If an E-Mail Is Unopened by the White House, Does It Still Exist?

The Supreme Court's decision in Massachusetts v. EPA that carbon dioxide and other greenhouse gases are pollutants under the Clean Air Act made the eventual regulation of GHGs under the Act a foregone conclusion. Nonetheless, the Bush Administration has been dragging its heels in making the requisite legal findings that would trigger regulatory measures in an effort to delay the inevitable. This morning, the NYT reports on a bizarre twist in this story:

The White House in December refused to accept the Environmental Protection Agency’s conclusion that greenhouse gases are pollutants that must be controlled, telling agency officials that an e-mail message containing the document would not be opened, senior E.P.A. officials said last week.

The document, which ended up in e-mail limbo, without official status, was the E.P.A.’s answer to a 2007 Supreme Court ruling that required it to determine whether greenhouse gases represent a danger to health or the environment, the officials said.

Now the EPA is preparing to release a "watered-down" version of what was contained in the December e-mail that outlines the government's options and will not, in itself, require more regulation.

The Times story also notes that the White House forced the EPA to eliminate certain portions of its analysis, such as the Agency's conclusion that regulating greenhouse gases could produce $500 billion to $2 trillion in benefits. If so, good for them. Such estimates are just this side of complete speculation. They are based on efforts to quantify unpriced benefits. The EPA likes to use such numbers as they can make their regulations look like a better deal when subjected to cost-benefit analysis, but the end result is even less reliable estimates of a regulation's overall economic impact. It would be better for the Agency to explain such impacts in detail without attempting to attach an arbitrary price tag.

rosignol (mail):
Please excuse my skepticism. Having worked in IT for over a decade, I know from experience that it is not uncommon for email attachments to become corrupted in transmission. However, I also know that the usual corrective action is to ask the sender to email it a second time.

With that said, the following passage makes me wonder...

The Times story also notes that the White House forced the EPA to eliminate certain portions of its analysis, such as the Agency's conclusion that regulating greenhouse gases could produce $500 billion to $2 trillion in benefits.

Benefits to whom?
6.25.2008 8:11am
PersonFromPorlock:
Good for the White House. Jackson's “John Marshall has made his decision; now let him enforce it” remains the proper expression of an Executive that's co-equal with the Judiciary: It puts the final resolution of interbranch disputes in the hands of the voters, not the Justices.
6.25.2008 8:16am
Curt Fischer:
PersonFromPorlock:

May I infer from your comment that you're more a "rule of men" type than a "rule of laws" type?
6.25.2008 8:37am
Justin (mail):
Do conservatives realize exactly the substantive argument Jackson and the Supreme Court had? Are they going to be quoting Pol Pot next for support of this administration?

In any event, if the Supreme Court, with its 7 appointed Republicans, has become a horribly liberal court that must be ignored or defied, it shows exactly the extremist state of this administration and their few remaining supporters.
6.25.2008 8:53am
byomtov (mail):
So excluding benefits is now a good way to improve cost-benefit analyses? Are all the cost estimates really so solid? I doubt it.
6.25.2008 9:11am
Rich B. (mail):
Byomtov has it exactly right. Economic analysis always opposes regulations that do not pass a cost/benefit analysis. Often, some of the costs and benefits are speculative and have to be estimated.

If you are allowed to speculate on costs, but not benefits, then you are essentially asking any new regulation to pass a "cost analysis," where any cost equals improper regulation.

It is certainly one way to promote de-regulation, but perhaps not the most honest way.
6.25.2008 9:36am
SteveW:
I'm confused about two issues concerning not opening the e-mail. First, I do not understand the motivation of the White House in refusing to open the e-mail. Second, I do not understand how the White House required specific revisions to a document that it never opened.
6.25.2008 9:42am
Ben P (mail):

The Times story also notes that the White House forced the EPA to eliminate certain portions of its analysis, such as the Agency's conclusion that regulating greenhouse gases could produce $500 billion to $2 trillion in benefits.

