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Brink Lindsey

The Cato Institute’s special online forum on reviving growth (see here for more details) continues today with the following four essays:

1. Dean Baker argues for free trade in doctors and drugs – by eliminating immigration restrictions and patent protection.

2. Jim Manzi also calls for more high-skill immigration, as well as visionary investments in scientific research and technology projects.

3. Jonathan Rauch proposes a national apprenticeship system.

4. Philip K. Howard makes the case for radical simplification of law.

Ilya Shapiro and Trevor Burrus

In order to create better telecom infrastructure, New York state law gives private telecom firms the power to take private property in exchange for just compensation. Verizon used this power to build terminal boxes on thousands of pieces of private property, thus essentially permanently occupying a part of the properties. Verizon is one of a few companies that enjoy this extraordinary, state-granted privilege to build things on other people’s property without their permission.

Those companies, however, must compensate the owners (at least theoretically) for these sorts of takings of property. Kurtz v. Verizon New York, Inc. arises from a putative class action alleging that Verizon failed to compensate 30,000-50,000 property owners for building terminal boxes on their property. Although Verizon is required to give property owners their “full compensation rights,” the plaintiffs argue that the company continuously flouts this requirement “as a matter of corporate policy and practice,” thus violating both the plaintiffs’ rights to procedural due process—for example, by not even notifying them that their property was being taken—and their Fifth Amendment rights to not have their property taken for public use without just compensation.

The U.S. Court of Appeals for the Second Circuit, however, ruled that the plaintiffs couldn’t proceed with their claims because of a case called Williamson County Regional Planning Commission v. Hamilton Bank of Johnson City (1985), in which the Supreme Court ruled that plaintiffs with takings claims have to seek relief from state courts before proceeding with a federal claim. Otherwise, the case will be dismissed for being not “ripe”—not ready for a federal court to hear the case.

Although this may seem like a small hoop-jumping exercise, this procedural requirement creates an unnecessary and burdensome extra step that can prevent many plaintiffs from ever having their takings claims heard in federal court. No other enumerated constitutional right has a similar requirement. Plaintiffs claiming a First Amendment violation, for example, don’t first have to exhaust their case in state courts.

The plaintiffs are now petitioning the Supreme Court to review the continuing relevance of Williamson County. In a brief supporting the petition, Cato, joining the Pacific Legal Foundation, argues that takings claims are ripe when the taking occurs, not after a plaintiff has gone through the state courts. Moreover, we point out that Williamson County, when combined with other rules of civil procedure, has actually prevented many claimants from ever bringing a case.

After exhausting their claims in state courts, some plaintiffs find that federal courts will dismiss their case on the ground that the matter has already been decided (what lawyers call res judicata, or “judged matter”). Other times, defendants will ask the judge to move the case from state court to federal court and then, once the case is in federal court, will argue that the plaintiffs did not exhaust their claims in state court (which of course they couldn’t have done because the defendants removed the case).

This Kafka-esque system is not the way to properly vindicate constitutional rights, and it’s certainly not what the Supreme Court imagined when it decided Williamson County. The Court should take this case to remove an unnecessary and harmful barrier to the protection of private property. 

Patrick J. Michaels and Paul C. "Chip" Knappenberger

You Ought to Have a Look is a feature from the Center for the Study of Science posted by Patrick J. Michaels and Paul C. (“Chip”) Knappenberger. While this section will feature all of the areas of interest that we are emphasizing, the prominence of the climate issue is driving a tremendous amount of web traffic. Here we post a few of the best in recent days, along with our color commentary.

The big news of the week was the “historic” (in President Obama’s words) climate agreement between the U.S. and China—but about the only “historic” thing about it was the hype the White House and environmental groups heaped upon it.  In actuality, there was very little new news. The emissions reduction pathway that Obama announced for the U.S. was not much different (actually a teense lower) than the one announced after the (failed) U.N. Copenhagen meeting in 2009, and China agreed to…well, it’s unclear to what they agreed. NBC News reported “China intends to begin to halt the rise in CO2 emissions by around the year 2030.” Try that line (inserting your own specific vice) on your significant other and see how it goes over.

A good article in Reuters by John Kemp nicely eschews the hype and looks more closely at the facts.  He opening paragraph reads:

Nov 12 (Reuters) - The joint statement by the United States and China on climate change, issued on Wednesday, is more important for its political and diplomatic symbolism than any practical effect it might have in reducing emissions.

Both Kemp’s article and our article on the announcement are worth having a look at to see what the agreement really entails, and its chances at success (spoiler alert: they aren’t good).

