in the atmospheric, hydrological, and climate sciences, and broad experience in environmental quality in both air and water. I’m also a science educator and communicator. My brief biosketch appears at the end of this stakeholder response.
Sector-Specific Policies
1. What policies should Congress adopt to decarbonize the following sectors consistent with meeting or exceeding net-zero emissions by mid-century? Where possible, please provide analytical support that demonstrates that the recommended policies achieve the goal.
a. Transportation– fuel prices and fuel taxes
b. Electric power. The Select Committee would like policy ideas across the electricity sector but requests specific comment on two areas:
i. If you recommend a Clean Energy Standard, how should it be Commedesigned?
· I do recommend it. Create an expert panel that reports to Congress, EPA, and Department of Energy.
ii. How can Congress expedite the permitting and siting of high-voltage interstate transmission lines to carry renewable energy to load centers.
· I’m worried about expediting here, as eminent domain is problematic. First, have companies that operate grids participate in fact-finding. Such work needs to follow from part (i) here.
c. Industry
· provide tax incentives (short term investment credits) for investing in renewables, storage technologies, electric vehicle station provisions, retrofits to cleaner technologies (verified by DOE, EPA, as needed).
d. Buildings
· first incentivize new green building standards be used (5 years or so), then require them for all new government buildings and all buildings which use federal funds directly or benefit from any federal tax breaks.
In all cases, an equity lens/social & environmental justice perspective should be deployed as measures are contemplated for regulation, legislation, or remediation. Some of my recommendations below may seem harsh, and I don’t address that equity concept directly in each component, as it should be at the center of any discussions. We should be seeking sustainable approaches that do not harm disadvantaged populations in particular.
Essential will be a rational data-driven way to measure carbon and its impacts (all of its impacts) and also to account for its cost in terms of any and all subsidies and public health impacts.
2. What policies should Congress adopt to ensure that the United States is a leader in innovative manufacturing clean technologies; creating new, family-sustaining jobs in these sectors; and supporting workers during the decarbonization transition?
· Job training programs in areas that are highly dependent upon oil drilling and transportation, gas extraction, and coal mining should be top priorities.
· To the extent possible, use industry best practices with a federal commission designed to create standards that can be met and can be certified as clean. These technologies more than pay for themselves and that should be incentive enough for family-sustaining jobs.
· A federally mandated minimum family wage would help here.
· In addition, removing tax credits for those with 2nd(or more) homes, yachts, privately-held aircraft, and the energy-related expenses that are write-offs for these deductions that only benefit the top 10% of earners in the economy. This would provide economic stimulus to the federal treasury to help to fund at least some of the incentives and initiatives that I’m suggesting here.
3. What policies should Congress adopt to ensure that environmental justice is integral to any plan to decarbonize these sectors?
· First, the environmental justice program must be restored within the EPA and funding increased substantially above what it was during the Obama and earlier administrations.
· There must be recognition of how opportunity zones have been prioritized to incorporate or include luxury housing at the expense of federal taxpayers, seriously diluting opportunities to improve livelihood for those who’ve been most seriously impacted by environmental injustice issues.
· There should also be increased prioritization towards remediation in particularly guided not only by the severity of the environmental hazard noted, but also by a metric which accounts for the “injustice” sustained by not having the remediation appropriately prioritized by community impacts in the past.
Cross-Cutting Policies
4. Carbon Pricing:
a. What role should carbon pricing play in any national climate action plan to meet or exceed net zero by mid-century, while also minimizing impacts to low- and middle-income families, creating family-sustaining jobs, and advancing environmental justice? Where possible, please provide analytical support to show that the recommended policies achieve these goals.
· There must be an increased fuel use tax; our gasoline and diesel prices for automobiles and trucks are ridiculously low (see related data at the end of my statement).
· A carbon tax must be assessed that properly weighs costs of raw materials, impacts of use, public health impacts, and any government subsidies that are in place.
· States should be enabled to also increase their own fuel taxes to help where federal infrastructure funding has been inadequate to support state and county/city highways, bridges, etc.
· Also facilitate charging by road use (miles per vehicle) if an all-electric or all-hydrogen vehicle is using the roads, as these should also pay into the maintenance system after a certain period of time. Incentivize the first 5-10 years of transition, then charge road miles for all users as you generate > 50% renewable fuel usage in the vehicle fleet.
b. How could sectoral-specific policies, outlined in questions 1-3, complement a carbon pricing program? I favor a carbon tax moreso than carbon trading, which would tend to enrich non-impacted communities (such as fiscal entities who already have capital).
