Category Archives: climate change

Action 156. Tell the administration to stop doing stupid math and start doing good science.

Executive Order 13771 (82 FR 9339, February 3, 2017) on Reducing Regulation and Controlling Regulatory Costs directs all agencies to repeal two existing regulations for each new regulation issued in FY 2017 and thereafter. It further directs agencies that the “total incremental costs of all regulations should be no greater than zero” in FY 2017.

You guys. Did you read that? Seriously, did you read that bad math? Based on WTF law of bad math is the administration devising this Executive Order (EO) to take two steps back for every one step forward? .

This piece of wisdom is part of a trifecta of EOs steeped in bad math and science dubbed “Regulatory Reform” on which the EPA is asking for public comment through May 15.  In addition to random reductions in regulatory ‘rithmetic, the relevant EOs also set up a “Task Force… to evaluate existing regulations and make recommendations to the agency head regarding their repeal, replacement, or modification” and “directs the EPA to review the Clean Power Plan, related rules and the NSPS for Oil and Gas, and all agencies to review existing regulations, orders, guidance documents and policies that potentially burden the development or use of domestically produced energy resources.” It doesn’t take much reading between the lines to see that the point of these orders is to push the EPA backwards on any kinds of regulations that might stand in the way of the dinosaur fossil fuel industry.

The EPA is asking for your feedback, dear reader, and I ask you, please take a few moments to do this; because besides you, me and the folks who are actually protected by the EPA’s regulation to protect our common resources and care to comment, you can guess who else is going to be providing comment: the industries that would love to be regulated a whole lot less.

Here are the comments I submitted to EPA this week:

Dear EPA:

Thank you for the opportunity to comment on the regulatory reforms that are proposed as part of Executive Orders 13771, 13777, and 13783.

As a Ph.D. environmental scientist who has worked for local, state, and federal regulatory agencies as well as in private industry sitting both on the same side of the table with and across the table from EPA and other federal regulatory agencies, I am well informed about the role of the EPA in safeguarding our nation’s air, water and natural resources. In addition, as a parent and an educator, I recognize the importance of these regulations for safeguarding my children and our future generations.

In light of my experience and priorities, I speak to the executive orders and to Director Pruitt’s evaluation of existing regulations with extraordinary concern for the integrity of the mission of this agency, and I have the following comments regarding these proposals:

Executive Order 13771 “directs all agencies to repeal two existing regulations for each new regulation issued in FY 2017 and thereafter. It further directs agencies that the “total incremental costs of all regulations should be no greater than zero” in FY 2017.” I find it fascinating and obscure why the EPA should be directed to play a zero-sum math game with its regulations. Is the administration interested in basic arithmetic, or should they perhaps be more interested in how the agency fulfills its mission? Is there any shred of scientific basis for assigning such arbitrary conditions? I also believe that we the public deserve to understand what is meant by “total incremental costs no greater than zero”. It would seem to me that the total incremental costs of thousands of additional deaths caused by plans to roll back the Clean Power Plan might be greater than zero. Or the loss of natural resources and access rights to public lands caused by re-opening our public holdings to drilling and mining, that might possibly cost We the People a bit more than zero. I do so hope that the administration is intending to consider that these are more-than-incremental costs that most certainly will need zeroing out for consistency with such a policy.

Executive Order 13778 seeks public input on existing regulations. Here is my input on existing regulations: the EPA should be encouraged and supported to continue to regulate the discharge of pollutants into our air, water, and environment to safeguard the health and well-being of the American public. This includes regulation of greenhouse gas emissions, as such emissions are known to contribute to climate change and contributes directly to increased risk to our health, safety and national security through multiple mechanisms including global destabilization, drought, wildfire, hurricanes, sea level rise, oceanic food chain collapse, and multiple other mechanisms which threaten the lives and livelihood of the American people. Attempts by Director Pruitt or this administration to undermine regulation of greenhouse gases and other discharges of pollutants that are done with the sole purpose of short-term economic benefit to specific corporate stakeholders and without regard to the enormous costs to broad segments of the American public and multiple other economic stakeholders including fisheries, tourism, coastal real estate, agriculture and others, is a dereliction of duties with which the EPA is charged.

Executive Order 13783 directs a review of “regulations, orders, guidance documents and policies that potentially burden the development or use of domestically produced energy resources.” This review must consider that the proposed attempt to roll back the Clean Power Plan and associated regulations has significant potential to unduly burden the clean energy industry of the United States, an industry which is promises entirely domestically produced power that is quickly approaching grid parity if not lower costs than fossil fuel sources of energy, and does so with many fewer negative economic and environmental impacts on the American people than does fossil fuel-based energy. In addition, the review should evaluate how fossil fuel industry subsidies lead to an absolutely unfair and inherently anti-capitalist, non-free-market advantage to these dinosaur industries and create a burden on clean energy technologies which have every right to compete on a level playing field with traditional energy sources.