Another big news item this week—or at least it should have been—was the release of Alex Epstein’s remarkable book The Moral Case for Fossil Fuels. We can’t say enough good things about this book—and we try often! You may have seen our glowing review on these pages yesterday along with some provocative text provided by Alex that cuts to the basic premise of the book—that the societal pros of fossil fuel use far, far exceed the cons, and therefore, it is, well, immoral, to try to restrict their usage and further development. This week Alex also hosted a Reddit AMA (“ask me anything”) to allow internet savvy folks to interact with him directly as ask questions about his new book and his general way of thinking.  Alex entertained many interesting questions, for example:

Question:  What should be the role of government with respect to pollution? Should it ban pollution? Limit it? Tax it?

Answer: Good question, the subject of chapter 7 “Minimizing Risks and Side-Effects.” The basic principle is that we should think of it in terms of individual rights. At a certain threshold of emission someone is polluting your person or property and should be forbidden to do so. But certain threshold is important and contextual based on the state of technology. So in the 1800s people should have been allowed to use the coal plants they did but we shouldn’t today. If something is fundamentally necessary to human life it’s not pollution. There’s a lot of complexity in application but that’s the framework I use.

If you want to see all that transpired in this lively round of questioning is archived here.

And finally, our friend, the ever-informative Dr. Roy Spencer has a good post up over at his blog looking at what really are the biggest influences on the climate during the timescale of our lifetime. What does he find? Why natural variability, of course! He takes us through a couple of the most influential natural sources of variability and the possible drivers behind them. Here is some insight from Roy:

But statistics aren’t enough. Since we understand that carbon dioxide is a greenhouse gas, and should cause some warming, but we don’t understand natural climate cycles, scientists only look where the streetlight of government funding illuminates the problem: CO2.

What complicates policymaking even further is that what motivates public perceptions and thus decision makers the most are weather events. Hurricane Sandy. A snowy winter. We end up blaming these on the only thing we thing we think we understand — increasing CO2 should cause some change, so it must be responsible for all of the change we see…

To the extent that human-caused warming is occurring, I am increasingly convinced it is a largely benign — and possibly beneficial — needle lost in the haystack of Mother Nature’s natural climate gyrations.

You ought to have a look at the rest of Roy’s article, which can be found here.

Matthew Feeney

Earlier this week, members of a Madison, Wisconsin city subcommittee recommended misguided rideshare regulations relating to insurance, surge pricing, and hours of service that reveal a confused understanding of how ridesharing works.

If the subcommittee’s recommended regulations are implemented, companies such as Uber and Lyft, both of which provide ridesharing services, will have to provide at least $1 million worth of insurance coverage once a rideshare driver is logged into their app, regardless of whether there is a passenger in the car. In Madison, taxis are required to be covered by auto liability policies worth at least $1 million per accident. 

The $1 million insurance requirement in place for Madison taxis is higher than the insurance requirements in many other cities. In New York and Los Angeles, regulations require taxis to have at least $300,000 of coverage per incident. In Washington, D.C., taxis must have at least $50,000 per incident in coverage. Chicago requires taxis to be covered up to a combined single limit of $350,000 per incident.

It should be noted that both Uber and Lyft already have a $1 million policy in place from when a driver accepts a ride request to when a passenger is dropped off. What ridesharing companies will almost certainly object to is the recommended $1 million of coverage for the time when a rideshare driver has a rideshare app open but has not accepted a ride request. As it stands, both Uber and Lyft offer coverage for this time period worth up to $50,000 per individual per incident, $100,000 per incident, and $25,000 per incident for property damage. This coverage is designed to kick in if a driver’s personal auto insurance declines a claim.

California and Colorado, which have both passed legislation related to ridesharing insurance, mandate coverage very similar to the coverage already offered by Uber and Lyft for the period when a driver is logged into a ridesharing app but has not accepted a ride request. The differences between Uber’s and Lyft’s policies and the California and Colorado legislation are that the laws in Colorado and California require that the coverage be primary and that the property coverage be $30,000 rather than $25,000. The laws’ requirements go into effect on January 15, 2015 in the case of Colorado and on July 1, 2015 for California. 

In addition to insurance requirements subcommittee officials have also recommended a ban on “surge pricing” at times of peak demand. Both Uber and Lyft change the price of rides at busy times such as holidays when demand is high. Uber’s surge pricing policy was in the news shortly after Halloween this year when it emerged that a few individuals had paid enormous fares after they took an Uber ride during a time of increased demand. While some might think that Uber fares during “peak demand” are excessive, it is worth keeping in mind that before an Uber passenger can request a ride while surge pricing is in effect she must input the amount of the surge in the Uber app. In addition, the Uber app allows for users to estimate their fare. Likewise, Lyft informs users “prime time” fares are in effect before they request a ride.