5. Innovation:
a. Where should Congress focus an innovation agenda for climate solutions? Please identify specific areas for federal investment and, where possible, recommend the scale of investment needed to achieve results in research, development and deployment.
· We need a NASA-type of innovation here. The Office of the Federal Coordinator for Meteorological Services and Supporting Research, or the Office of the Federal Coordinator for Meteorology (OFCM), as it is more widely known, could be used as a model to create an Office of the Federal Coordinator on Climate Solutions Engagement (OFCCSE). OFCM facilitates cooperation between and collaboration among 15 federal agencies. This problem we are facing is a crisis, and is too big for one agency. The White House Office of Science and Technology Policy and Congressional Science Office should also both be engaged in this work, along with the Executive Branch functions. We need a broad physical, life, earth and social science community working together with policy-makers who don’t question the science that is driven by data.
b. How can Congress incentivize more public-private partnerships and encourage more private investment in clean energy innovation?
· Again, NASA provides some examples here. With the loss of the space shuttle program, and partnerships with Russia and private companies that have kept our astronaut corps busy and space-based research and operations functional, and the USAF involvement, too, we have plenty of models about how to make this work. But using a Department of Defense model is no good as it perpetuates the military-industrial complex model that Ike warned us about in his departure address almost 60 years ago. We need a moon-shot approach.
· We also need to realize that the economic model naysayers have not proven to have any skill whatsoever in forecasting costs to the economy of “greening” or incentivizing green tech. There is much information spewed out about how cost-effective getting oil, fracking for gas, or mining coal is; yet the true costs are never factored in to their “analyses.” They have been overly and overtly pessimistic. The truth has been much more positive, with renewables becoming cheaper faster, while the negative health impacts of drilling, mining, and transporting fossil fuels continue to kill and injure tens of thousands annually in the USA.
Agriculture
6. What policies should Congress adopt to reduce carbon pollution and other greenhouse gas emissions and maximize carbon storage in agriculture?
· We must recognize that agriculture, including both growing of crops and managing livestock, are essential to our having sufficient food (and raw materials for textiles and essential fiber-based materials, for example) production to meet the needs of all Americans, and also to facilitate our ability to export and import and participate in fair international trade.
· Transportation costs are high for agriculture. But carbon pollution can be reduced if there are incentives to convert to renewable fuel standards and vehicles on large farms in particular.
· Use of fewer chemicals, many of which derive from fossil fuels, or through natural environmental changes which can then produce greenhouse gases, will also aid this transition to less overall reliance on carbon in our agricultural economy, and less greenhouse gas pollution.
· There should also be rational use of agricultural subsidies in areas where the climate is suitable to grow certain crops – based on availability of water in a given watershed, soil health, and other factors grounded in agricultural scientific research. It makes no sense for the federal government and taxpayers to pay farmers or ranchers to grow or maintain crops or livestock in areas where the climate in that region would not ordinarily support such practices. Cotton or alfalfa in the Arizona desert for export to China? No.
7. What policies should Congress adopt to help farmers, ranchers, and natural resource managers adapt to the impacts of climate change?
· Large corporate farms, ranches, and many government natural resource areas (including offshore) could be useful for consideration of deployment of wind, solar, and tidal energy. These could provide economic offsets to take some land out of production, as an example, particularly if the environmental and economic costs to get a crop are too high to make a profit for the farmer. Such transitions are occurring in northeast Oregon at present as farmers are leasing land to wind farm deployment and earning higher incomes than they can for crops, and there are no transportation costs for their commodity (to the farmer or rancher).
· Encouraging natural resource managers to restore wetlands and habitats such as oak savannahs, both of which have largely disappeared from the landscape, have positive conservation benefit.
· Selective harvesting of trees done renewably in a more natural way that also creates better survival strategies against blights and pests would likely provide healthier forest lands that would be more sustainable. Increased utilization of renewable and recyclable building materials in federal projects or federally supported projects would facilitate economically-sustainable natural resource management in the private sector. (also relates to #8)
Oceans, Forestry and Public Lands
8. How should Congress update the laws governing management of federal lands, forests, and oceans to accelerate climate adaptation, reduce greenhouse gas emissions and maximize carbon storage?