In conclusion, I would like to thank the scientists and staff of the EPA for their incredibly hard work that they do every day to protect our air, land, water and health. I hope and expect our agencies will continue to be able to fulfill their mission in an environment that is fair, open, and supportive of objective, science-based decision making.


Deborah Rudnick, Ph.D.


Action 145. What can you and I do about the Porter Ranch disaster?

If I had more of a sense of humor about climate change, I might find the Porter Ranch/Aliso Canyon natural gas leak almost funny, in a kind of take-your-Paris-accord-and-shove-it kind of symbology from a vengeful god. As it is, I’m mainly just really pissed off.

If you haven’t yet heard about Porter Ranch, this is the massive gas leak that started in late October 2015 that is one of the largest such leaks from an underground natural gas facility in US History. Methane and odorizing chemicals have been pouring from the leaking shaft, sickening thousands of residents, causing local community upheaval, and spewing persistent and powerful greenhouse gases into the atmosphere. According to the LA Times,

In three months, one failed well at Southern California Gas Co.’s Aliso Canyon storage field has spewed more greenhouse gases than any other facility in California. At its height, the leak more than doubled the methane emissions of the entire Los Angeles Basin and surpassed what is released by all industrial activity in the state….Long after the leak stops and the foul odors vanish, the pulse of methane will remain in the atmosphere and its damage to the climate will go on.

You can learn much more over at the LA Times which has a whole section devoted to covering the many impacts of this catastrophic leak. Southern California Gas, who owns the facility, has said it will be at least the end of February before they manage to stop the leak.

For good measure, here’s an eye-popping graphic on an emissions statistic, courtesy of the LA Times:


California has 14 underground gas facilities, and both state and federal oversight is lacking regarding the safety technology, monitoring requirements, and other policies that would help keep these facilities safer from leaks. The reality is that many companies that are aware of weaknesses in their safety regulations or infrastructure will wait until regulatory agencies make them deal with it. They, like everyone else, weigh the risks and benefits of saving money and making profits, and the agencies that oversee them so far have certainly not been asking enough of them.

It is incredible how many times we have faced environmental disasters in our recent history just like this- Deepwater Horizon, Flint’s water supply debacle, the Mount Polley Tailings Dam breach are just a few that come to mind- which were probably preventable, and certainly many of the worst impacts would have been avoidable, if proper safety, monitoring and oversight had been in place. Unfortunately for Southern California Gas, the safety checks they could have put in place that would have done a lot to prevent this disaster would have been a LOT cheaper than the regulatory backlash and legal proceedings they will be facing for years to come.

So rather than sit here fuming (pun intended), what’s a non-Californian to do about a serious environmental and public health catastrophe that feels very out of reach? There are at least some things within my grasp that I can do about the immediate issue.

I can and have and will continue to call the White House repeatedly and asking why the federal government is not putting every single piece of expertise, technology and form of pressure to bear on this catastrophe.

I have also signed- you can too right at this link: the CREDO petition to President Obama essentially saying the same thing.

And, very importantly, we can start mobilizing to make sure that more gas leaks like Porter Ranch are not in our future. California legislators are rushing to propose several new laws that would increase regulations for safety, technology and monitoring to prevent future disasters like this one. Federal agencies and congress are also starting to mobilize with new plans and proposals for increasing the consistency and stringency of these regulations.

With about half a million producing natural gas wells in the US, and more than 300 underground gas storage sites, with many heavily concentrated in the midwest, you have a very good chance as a resident of any state to live in the vicinity of natural gas production, and to have a voice and a stake in the proper regulation of this industry. I will be calling my representatives to support stronger regulation that protects all of us and our climate from the type of devastation we have seen from the Porter Ranch leak. We absolutely cannot afford more of these types of disasters if we are to make progress in controlling greenhouse gas emissions.

Action 135. More encouragement on carbon pricing!