What the surge price ban proposal reveals is a misunderstanding of how ridesharing works. Ridesharing drivers are not professional drivers and drive whenever they want. During popular times of partying or celebration (such as New Year’s or Halloween), rideshare drivers may have to decide between partaking in the festivities and driving. Surge pricing helps incentivize rideshare drivers to meet demand during busy times by allowing for increased profit. If passengers do not like surge pricing, the market will reflect that very quickly, so there is no need for Madison officials to interfere with the surge pricing systems in place.

Another set of recommendations made by the Madison subcommittee relates to hours of service. According to the recommended regulations, ridesharing companies will have to ensure that drivers are available 24/7 after one year of licensed service in Madison. This requirement, like the surge pricing ban, reveals a misunderstanding of ridesharing. Uber and Lyft do not control when drivers turn on ridesharing apps, rideshare drivers drive when they want. Regulators ought to leave the issue of driver availability to market forces rather than concern themselves with when private car owners use an app.

The regulations proposed by the Madison subcommittee betray a misunderstanding of an industry officials ought to welcome rather than burden with unnecessary regulations. Let’s hope that when the recommendations are put before the Madison Transit and Parking Commission next month, its members will realize how misguided these recommendations are. 

Neal McCluskey

If the outcry over unilateral executive moves we’ve seen over the last few years remains consistent, Obamacare and immigration are likely to keep sucking up most of Republicans’ attention and the media’s coverage. But just as sweeping have been executive waivers issued from the hated No Child Left Behind Act – really the most recent reauthorization of the Elementary and Secondary Education Act – that have been instrumental in connecting numerous states to, among other things, the Common Core national curriculum standards. And yesterday, the Education Department issued guidance offering states the chance to obtain waivers – if they do the administration’s bidding, of course – lasting well into the term of the next president: the 2018-19 school year.

These waivers are almost certainly illegal – even a Congressional Research Service report often cited to suggest the opposite says they are unprecedented in scope and, hence, an untested case – and even if they are not deemed technically illegal, the reality is they still amount to the executive department unilaterally making law. NCLB does grant the Secretary of Education the authority to issue waivers from many parts of the Act, but it grants no authority to condition those waivers on states adopting administration-preferred policies. Indeed, as University of South Carolina law professor Derek W. Black writes in a recent analysis of waivers, not only does NCLB not authorize conditional waivers, even if a court were to read any waiver authorization as implicitly authorizing conditions, the actual conditions attached – “college- and career-ready standards,” new teacher evaluations, etc. – fundamentally change the law. In fact the changes, Black notes, are essentially what the administration proposed in its 2010 “blueprint” to reauthorize NCLB. And quite simply, the executive fundamentally changing a law is not constitutional.

The latest waiver guidance goes beyond even the toxic status quo. Not only is the President using his vaunted pen and phone to unilaterally make education law, but law that would continue well into his successor’s term. It is a very dangerous move that, quite frankly, deserves at least as much alarmed coverage as Obamacare waivers and immigration actions. If for no other reason, because the action is moving us swiftly toward a de facto federal curriculum. In other words, direct control over what the vast majority of the nation’s children learn.

Federal power can’t get much more invasive than that.

Brink Lindsey

In conjunction with the upcoming conference on the future of U.S. economic growth, the Cato Institute has organized a special online forum to explore possible avenues for pro-growth policy reforms. We have reached out to leading economists and policy experts and challenged them to answer the following question:

If you could wave a magic wand and make one or two policy or institutional changes to brighten the U.S. economy’s long-term growth prospects, what would you change and why?

Their responses will all be made available here. We will post a few new essays each day in the run-up to the conference.

Assembling this impressive roster of contributors was a lot of fun. I strove for real diversity in outlooks – diversity not only in ideological orientation but in specific domains of expertise as well. I did this for a couple reasons. First, the U.S. economy’s growth slowdown is a serious and underappreciated problem and I want to spread awareness of the challenges ahead as broadly as possible. My hope is that a diverse set of writers will attract a broad set of readers. Furthermore, the problem of improving long-term U.S. economic performance is incredibly complex: there are no silver bullets, so meaningful progress will take the form of policy reforms on a whole host of different fronts. It makes sense then to look for promising approaches from as many different angles as possible.