Benefits to whom?


US Companies of all sorts.

Anyone who isn't tied up in continuing to deny that Global Warming exists in any form would quickly notice that the US's environmental regulations have fallen "behind" comparative regulations in Europe.

That means that US companies doing Business in Europe have to adhere to stricter environmental regulations, and have already developed the policies, technologies, and infrastructure for doing so.

That gives them an incredible competitive advantage against companies that operate solely in the US and will have to pick up compliance with new regulations on the fly, and consequently given them a market where they can undercut their competitors because they were more forward thinking and innovative.
6.25.2008 9:55am
The Unbeliever:
That gives them an incredible competitive advantage against companies that operate solely in the US and will have to pick up compliance with new regulations on the fly,
Yes, an incredible advantage, except where it matters: cost.

There's a reason first-mover advantage is only a temporary advantage.
6.25.2008 10:29am
Ben P (mail):

There's a reason first-mover advantage is only a temporary advantage.


Temporary does not equal small. Would you sneeze at 10 years of a 15% higher market share? And that potentially may be understating it, if and when we enact further reforms some companies will be in a major spot to move into markets in a big way.

There are lots of companies today that are now significantly pursuing various "green" avenues, not only for present gain (For Example, Supply Chain streamlining is much more important now than before) but in anticipation of future requirements.
6.25.2008 10:32am
Splunge:
I suppose this means the EPA may tell us we'll all need to get fitted with soda-lime masks.

Ugh...wait...it says all greenhouse gases. I guess that means absorbing filters at the other end, too.

I've rarely heard such nincompoopery from adults.
6.25.2008 10:49am
SeaDrive:
So much for the theory of the unitary executive which, as I understand it, would hold that the EPA and the White House are part of the same indivisible identity. Knowledge and responsibility at EPA would equal knowledge and responsibility in the Oval Office.

Or, perhaps, only when convenient.
6.25.2008 10:52am
Constructively Reasonable (www):
I believe all this hysteria over CO2 is silly and would be entertaining if the greens did not have so much influence on changing the fundamental ways in which we live and work. The EPA’s regulations would be disastrous and in no way should they be implemented.

That said, I love the White House’s “Nah nah nah, I can’t hear you!” approach to handling the EPA. It’s infantile, but it works.

What’s next? “The executive order is in the mail.”
6.25.2008 11:11am
Floridan:
CR: "That said, I love the White House’s “Nah nah nah, I can’t hear you!” approach to handling the EPA. It’s infantile, but it works."

Yes, an adminstration that we can all be proud of. Is this the "shining city upon a hill" Ronald Reagan referred to?
6.25.2008 11:23am
PersonFromPorlock:
Curt Fischer:

PersonFromPorlock:

May I infer from your comment that you're more a "rule of men" type than a "rule of laws" type?


Not at all. None of the three branches is subordinate to either or both of the others; intransigent policy differences are properly resolved by the voters removing one or another of the disputants at election time. This isn't directly possible if the disfavored disputants are in the Judicial branch, but it is possible for the voters to elect a Congress to impeach them.

Neither "rule of men" nor "rule of law," but "rule of the People" expressed through Constitutional processes.
6.25.2008 12:02pm
ruralcounsel (mail) (www):
In the environmental regulatory game, costs are inherently more certain than benefits, generally speaking.

The costs are usually born by well-identified parties, with reasonable engineering cost estimates of control equipment etc.

Benefits are usually more diffuse, harder to quantify, and accrue to society as a whole. For example: What's it worth to you to reduce the mean global temperature by 0.5 degrees Centigrade within the next 20 years? I'll bet a lot of folks would say "Nothing." Especially if you were about to hit them with a tax bill for whatever amount they said.