· I hate to suggest that we start over here, but with the changes implemented related to environmental and natural resource laws and regulations over the past 30 months by the present administration, a simple reversal of policies invoked by EPA, Agriculture, Interior, Commerce, and Health and Human Services (to name a few) will be inadequate to meet the demands that we must address with respect to our substantial needs in these areas. Obviously, we must take a leadership role in the IPCC frameworks and committees, including returning to the Paris Accord, and doubling down on increasing environmental protections to reverse course and recover all of the lost ground that would have been created since 2017, had federal action not been deployed to counter rational scientific practices in environmental and climate policy.
· Continuing to move forest policy towards more effective strategies for restoration using fire and proper thinning to natural techniques must be deployed on a wider scale.
· Disaster funding should be managed differently with respect to large wildfires that negative impact communities (like some recent California fires), without the threat of federal fund removal such as we’ve heard recently from the White House. In addition, the use of forest service budget funds to fight wildfires as disasters limits the productive use of resources to prevent future large-scale fires, and to develop prevention strategies.
· Public health measures must be in use to assure the public that those who are sensitive to smoke during increased cooler season fire activity have ways to mitigate potential problems.
· While we are at it – Congress should move to restore the important work done to resurrect in some form the 2015 Waters of the United States (WOTUS) rule that was repealed in 2017. Please. Climate change impacts the hydrologic cycle significantly, and that has deleterious impacts on water availability and quality.
Non-CO2Greenhouse Gases
9. What policies should Congress adopt to reduce emissions of non-CO2greenhouse gases, including methane, nitrous oxide, and fluorinated gases?
· First of all, these are all greenhouse gases, and they are generally more potent than CO2— this is something that is often overlooked, as many non-acceptors claim that CO2is just a fertilizer and is all good. There is horrible government misinformation being shared by policymakers on this topic, and this is finding its way into mainstream educational systems by false and misleading nonprofit agencies with an anti-climate science bias, supported by political power brokers in Congress and the White House.
· There needs to be a good science-based framework for estimating natural and anthropogenic emissions for all of these gases that do not rely solely on industry-reporting criteria.
· Further, there should also be scientific agreement for how these CO2-eq (carbon dioxide equivalent emissions) for these other gases are arrived at. And since direct emissions of regulated pollutants should include greenhouse gases, there should be legislation that enshrines the 2007 Massachusetts v. EPA Supreme Court Decision into federal law, to include them specifically, and through appropriate updates to the Clean Air Act. The IPCC has a guide for us here, and these estimates will be updated in its AR6 report due in 2021.
· In addition, the US EPA should further regulate many of these 6 gases at lower exposure levels to protect public health, and include at least mercury in its inventory of regulated air pollutants, as suggested by scientific research over the past several decades.
· It may be also useful to consider increased atmospheric and/or environmental system temperature (e.g., of soils and forest canopies) as a possible criteria pollutant as an impact on disease and on human and ecosystem health, as it is for water temperature, which is already considered as a criteria pollutant in the Clean Water Act, in particular for ecosystem health. Our emissions (and global emissions) are clearly responsible for more negative impacts on human health, particularly in regards to heat stress, as a result of anthropogenically-driven climate change.
· The cost of inaction in our transportation and utility sectors on improving our renewable energy portfolio is not a partisan problem; there needs to be bipartisan Congressional support that is sound and meaningful, and such support has also been demonstrated that it is also sound and can drive community improvement with regard to economic and environmental justice concerns.
Carbon Removal
10.How can Congress accelerate development and deployment of carbon removal technology to help achieve negative emissions?
· Incentivizing research into carbon capture and storage may help, but would require both strategic short- and long-term investment. Such investment is not likely to have any short-term impacts, but further basic research investment may trigger new breakthroughs.
Resilience and Adaptation
11.What policies should Congress adopt to help communities become more resilient in response to climate change? The Select Committee welcomes all ideas on resilience and adaptation but requests comments on three specific questions:
a. What adjustments to federal disaster policies should Congress consider to reduce the risks and costs of extreme weather and other effects of climate change that can no longer be avoided?
· The National Flood Insurance Program needs to be reimagined to ensure that communities, businesses, and individuals are not entitled to re-build on existing and changing floodplains at taxpayer expense. Relocation expenses should be reasonable and required, if federal flood insurance is to be used as compensation for anything other than short-term emergency assistance.