No doubt the participants in this forum disagree about a great deal, and you will likely disagree with some of their proposals. The point of this forum, though, is to look past this and search for surprising areas of convergence and agreement. Back in the 1970s, during another protracted period of poor economic performance, the wholesale elimination of damaging price and entry controls came about as a result of an unusual left-right coalition: don’t forget that Ted Kennedy and Ralph Nader were major supporters of airline and trucking deregulation. It is my hope that similar coalitions can emerge to lift us out of our current predicament.

With that said, here are the first four essays:

1. Arnold Kling proposes alternatives to the regulatory status quo at the FCC and FDA, respectively: a spectrum arbitration board and prize-grants for medical research.

2. Robert Litan calls for more high-skill immigration and higher pay for teachers in exchange for an end to tenure.

3. Douglas Holtz-Eakin provides an overview of structural reforms needed to reduce government debt levels and restore growth.

4. Lee Drutman argues that tripling the budget for congressional staff can lead to improved policymaking.

Chelsea German

There has never been a better time to be alive on this planet. While many measures of wellbeing are already on a positive trajectory, humanity’s innate curiosity and enterprising spirit continue to push many individuals to seek the stars. The Rosetta mission’s successful comet landing was just the latest development. Privately-funded initiatives, such as SpaceX and Mars One, are taking the lead on a bolder project: a mission to Mars. Greater availability of knowledge and resources is enabling ever-more ambitious space exploration.

Successful space exploration requires expertise. Today, more people pursue advanced degrees globally, many of them in critical fields like physics, math, computer science, geology, and engineering. Furthermore, scientific knowledge compounds over time, and so each generation understands more than the last.

With a higher quantity and quality of scientists, mathematicians, and engineers than at any point in history, humankind is better equipped than ever to tackle the complex challenges of extraterrestrial travel.

Space exploration also requires a tremendous investment of resources. Throughout most of history, even if humankind had possessed the technical knowledge for space travel, scarcity would have prohibited the endeavor. Fortunately, wealth and prosperity are rising rapidly while poverty is in decline. Increasing abundance makes it possible to take on previously unthinkable projects like space exploration. 

Increasing abundance and scientific advancement are expanding humanity’s capacity to pursue ambitious undertakings. Not only has there never been a better time to be alive on this planet, but, thanks to growing prosperity and knowledge, there has also never been a better time to attempt exploration beyond Earth.  

Patrick J. Michaels

Alex Epstein’s long-anticipated book, The Moral Case for Fossil Fuels, published by Penguin, comes out today! I reviewed it as, “simply the best popular-market book about climate, environmental policy, and energy that I have read.  Laymen and experts alike will be boggled by Epstein’s clarity.”

Alex recently sent us a brief essay based upon material in the book. Alex Epstein is President and Founder of the Center for Industrial Progress—an organization sowing the seeds of energy enthusiasm to counter the tide of climate alarmism. We asked Alex to share a few thoughts with our readers here at Cato; find them below.

If you are in Washington, you might want to meet Alex. He will be giving a Hill Briefing in B-369 Rayburn at 9am on Friday, November 21.

If you ever get asked the vague but morally-charged question “Do you believe in climate change?” someone is trying to put something over on you.

Climate change is a constant of nature and everyone agrees that fossil fuels have some impact on our naturally variable, volatile, and often vicious climate.

The question is whether it will have a catastrophic impact—one so bad it justifies restricting the only practical way to get energy in the foreseeable future to the 3 billion people who have next to none of it: fossil fuels. (No country relies on the sun and wind for energy, but rich countries can afford to pay tens or hundreds of billions to install and accommodate allegedly virtuous wind turbines and solar panels on their grids.)

The real issue is climate catastrophe. I’m not a climate-change skeptic. I’m a climate catastrophe skeptic—and here’s one graph that shows why you should be, too.

No, it’s not showing temperatures have gone up half a degree in the 80 years we’ve used a lot of fossil fuels, which is barely more than they went up the prior 80 years. Nor does it show temperatures have flattened in the past eighteen years—while  the world’s leading climate catastrophists predicted dramatic, accelerating, runaway warming. Dr. James Hansen predicted that temperatures would increase between two-and-a-half and five degrees in 20 years!