The Cost/Benefit studies are probably MORE accurate for taking out that kind of pie-in-the-sky benefit that is prone to abuse and exaggeration. Nothing wrong with making everyone aware of these supposed benefits, but better to keep them qualitative.
6.25.2008 12:56pm
ruralcounsel (mail) (www):

Anyone who isn't tied up in continuing to deny that Global Warming exists in any form

Anyone who isn't tied up in continuing to deny that (Anthropogenic) Global Warming has an enormous number of theoretical holes and rests on shaky science, and a plethora of questionable inferred data and a miniscule amount of real data over an incredibly short period of time relative to climatic time-scales.

Care for some rope?
6.25.2008 1:02pm
JBL:
Well, considering that it is standard practice to deem paper documents received for legal purposes shortly after they are sent via the US Postal Service whether or not the intended recipient actually receives them, I would assume that the same is true for emails. Especially since the tracking on emails is much better. I doubt the claim that the message is in email limbo with no status; it sounds like the status is delivered but not opened. The fact that the White House can't figure out what to do with it doesn't have any real bearing on its existence.
6.25.2008 1:05pm
Crafty Hunter (www):
Excellent response, ruralcounsel.

Also, some NASA nutball recently suggested trying people for crimes against humanity for refusing to be stampeded into the illogical belief that there is any water in climate hystericalism. I suggest in turn that "global warming" hystericalists should be tried for crimes against humanity.

Anyone who isn't tied up in continuing to deny that (Anthropogenic) Global Warming has an enormous number of theoretical holes and rests on shaky science, and a plethora of questionable inferred data and a minuscule amount of real data over an incredibly short period of time relative to climatic time-scales.
6.25.2008 1:29pm
byomtov (mail):
The costs are usually born by well-identified parties, with reasonable engineering cost estimates of control equipment etc.

Those well-identified parties are often companies strongly opposed to the regulatiion, and often are the source of the cost estimates. I don't think it's wise to take their estimates at face value. Remember when air bags and catalytic converters were going to bankrupt the car companies?

Benefits are usually more diffuse, harder to quantify, and accrue to society as a whole. For example: What's it worth to you to reduce the mean global temperature by 0.5 degrees Centigrade within the next 20 years? I'll bet a lot of folks would say "Nothing."

Well, they are more diffuse, and do accrue to society as a whole. All the more reason why we should try had to quantify them and not rely on just asking the kind of question you describe. Opponents of regulation are all too happy to quantify things like the value of life when they can use the result to show that the proposed rule is unwise. But when it's the other way around suddenly it's too vague, etc. By the way, the benefit being discussed here is specifically the benefit from reducing auto emissions. Presumably some of this is improved health, etc. - the sort of thing that is routinely quantifed in these analyses.

The Cost/Benefit studies are probably MORE accurate for taking out that kind of pie-in-the-sky benefit that is prone to abuse and exaggeration.

If you're worried about exaggeration then take a careful look at the methodology and decide whether things are overstated or not.
6.25.2008 1:36pm
libarbarian (mail):

Also, some NASA nutball recently suggested trying people for crimes against humanity for refusing to be stampeded into the illogical belief that there is any water in climate hystericalism. I suggest in turn that "global warming" hystericalists should be tried for crimes against humanity.



By all means, lets completely debase the notion of crimes against humanity by charging people who say things you don't believe in.
6.25.2008 1:37pm
Dilan Esper (mail) (www):
Not at all. None of the three branches is subordinate to either or both of the others; intransigent policy differences are properly resolved by the voters removing one or another of the disputants at election time. This isn't directly possible if the disfavored disputants are in the Judicial branch, but it is possible for the voters to elect a Congress to impeach them. Neither "rule of men" nor "rule of law," but "rule of the People" expressed through Constitutional processes.

Someone here has forgotten that it is a Constitution that we are expounding.
6.25.2008 1:38pm
Snarky:

The Times story also notes that the White House forced the EPA to eliminate certain portions of its analysis, such as the Agency's conclusion that regulating greenhouse gases could produce $500 billion to $2 trillion in benefits.


