"But the projections were strongly criticized as unrealistic by the affected industries and by independent economists who reviewed the analysis — including two from the Pew Center on Global Climate Change, which supports the emission reduction goals.
In one withering review, Matthew E. Kahn of the University of California, Los Angeles said the analysis unconvincingly portrayed the law as “a riskless free lunch.” Another economist, Robert N. Stavins of Harvard, said the regulators were “systematically biased” in ways “that lead to potentially severe underestimates of costs.”"
I object to the adjective "withering". As stated it appears that this is my view of "AB32" when instead this is how I view the CGE economic analysis that I was asked to review.
If the reporter had read through my report on the AB32 document here is what she would have read;
Introduction
This memo provides my answers to the set of questions that I have been asked to comment on. Before I present my views I would like to state that I am a 100% supporter of the Air Resources Board’s efforts to translate the broad, vague mission embodied in AB32 to produce a game plan for achieving sharp reductions in California’s greenhouse gas emissions by 2020 and even greater emissions reductions by 2050. I want to see the ARB succeed in achieving its greenhouse gas mitigation goals. By pursuing this effort, California will reaffirm its world leadership in tackling environmental issues. By acting as a “guinea pig”, the state will help to educate governments around the world on cost effective techniques for reducing carbon emissions.
While I support the Governor’s broad AB32 goals, I must admit that I am troubled by the economic modeling analysis documents that I have been asked to read. As presented, AB32 will be a riskless “free lunch” for Californians. These economic models predict that we will enjoy a “win-win” of much lower greenhouse gas emissions and economic growth caused by this regulation. According to my arithmetic 95.6 MMTCO2 reduction or 57% of the AB32 2020 offers a net benefit of $132 million per MMTCO2. This would be a large free lunch! I would like to believe this claim but after reading through the Economic Analysis and the five appendices there are too many uncertainties for me to believe this.
In this review, I will highlight why I believe the current modeling exercise underestimates the costs of meeting AB32’s goals and I will sketch a research methodology for collecting the necessary data to truly test whether the optimistic numbers reported in Table I-2 of http://www.arb.ca.gov/cc/scopingplan/document/economic_appendix1.pdf could be accurate estimates of the expected net costs of this program.
In this review, I will point to other economic modeling efforts being conducted by some expert economists who conclude that the introduction of carbon pricing will entail small but significant costs on our economy. I will also highlight the fundamental uncertainties we face because of the ambitious 33% Renewable Portfolio Standards. Nowhere in this economic document could I find any mention of the words “risk” and “uncertainty”. Yet, each day we buy insurance and hold “safe” portfolios (i.e U.S Treasury Bills) to protect us against unforeseen contingencies. We are risk averse. AB32 is a gamble. It will force us to deviate from our “business as usual” ways of running our economy. This offers potential large benefits but it also raises the potential for bad scenarios whose probabilities and costs if they ensue have not been quantified in the documents I have read through.
Finally, this report will emphasize the need for more data collection and for field experiments to be conducted so that we can learn about how diverse real Californians and California firms will respond to the incentives embedded in AB32. Whether AB32 offers “negative costs” hinges on a number of micro-economic factors that the documents I have been asked to review do not touch on.
To see my full review go here:
http://mek1966.googlepages.com/publishedpapersandworkingpapers
and click on the first link.