Okay, I’ll show that graph, too—here it is:

Sources: Met Office Hadley Centre HadCRUT4 dataset; Etheridge et al. (1998); Keeling et al. (2001); MacFarling Meure et al. (2006); Merged IceCore Record Data, Scripps Institution of Oceanography

But that’s not the graph that really matters. There is no intrinsically perfect global temperature and, if there was, we would expect it to be warmer. Until it became politically correct for temperature trends to warm, people around the world prayed for far more warming than we’ve experienced. There is no time in human history when it has been considered “too warm” for human beings.

What matters is: is the climate becoming more or less livable? The key statistic here, one that is unfortunately almost never mentioned, is “climate-related deaths.”

The best source I have found for this data is the U.S. Office of Foreign Disaster Assistance and Centre for Research on the Epidemiology of Disasters International Disaster Database (OFDA/CRED EM-DAT), based in Brussels.1 It gathers data about disasters since 1900.

Here is a graph comparing CO2 emissions, the alleged climate danger, to the number of climate-related deaths, which reflects actual climate danger to humans. It’s striking—as CO2 emissions rise, climate-related deaths plunge.

Sources: Boden, Marland, Andres (2013); Etheridge et al. (1998); Keeling et al. (2001); MacFarling Meure et al. (2006); Merged IceCore Record Data, Scripps Institution of Oceanography; EM-DAT International Disaster Database

To make matters better, in reality the trend is even more dramatically downward, as before the 1970s many disasters went unreported. One big reason for this was lack of satellite data—we can now see the whole world, enabling us to track icecaps and disaster areas with relative ease. In 1950, if there was a disaster in the middle of what is now Bangladesh, would information have been accurately collected? In general, we can expect in more recent years, more deaths were recorded and in earlier years, fewer deaths were recorded. For some countries there is simply no good data, because in underdeveloped places like Haiti or Ethiopia we do not even know exactly how many people lived in a particular place before a disaster struck. Today we have much better information—and because disaster statistics are tied to aid, there is incentive to overreport.

And the more we dig into the data, the stronger the correlations get.

Here are a couple of striking numbers from the data: in the decade from 2004 to 2013, worldwide climate-related deaths (including droughts, floods, extreme temperatures, wildfires, and storms) plummeted to a level 88.6 percent below that of the peak decade, 1930 to 1939.2 The year 2013, with 29,404 reported deaths, had 99.4 percent fewer climate-related deaths than the historic record year of 1932, which had 5,073,283 reported deaths for the same category.3

That reduction occurred despite more complete reporting, an incentive to declare greater damage to gain more aid, and a massively growing population, particularly in vulnerable places like coastal areas, in recent times.

The climate catastrophists don’t want you to know this because it reveals how fundamentally flawed their viewpoint is. They treat the global climate system as a stable and safe place we make volatile and dangerous. In fact, the global climate system is naturally volatile and dangerous—we make it livable through development and technology—development and technology powered by the only form of cheap, reliable, scalable reliable energy that can make climate livable for 7 billion people.

As the climate-related death data show, there are some major benefits—namely, the power of fossil-fueled machines to build a durable civilization highly resilient to extreme heat, extreme cold, floods, storms, and so on. Why weren’t those mentioned in the discussion when we talked about storms like Sandy and Irene, even though anyone going through those storms was far more protected from them than he or she would have been a century ago?

I have debated representatives of the three leading environmental organizations in the world—Greenpeace, Sierra Club and 350.org—including 350.org’s Bill McKibben, the leading environmentalist in the world today—and every time, I have repeatedly mentioned the climate livability statistics. I raised it to Bill McKibben before I debated him and half a dozen times during my debate with him—he didn’t acknowledge it. He just called it “one number.” Yeah, one number, based on billions of empirical observations, that destroys billions of dollars worth of speculation.

Why? Because the dogma that man is ruining the planet rather than improving it is a religion, a source of prestige, and a career for too many people. But for the rest of us, the statistic climate catastrophists don’t want us to know is very, very good news.

Tim Lynch

Over at Cato’s Police Misconduct website we have identified the worst case for the month of October.

The worst police misconduct of October goes to the officers who shot David Hooks in his own home during a drug raid based on an invalid warrant and the tip of an informant who was allegedly high on meth.  The informant, Rodney Garrett, had just stolen a vehicle from the Hooks’ home when he was either arrested or turned himself into the police (reports vary).  Garrett told police that the 20g bag of meth he had had been stolen from Hooks’ pickup truck.

That same night, the Laurens County Drug Unit pushed through a warrant based primarily on Garrett’s word, and at 10:55 pm, executed a no-knock warrant despite the fact that the warrant did not authorize one–at a home that the police knew had just previously been burglarized two nights earlier. Hooks’ wife Teresa saw armed, hooded figures in black rushing towards the back door and woke her husband, thinking the burglars had returned.  David Hooks got his gun, and when the SWAT team knocked in the back door without announcing their presence, he didn’t even have the opportunity to get a shot off before officers fired between 16 and 18 rounds, killing him.