· Exceptions could and should rationally be provided within Federal law for US states and territories consisting wholly of islands or archipelagos, including the Alaskan Aleutian Islands, Hawaii, Puerto Rico, US Virgin Islands, and parts of Micronesia, cognizant of the practicality that such areas are small in scale compared to hazards that create flooding (e.g., tropical cyclones), and also cognizant of environmental justice issues for these communities. Barrier islands adjacent to the contiguous United States including Alaska should be excluded from this provision owing to their inherent geological instability.
· There should be federal laws requiring disclosure of any geophysical or environmental hazards on a property, past, present, or future, related to any change in land use or real estate transaction. Lack of this disclosure requirement by a state should provide a remedy for citizens, as the state would retain regulatory authority.
· There should be government payout or buy-back provisions available one-time for any homeowner impacted negatively by these decisions to assist them with relocation expenses.
b. How can Congress better identify and reduce climate risks for front-line communities, including ensuring that low and moderate-income populations and communities that suffer from racial discrimination can effectively grapple with climate change?
· Stormreadiness is required and evacuation and shelter plans should be optimized and required to protect these communities. We should never have another Katrina (New Orleans), Paradise fire (California), or Hurricane Maria (Puerto Rico and US Virgin Islands) situation that leaves people both unprepared and unable to recover.
c. What standards and codes should Congress consider for the built environment to ensure federally-supported buildings and infrastructure are built to withstand the current and projected effects of climate change?
· All Gulf and east coastal properties from Brownsville, Texas to northern Maine should have building codes sufficient to allow structures to withstand category 3 tropical cyclone winds and storm surges (locally defined based on SLOSH or other federally-established storm surge models) with relatively minor damage, for any government funded or insured construction. It should be highly recommended for others and federal insurance liability reduced and responsibility taken over by the state (if more loosely regulated) or private insurance company or property owner.
· Eventually, west coast states will also need increased standards for resistance to hazards associated with climate change, including a likely northern range extension of tropical cyclones, and more intense and or more frequent winter season coastal storms attendant with sea level rise, with both wind and water hazards.
· As indicated earlier, special consideration may have to be extended to Caribbean or Pacific Island states or territories of the United States.
· Large number of dams in the western United States could be severely damaged by heavy winter precipitation associated with increased storm activity and less snowfall, and/or rapid snowmelt. These events would be occurring simultaneous with a lack of infrastructure maintenance on these dams and in the downstream river channels, increasing flooding hazards in densely populated areas.
Climate Information Support
12.Our understanding and response to the climate crisis has relied on U.S. climate observations, monitoring and research, including regular assessment reports such as the National Climate Assessment. What policies should Congress adopt to maintain and expand these efforts in order to support solutions to the climate crisis and provide decisionmakers – and the American people – with the information they need? Where possible, recommend the scale of investment needed to achieve results.
· The United States is a world leader in climate research, weather and climate observation technology development, whether deployed on the ground or in space, and has the scientific capacity to do much more to advance our understanding of the earth system, and what humans are doing to make its natural functioning more difficult. Across the life, physical, and earth sciences, there have been drastic cutbacks to basic and applied scientific programs in many of the federal agencies. Policy setbacks in energy, food, water, and climate issues in federal agencies within Agriculture, Commerce, EPA, Health & Human Services, Homeland Security, and Interior have stalled progress in factors related to better understanding of the system, mitigation and adaptation strategies, and international cooperation and United States participation in developing global strategies. As a climate scientist and science educator for over 30 years, I find the policy changes over the last 33 months to be not only disruptive to our progress on understanding of the earth system, but also it is demeaning to the scientific community, and disheartening to agency employees who work on these issues with others. The elimination of scientific advisory boards and councils within some of these agencies removes the benefit of an external lens through which policies under consideration are vetted. The proposed “full disclosure” policies that are under consideration, which can lead to a lack of protection of private information (by industry patent, health information of study participants, etc.), and would delay progress by years. I also suffer from public health impacts of poor air quality myself, and so have lived my entire professional career with this personal perspective as well.
· The investment required should involve a combination of enhanced direct observation systems for land (including soil and forest health, and remediation), ocean observing (globally), and air (direct surface measurements and enhanced capabilities for supporting rawinsonde and other direct measures of the atmospheric boundary layer where fluxes of gases and energy are inadequately monitored, except in some locales). In addition, technological developments in remote sensing provide opportunities to strategically monitor the same aspects of the earth system from space, yet our ability to protect investments in these assets remain compromised, and the selling off of the radio frequency spectrum to the highest bidder interferes with many of these existing and coming remote sensing technologies. The FCC needs to respond to concerns by NOAA and NASA scientists in particular to reign in these actions which will harm advances in earth monitoring and weather forecasting. Improvement in ability to monitor and understand the climate system will also yield better results projecting human actions (or inaction) into the future with climate modeling systems. The US is a leading participant in this important work, and can increase influence in the IPCC framework agreements, but only if we play our role as an honest partner. Climate modeling investments will need to be included in this strategy.