Yes. Good for them. Because of course the White House has far more expertise in making environmental estimates than the EPA. In fact, it is about time we did away with these "expert" agencies making estimates at all


Such estimates are just this side of complete speculation. They are based on efforts to quantify unpriced benefits.


Yeah. Instead of estimating the value of unpriced benefits, it is so much better to assume that the value is zero. We wouldn't want things that are important to people but which do not have a market price actually mattering in the analysis!


It would be better for the Agency to explain such impacts in detail without attempting to attach an arbitrary price tag.


But, of course, it should continue to perform cost-benefit analysis which systematically ignores particular benefits because they are hard to price. Because that makes a lot of sense.

--------

It is not clear how Adler would handle the implications of his suggestion. Would he (1) eliminate cost-benefit analysis altogether, in recognition that systematically ignoring certain benefits makes comparison between costs and benefits useless or (2) keep a fatally flawed cost-benefit analysis around so that those who oppose conservation can argue against protecting the environment.

I actually tend to agree that we should get rid of cost-benefit analysis in which we come up with two numbers, one for cost, and one for benefit. A lot of these things cannot be objectively quantified -- why pretend that a particular decision is more objective than it is? But, if you go down that route, you should just make lists of costs and benefits without attaching numbers (where, of course, some of the costs and some of the benefits will in fact include numbers.)

But you know, somehow I suspect the the White House is not all about instituting slightly better cost-benefit analysis when it f*cks with the EPA. Anyway, the benefit of not quantifying that which cannot be easily quantified are small. Attaching a number may confuse some people who have no clue, but overall it doesn't do a lot of harm.

But it does give Alder an excuse to praise an irresponsible White House.
6.25.2008 1:41pm
Snarky:

Anyone who isn't tied up in continuing to deny that (Anthropogenic) Global Warming has an enormous number of theoretical holes and rests on shaky science, and a plethora of questionable inferred data and a minuscule amount of real data over an incredibly short period of time relative to climatic time-scales.


Everyone knows that the theory that the earth revolves around the sun has an enormous number of theoretical holes and is on shaky science. Because I said so! And Im a lawyer out in the middle of nowhere, so I must be right!
6.25.2008 1:50pm
Snarky:

Anyone who isn't tied up in continuing to deny that (Anthropogenic) Global Warming has an enormous number of theoretical holes and rests on shaky science, and a plethora of questionable inferred data and a minuscule amount of real data over an incredibly short period of time relative to climatic time-scales.


Everyone knows that the theory that the earth revolves around the sun has an enormous number of theoretical holes and is on shaky science. Because I said so! And Im a lawyer out in the middle of nowhere, so I must be right!
6.25.2008 1:50pm
Ben P (mail):

Anyone who isn't tied up in continuing to deny that (Anthropogenic) Global Warming has an enormous number of theoretical holes and rests on shaky science, and a plethora of questionable inferred data and a miniscule amount of real data over an incredibly short period of time relative to climatic time-scales.

Care for some rope?


As I've said before, you should write a letter or something. I'm sure all the experts would be fascinated to learn that someone on the internet has categorically proved them wrong.
6.25.2008 1:54pm
Bob from Ohio (mail):

In fact, it is about time we did away with these "expert" agencies making estimates at all


You say that sarcasticly of course but why should the judgment of the elected President of the United States and his close associates be subordinate to unknown, unnamed "experts" in the bureaucracy?

If Congress wants to pass a law to regulate greenhouse gases, let it. Let it make findings that the benefits and burdens justify the law. The law can be as detailed as this proposed regulation. Then the EPA just has to enforce the detailed law.

They don't do it because it is to hard to get the votes, of course. So, they delegate law making to bureaucrats and the courts limit the elected president's imput.

Power is given to unelected, unaccountable bureaucrats and their simbiotic interest groups.