Some of the rounds were shot blindly through a wall at Hooks, without regard for whom or what they were firing at and killing. As you might expect from a search warrant based almost entirely on the tip of a meth addict who may or may not have been high when giving it, a 44-hour search of the Hooks home produced absolutely no contraband whatsoever.

David Hooks was a successful businessman who ran a construction firm that contracted with the U.S. government.  He had passed numerous security clearances and background checks, but on the word of a thief and meth addict, he was reduced to just another casualty in the war on drugs. Additional background here.

Patrick J. Michaels

Most every paper in the country is trumpeting today that China has finally agreed to limit its emissions of carbon dioxide, gutting the principal objection of people opposed to unilateral and expensive reductions in ours. 

Too bad it’s not true.

According to the official pronouncement, all China said was that they “intend” to cap their emissions “around 2030”. Anything new here?  In November, 2009, prior to the (failed) UN climate fest in Copenhagen, they announced their “intention” to reduce their emissions per unit economic output (called “carbon intensity”)  by 40-45% by 2020. Since then, things haven’t appreciably changed—so they now have five years to execute this huge drop, which isn’t going to happen.

The road to global warming is paved with China’s good “intentions”.

We also note that they “intend” to derive 20 per cent of their energy from non-carbon based sources by 2030. No doubt working late into last night (as did we; this story broke at 10:30), the estimable Roger Pielke, Jr., has already calculated that this means that the Chinese will have to put the equivalent of one nuclear power plant per week on line between now and then. As Roger wryly noted, “some people take it seriously”.

Don’t. But we should take seriously President Obama’s announcement that the US will double its scheduled emissions reductions by 2025. Thanks to the 2007 Supreme Court (5-4) decision that incredulously said that the 1992 Clean Air Act Amendments gave the President the power to command and control virtually our entire energy economy, he indeed can do what he just said.

It would take an act of Congress to prevent him, an act that would most certainly be vetoed, without the necessary two-thirds majority to override.

One might think that he would care about what the voters think—but that’s not the case. A careful read of election returns reveals that the cap-and-trade, and not health care, cost his party control of the House in 2010, and, in 2014, the epicenter of electoral carnage was in the coal mining regions of Kentucky and West Virginia, costing his party the Senate.

While China has good “intentions” we get real “unemployment”. Such a deal!

K. William Watson

This week is the #StopFastTrack Week of Action, an attempt by the anti-globalization movement to coordinate protests around the world against the Trans-Pacific Partnership, a potential free trade agreement between the United States and 11 other Pacific Rim countries.  The reason they’re doing it now is to influence lawmakers in the lead up to Congress’s lame duck session, during which many in Washington hope/fear that Congress will vote on a bill to grant “trade promotion authority” (also known as “fast track”) to help the Obama administration complete the TPP negotiations.

Spearheading the effort is the AFL-CIO.  In addition to asking supporters to call their member of Congress, the unions have also paid for ads at the DC metro station on Capitol Hill, obviously meant to reach congressional staffers during their commute.

Understandably considering the source, the ads have a very union-like feel to them.  Lonely hardhats on the floor of a shuttered factory, middle-aged people lamenting that they’re not being paid enough, etc.  Here’s a typical example showing a forlorn-looking young man who’s upset about income inequality:

The “1%” rhetoric should be quite familiar to most Americans by now as the standard jargon of the ideological left when they rail against all forms of voluntary commerce.  It’s no surprise to see it employed by labor unions in their crusade against free trade. 

Organized labor’s opposition to trade is nothing new.  So, in order to get more attention this year, labor groups have been readily pointing out that even some Republicans are opposed to fast track.  In particular, they are referring to a soi-disant “tea party” group that claims fast track will enable “Obamatrade” to destroy American sovereignty and jobs.   That group takes a very different approach with its messaging:

The news media have run with the narrative that a right-wing insurgency against fast track could threaten the U.S. trade agenda.

The problem with this narrative is that it is just wrong.  Scott Lincicome and I have written a comprehensive take-down of the attempt by a tiny protectionist wing of the GOP to paint its anti-trade agenda as part of the tea party movement.  Yes, there are conservatives who don’t like free trade, but the tea party movement is all about holding Republican members of Congress accountable when they stray from (most) limited government principles.  As such, the members of Congress most associated with the tea party movement have the best records in support of free trade

Trying to get Republicans to oppose free trade by wearing a tri-corner hat and shrieking “OBAMA!!!” merely plays to the negative views of the tea party held by many in the news media.