This last week, my Governor, Jay Inslee announced the Carbon Pollution Accountability Act. What timing, we were just talking about carbon pricing in my last action! He must have known. 🙂 Inslee’s  plan aims to create a cap and trade program that aims to cover 85% of our state’s emissions, with- and this is important – no giveaway allowances to polluters. Initial giveaways that are supposed to “ease polluters” in and make the transition to carbon pricing more palatable also have the unfortunate side effect of undermining the entire point of pricing carbon in the first place, i.e., creating an economic incentive to pollute less. We’ve seen this really hobble the EU carbon market, and Inslee’s plan does not allow for it. Other important components of Inslee’s plan include subsidies back to low-income families that will be most burdened by the pricing, and the funds are proposed to be reinvested right back into state priorities that matter a great deal to our green economy- namely, education and infrastructure.

Insee does not have an easy task before him. Our Democratic representatives that tend to look more favorably on carbon pricing and addressing climate change lost ground in our mid-term elections to Republicans, and this will mean a long, uphill battle to move any legislation forward. All the more important that we reach out to our representatives and let them know this is an issue about which we care deeply.

Although as I said in my last post, I prefer the carbon tax model over carbon cap and trade, what I am for is ANY discussion and movement on carbon pricing that moves us in the right direction, so we can start internalizing these costs and making good on our state’s promise to reduce emissions. And as I also mentioned in my last post, politicians tend to favor cap and trade for its institutional certainty and longevity, plus its avoidance of the evil “tax” word. So I’m not surprised this is the route Inslee has chosen, and I want my reps to know I am thrilled that Inslee is forcing a serious discussion about carbon pricing as a way to meet our promises to the region to reduce our emissions. Here’s the letter I wrote my three reps:

Dear Senator/Representative… :

I was thrilled to hear the details this week of the Governor’s Carbon Pollution Accountability Act. As I am sure you know, the Governor’s plan is a bold and comprehensive approach to pricing carbon that does several really important things: brings accountability and cost internalization of carbon pollution back to the polluters; provides a mechanism for accelerating our transition to a clean energy economy; and provides a funding mechanism for sorely needed budgets in education and infrastructure. I was also extremely pleased to hear that the plan includes a mechanism to offset some of these costs for low-income families, so that the burden is not unduly felt by those who have fewer resources to shoulder the additional costs.

I know that you will be supportive of the Governor’s plan- it is so critically necessary to move us forward on climate change actions, and it just makes good environmental AND economic sense. I just want you to know that I as your constituent am thrilled that our state is showing leadership on climate and really trying to provide the people of Washington- and the country and the world- an example of how we can reduce our emissions and maintain a vibrant economy all at the same time. Its not one or the other. I know this will be an uphill battle with some of your colleagues to prove this obvious point- I just want you to know I am supporting you and the Governor on this commitment to move forward.

Thank you!

I dont kid myself that the Governor’s plan is a political long shot; opposition within and outside of the capitol will be substantial. But it is critical that our elected leaders continue to hear from their constituents that carbon pricing is essential to reducing our greenhouse gas emissions, and we can no longer afford to push these strategies and solutions off to the future.

Action 133. Here we go again: Keystone write, call, yell, repeat.

Wellllll that didn’t take long. Just a few short days after the mid-terms and I found myself on the phone, once again calling my senators to ask them to vote No on Yet.Another.Keystone XL Pipeline.Bill! In an interesting twist, this push came from the Democratic side of the aisle, from embattled, runoff-bound Senator Mary Landrieu– whose opponent Mike Cassidy just happened to introduce its parallel bill in the House. Right, not a coincidence. Nothing like making a multi-billion dollar boondoggle into your last best hope for fighting for the same conservative voting block.  Not that her position is particularly surprising, given the roughly $1.5 million dollars she’s taken for her campaign coffers from the fossil fuel industry.

Side note: John Stewart’s piece ridiculing Landrieu’s endgame on Keystone is well worth watching.

So, back to the phones and emails and petitioning it is. Not that my senators would vote for Keystone. Nor did they. I happen to have pretty great senators who know the extremely basic math of why Keystone makes no sense from an economic or environmental standpoint. However, it is important to keep pushing on this issue, and let our representatives know that this is important. Landrieu’s attempt this week fell one vote short of what she needed to pass the bill. When the republican-controlled Senate convenes in January, you can bet your bottom dollar Keystone will come right back up again, front and center.

And next time, it will probably pass. I’m not naive about that likelihood. But nor am I going to go down without a fight, nor will my fellow Americans who understand that this pipeline is bad for us, bad for our environment, bad for our climate, and does nothing for our economy or our energy independence. We can hold out small hope that the State Department will give a more thorough and reasonable review of the latest permit application, and come to similar conclusions. And/or, it remains to be seen whether the Nebraska landowner lawsuit that is challenging the right of TransCanada to condemn private property for the pipeline will be upheld- we should hear more on that in the next few weeks. In the meantime, we have to keep to keep yelling.