Where there is no Regulator: EPA Carbon Regulation Jan 2.

Hey Doc,

Let's talk about this.  I know how you must feel.  You didn't ask to do this surgery.  Heck, you begged out of it.  The judges said someone has to regulate carbon emissions, and it fell you to you.

The best thing you can do right now is to confront the mistakes of the past.  Go over the records of patients who died under your knife.

First, let's remember that you've had some successes before.  Like with the Clean Water Act of 1972...   When you regulated water pollution, it had a positive effect on the paper industry.  The chemicals they used to bleach virgin tree pulp white were now more expensive to use.  And the office paper that was already bleached white was more valuable.  Small recycling based tissue paper mills, like the Erving Mill in central Massachusetts suddenly had advantages over larger tissue mills that were bleaching tree fiber white.  They were closer to the source of recycled paper, and used less chlorine.

Yeah, it was kind of an accidental success.  You didn't plan on the Clean Water Act increasing office paper recycling.  But take credit, ok?   Lots of cool inventions come from accidental Freakonomics.

Now.  About copper...



Sit down, Doc.  You need to study this, figure out what happened.  Everything you did on point-source pollution made sense, but after three decades, the USA had closed every secondary copper (scrap) smelter, and remained with mining, and the secondary smelters went overseas.   You followed the book, but it didn't result in better environmental health, less toxics, or less energy. When you regulate carbon, you don't want to repeat mistakes.

Here is a copy of EPA's report on secondary copper smelting from 1992,  how the process works, and how this is a safer way to get copper than mining and refining.   You need to find out why every single one of these patients died under EPA's watch.  The exact same thing is now happening to CRT glass refurbishment, good patients who reuse material are being mis-diagnosed and mistreated. 

The USA had 7 big secondary (recycled) copper smelters in 1960.  The last one closed in 2001.  Chemetco in Illinois.  You enforced pollution standards on secondary smelters, under Superfund, in a way that was more forgiving to point sources in one geography (mining, out west) than to urban ore smelters.  Now, Chemetco was a mess, and it was pretty ballsy the way they covered up an effluent pipe running into a wetland (landscaping over it).  Talk about driving the business underground...  But the winner was the primary, mining copper smelters, producing far more pollution per kilo of copper. We live with the outcomes.

Metals smelters are like slaughterhouses.  People don't want to live next door.  But they keep buying the meat.   Slaughterhouses and secondary smelters bring down property values.  But putting them farther away doesn't make them more humane.

This carbon thing could be different from clean water and even clean air.  I don't know enough about it to provide much advice.  But I can see how the "Not In My BackYard" or NIMBY thing may not apply.   Climate change is in all our backyards.   Still, EPA's surgical tools are designed around a point-source problem, and you'll be regulating individual actors to achieve a global effect.


Carbon generation has little local impact, it's in no one's backyard, really.  Or, it's everyone's backyard. But the point sources will be in political districts and in different countries.  But in globalization, on the world scale, maybe America is the new "local".

Doc.  Let's say there's a factory in San Francisco, and it's making windmills or solar panels.  And let's say it creates ten times more carbon than another factory that's making diesel engines.   Hopefully, the windmill factory comes out ahead, like the tissue paper mills using recycled feedstock in 1972.  But then again, if the world still needs diesel engines, do you want the manufacturing to go offshore, like happened with the secondary copper smelters?  How are you going to do this without losing patients?  When faced with something complicated like this, surgery is like carpentry - measure twice, cut once.

You don't want to have to do plastic surgery to correct previous plastic surgery.  Ask Michael.  

The secondary copper market died in the wealthy neighborhoods first, and in the poorer neighborhoods second, but what we wound up with was wire burning in fricking China, and mining in the USA. The outcome of regulation should be Primum non nocere... "Do No Harm".

It's true we must do something about climate change, global warming. The planet's fever is undeniable, and carbon emissions make it worse.   What we must follow is Evidence Based Medicine.

Start by reading, "Where There is No Doctor".  Then, you need a good teaching hospital environment.  Surround yourself with people who have interdisciplinary insights.  Don't create a department of people who all agree.   You don't want a whole bunch of people who are experts in cancer to run the maternity ward.


The best evidence-based medicine comes from re-testing assumptions.  Western medicine began with scatology and worked its way, from the butt up to the garden, to nutrition.  In the big carbon picture, you might find that eating meat puts more strain on carbon sinks (like the Amazon forest).  It might turn out you should be taxing hamburgers instead of auto tailpipes.

Start with the rain forests.  Plants like greenhouses.  Maybe we can grow a solution which aids habitats for endangered species, rather than prescribing based on whining.  I recently read that it's "unlikely" to be a solution, compared to (in the article) pumping carbon back into salt mines.  But there aren't endangered species habitats (that I know of) in salt mines.  So give the rain forest idea a good hard look, ok?