There are real obstacles to liberalizing trade in the United States.  The greatest obstacle is the inescapable reality that politicians benefit from rigging the system in favor of narrow constituencies seeking protection.  Protectionists get ideological cover mostly from the anti-globalist left but also from the nationalist right.  Thankfully, that nationalist impulse is largely in abeyance as a force against free trade in Congress at the moment, and “Obamatrade” notwithstanding, the tea party isn’t about to bring it back.

Charles Hughes

Broken promises and lowered expectations littered the first year of the Affordable Care Act. When the law was being debated, Obama promised the law would cut health care premiums for a typical family by $2,500. Instead, premiums everywhere continued to rise, in some places they skyrocketed. Supporters claimed the law would reduce the deficit, citing a score from the Congressional Budget Office. More recent calculations with a full ten years of implementation show that it will increase budget deficits. The now infamous “if you like your health care plan, you can keep it” pledge, which Politifact dubbed its “lie of the year” turned out to be a fabrication as millions of people received cancellation notices. The administration has tried to shift focus from past promises on cost containment and premium savings to the expansion of insurance coverage. Even in this area, the Affordable Care Act looks like it will fail to meet its goals, and the administration is already scrambling to try to temper expectations.

At an event at the Center for American Progress earlier this week, Health and Human Services Secretary Sylvia Burwell revealed that the administration had drastically lowered their exchange enrollment target. She divulged “[t]he number we’re going to aim for this year is 9.1 million.” This is a far cry from the Congressional Budget Office’s April projection of 13 million. The new goal for next year  is only 70 percent of the initial projection, which showed exchange enrollment jumping 7 million in 2015. The new target only anticipates a net increase of 2 million, a drastic reduction.       

In a related brief, HHS cited a slower than expected shift from employer-sponsored insurance and off-exchange enrollment as the reason for the lower projection. The brief suggests that it will take five years instead of three to ramp up to the eventual enrollment level of 25 million. This could mean that exchange enrollment could not reach its peak until 2019 and will likely fall short of initial expectations for years to come.

Secretary Burwell also sought to tamp down expectations for the website, saying that it “will have things that won’t go right. We will have outages, we will have downtime.” While the website will probably function better than last time, the second round of open enrollment faces many serious obstacles.

Most of the people most interested in signing up already did last year. Convincing those still uninsured to sign up could be more of a challenge. The first enrollment period had more outreach and coverage, whereas the Obamacare story potential enrollees are most likely to see now is news that the Supreme Court agreed to hear a case that could invalidate the majority of federal subsidies. Automatic renewal for people already enrolled poses another problem. If they do nothing, many people could keep the same plan but have to pay much more due to the way the law calculates subsidies. On top of that, the second open enrollment is only half as long as the first, so people have less time to visit the website and enroll through the exchange.

The first real indicator for how the second round is going will be how the renewal period goes for people who signed up last year. Last year there was a surge in enrollment at the end of the enrollment period. If people run into problems with automatic renewal or have difficulty using the website that could deter new potential enrollees.

The law’s past failures have led to broken promises and missed goals in areas like cost savings, premium reduction and improving the quality of care people receive. One of the only metrics the administration could point to in the past was that exchange enrollment in the first year actually met stated goals despite the website’s terrible launch. Now it seems that the law will fall short in enrollment too.

Open enrollment begins next week, and the recent efforts by the administration to lower expectations so close to the start date do not inspire much confidence.

Chris Edwards

In an article about federal highway legislation yesterday, the Washington Post illustrated the art of advocacy journalism cloaked as news reporting. The article explored different options for raising federal taxes $100 billion to fund state highways. It quotes three transportation lobbyists and included scare lines about the supposed consequences of not raising taxes (“… hundreds of thousands of construction jobs put at risk…”).

The article does not mention that spending cuts are an option for the upcoming highway bill. Everyone agrees that there is a large gap in the Highway Trust Fund (HTF), but gaps can be closed either by tax hikes or spending cuts. Yet the “transportation advocates” the Post talked to agreed, “until there is consensus on finding more money, transportation may be doomed to limp along in perpetual crisis.”

Nonsense. As I testified here, federal spending cuts would balance the HTF and solve the crisis, while spurring greater efficiency and innovation in U.S. transportation as the states played a larger role. The Post did not bother to explore that option, despite support from conservatives in Congress, prominent think tanks, and independent transportation experts.