· Finally, the tacit incentivizing of enhancing coal extraction/mining across the United States should be stopped, and accompanied by useful programs for workers and families in coal mining regions to protect their health and livelihood. As mining operations are stepped down, increased monitoring to support miner safety should be deployed, health benefits should not be withdrawn or withheld from any minors who are already suffering from injury or lung, heart, or vision systems impacts, and ongoing monitoring for any impacted employee or community member of mining or transportation operations should be established. Further, water quality impacts from long-term storage of coal mining residual materials should be assessed and better strategies deployed for restoration of these spaces to natural habitats. Proper waste removal should be paid for by companies that created the problem and government funding should be put in place for remediation in the event that the companies’ have escaped liability through bankruptcy or other means. In addition, any further mining activity that occurs on federal lands or is regulated by federal policy on other lands should require a realistic indemnification against environmental harm (including human public health issues).
· The indirect benefit to air quality (including particulate matter standards and gases that can influence cardiopulmonary function) that greenhouse gas controls can provide should also not be ignored in an attempt to establish legal or regulatory authority; this work would likely require important Congressional authorization, work, and oversight.
· Congress should increase support for agency participation in IPCC, national climate assessment reports, and the scientists whose work goes into formulating our best understanding of how the climate is changing and why. Mitigation and adaptation strategic planning is also important to be reckoned with. Just because we already know the reasons why we are impacting our climate system so negatively with much of our understanding complete, does not mean we have all of the answers. Predicting the future is hard, and projections into decades beyond even tougher. But reducing investment in research is a strategic mistake at this time.
International
13.The climate crisis requires a global response. U.S. leadership is critical for successful global solutions. What policies should Congress adopt to support international action on the climate crisis?
· Resume our participation in the Paris Accords.
· Strengthen our resolve to lead the world in reduction of greenhouse gas emissions by advancing “green” energy policies in the utility, transportation, and construction sectors of the economy.
· Increase the cost of using carbon-based technologies, all of which increase the human carbon footprint, worsening the climate crisis, to reflect the true cost of carbon use. By establishing a common understanding of greenhouse gas equivalents for all greenhouse gases and also establishing the true cost of carbon, based on sound scientific and economic principles, we will better be able to develop sensible policies to address our government’s response, and own up to our legacy as the world’s historically greatest contributor to the greenhouse gases that have been emitted over time.
· Educate the public towards not being driven by a consumer-driven attitude, and encourage people to use and waste less materials.
In addition to your responses to any of these questions, please include any other specific policies that you think Congress should adopt to solve the climate crisis and adapt to the impacts of climate change.
Note: The Select Committee may choose to publish your responses in whole or in part. All responses will become part of the permanent committee record in the National Archives.
Short Commenter Biography
Dr. Paul Ruscher, PhD, is the Dean of the Science Division at Lane Community College in Eugene, Oregon. He has spent over 30 years working in scientific research and education in the atmospheric and environmental sciences, including work in atmospheric chemistry/air quality, climate studies, and geoscience education. He earned his PhD in Atmospheric Sciences from Oregon State University and spent 25 years at Florida State University (FSU) as a professor and research associate in the Geophysical Fluid Dynamics Institute before moving back to Oregon. He has served on numerous national review panels and worked with state and federal agencies on meteorological and education issues, including a present assignment with the Oregon Department of Education related to K-12 science standards.
He is a Fellow of the American Meteorological Society, was a climate change fellow of the Translating Science/Telling Stories program at Michigan State University and the Society of Environmental Journalists, and was the recipient of an annual transportation planning award by the Federal Highway Administration for his work on the “Conserve by Transit” program at FSU. Ruscher is also a collaborator with the international GLOBE program, which is sponsored in the US by the National Science Foundation and NASA, with support from NOAA.
Selected References and Data Citations
Dessler, Andrew, 2015,Introduction to Modern Climate Change, 2e, Cambridge University Press, 267 pp.
US Global Change Research Program, 2018, Fourth National Climate Assessment, Volume II: Impacts, Risks and Adaption in the United States, https://nca2018.globalchange.gov.