I realize the courts have found this sham constitutional but it really is not. We should go back to the pre-Progressive era view that this is unconstitutional delegation of legislative power.
6.25.2008 2:13pm
Snarky:

why should the judgment of the elected President of the United States and his close associates be subordinate to unknown, unnamed "experts" in the bureaucracy?


Of course the President of the United States should not defer to "experts." Next time the Federal Highway Administration designs a bridge, of course the White House should decide, no, you should not use material X and design Y for that bridge, you should use material A and design B. Oh, and not only that, you should hire the following no-bid contractors.

These so-called "experts" do not know any more than the White House about how to build a bridge, after all. And isn't the point of building a bridge to reward important political supporters with no-bid contracts anyway?


I realize the courts have found this sham constitutional but it really is not. We should go back to the pre-Progressive era view that this is unconstitutional delegation of legislative power.


Really, I wish all Republicans would join you in advancing this idea. As a Democrat, I am sick of having to actually compete to win elections.
6.25.2008 2:47pm
Snarky:

why should the judgment of the elected President of the United States and his close associates be subordinate to unknown, unnamed "experts" in the bureaucracy?


Of course the President of the United States should not defer to "experts." Next time the Federal Highway Administration designs a bridge, of course the White House should decide, no, you should not use material X and design Y for that bridge, you should use material A and design B. Oh, and not only that, you should hire the following no-bid contractors.

These so-called "experts" do not know any more than the White House about how to build a bridge, after all. And isn't the point of building a bridge to reward important political supporters with no-bid contracts anyway?


I realize the courts have found this sham constitutional but it really is not. We should go back to the pre-Progressive era view that this is unconstitutional delegation of legislative power.


Really, I wish all Republicans would join you in advancing this idea. As a Democrat, I am sick of having to actually compete to win elections.
6.25.2008 2:47pm
Smokey:
Ben P:
"Anyone who isn't tied up in continuing to deny that Global Warming exists..."
Take a gander, Ben.

Snarky
"Everyone knows that the theory that the earth revolves around the sun has an enormous number of theoretical holes and is on shaky science. Because I said so! And Im a lawyer out in the middle of nowhere, so I must be right!"
Hey, that is pretty snarky.

However, anyone who repeatedly double posts should put down their ideas about science and step back. Leave the climate to the adults.
6.25.2008 3:13pm
Crust (mail):
Just in case anyone is inclined to Smokey seriously, RealClimate addressed the general issue of his "take a gander" link.
6.25.2008 4:25pm
PersonFromPorlock:
Dilan Esper:

Someone here has forgotten that it is a Constitution that we are expounding.

A Constitution in which the Court's having the final word was established by perhaps-not-disinterested judicial fiat in Marbury. The Founders' vision of the Court's being the weakest branch of government is hardly consistent with its being able to command every power of that government.
6.25.2008 5:10pm
smrad8:
May I ask, has no one at the EPA ever heard of a printer? If they put it on a postcard and no one would even have to open it. Worked for these guys.
6.25.2008 6:04pm
TDPerkins (mail):

Leave the climate to the adults.


Better, leave it to the audits.

There is no more intellectual rigor or honesty to the notion it is certain human activity has significantly warmed the climate than there is solid scholarship behind a collective right to arms embodied in the 2nd amendment.

Yours, TDP, ml, msl, &pfpp

PS. And if the sun doesn't start kicking out some significant sunspots soon, we'll revisit the Little Ice Age.
6.25.2008 9:06pm
p3731 (mail):
"If so, good for them. Such estimates are just this side of complete speculation. They are based on efforts to quantify unpriced benefits."

Can you back this statement up?
6.25.2008 9:45pm
DannyK (mail):
So, can anybody comment on why the White House might choose to leave an email unopened for so long while it wrangles with another part of the executive branch? Is there some legal fallout from opening the email that isn't already there from their very obvious knowledge of what the email contains? Is it all about plausible deniability?

It just seems such an ugly way to handle something, when the bureaucracy provides so many more elegant ways of failing to react.
6.26.2008 1:24am