In the election, Congress swung decidedly in a small-government direction, but the Post’s reporting did not reflect that reality, and instead presented only the lobbyist point of view. The Post’s silence on the spending-cut option is all the more striking because the newspaper admits that it would be very difficult to raise transportation taxes due to political and public opposition.

It will be interesting to see how Congress closes the HTF gap before the May expiration of the current highway bill. I hope that we have a robust debate on all the options and that the Washington Post changes course and presents its readers with a more balanced perspective.

Doug Bandow

Power is like quicksilver.  It often slips through the fingers of those attempting to grasp it.  Who is in power in North Korea?  Maybe 31-year-old Kim Jong-un.  Maybe not.

The Democratic People’s Republic of Korea’s Kim disappeared from public view for 40 days.  On his return Pyongyang only released undated still photos.

There’ve been no untoward troop movements or party conclaves in the North, though some other signs seemed conflicting.  Whoever reigns, there is little reason to hope for nuclear disarmament. 

To the contrary, the North appears to be increasing production of fissile material, moving ahead on ICBM development, and upgrading rocket launch facilities.  Even a seemingly secure Kim, the “Great Successor” whose father concocted the North’s “military first” policy, would hesitate challenging the armed services by trading away its most important weapon. 

Yet there are signs of change elsewhere.  The economy appears to be growing, with more consumer goods evident, especially in Pyongyang. 

Moreover, Pyongyang appears to be adjusting diplomatic strategies yet again.  The North released the three Americans it held, apparently without receiving anything in return. 

North Korea’s UN ambassador, So Se-pyong, indicated that the North was ready to return to the six-Party nuclear talks.  In early October Pyongyang sent a high-ranking delegation to Seoul for the Asian Games, which proposed further talks, though the latter later foundered. 

Nothing suggests that the regime is close to collapse. 

In this situation there is little to recommend the administration’s continuing policy of isolating the North.  In August North Korea’s deputy UN representative, Ri Tong-il, complained that “No country in the world has been living like the DPRK under serious threats to its existence, sovereignty, survival.” 

Of course, the North’s leaders are practiced cynics and their claims cannot be taken at face value.  But even paranoids have enemies, it is said, and North Korea is surrounded by wealthier and more powerful adversaries. 

A more pacific U.S. approach might not change the Kim regime’s calculus.  However, it’s hard to imagine a less threatening DPRK without changing America’s approach.

And that could come in part from diplomatic dialogue.  Washington should offer to establish low-key diplomatic relations, perhaps a consulate. 

Such a shift would be even more effective if coupled with policy changes that would be in America’s interest in any case.  Sanctions haven’t changed the DPRK and should be loosened.

Moreover, Washington should bring home its troops.  The U.S. conventional presence is long outmoded:  the South has around 40 times the GDP and twice the population of the DPRK.

Washington then could invite the North’s authorities to reciprocate.  If Pyongyang failed to act, which would surprise no one, Washington would be no worse off. 

It also would be more difficult for Beijing to excuse North Korean misbehavior.  Moreover, a troop withdrawal would eliminate the prospect that Korea unification would result in U.S. troops on China’s border, a Chinese nightmare which discourages Beijing from cooperating with Washington.

Even a more responsive North Korea is unlikely to be a particularly friendly actor.  Nevertheless, there is more hope for internal improvements in human rights and external talks over the issue if the international environment is less threatening for Pyongyang.  America’s earlier refusal to talk to the PRC gained nothing, while the famed Nixon opening helped create an atmosphere more conducive to post-Mao reforms.

Someday North Korea will pass away.  As I wrote in National Interest online:  “Until then the country is likely to remain a mysterious challenge, unsettling an entire region.  Washington’s best approach would be to extricate itself from confrontation and pursue dialogue, while leaving South Korea and Japan free to develop their separate policies.” 

Every strategy toward the DPRK so far seems to have failed.  Anything adopted is likely to be only a second best.  However, today even second best would be a major step forward.  It’s time for Washington to try something different.

Patrick J. Michaels

Okay, here’s how much of what calls itself science works today:

1) Find a change in something

2) Say it could be caused by global warming

3) Get more funding

4) Let people ask critical questions

5) Get tenure to protect you from that criticism

Today’s textbook example comes from the Washington Post, in an article, “Large ‘dead zones’, oxygen depeleted water, likely because of climate change”.

This is bad. According to The Post, the authors of newly minted article in Global Change Biology, say,

As global temperatures warm, they will create conditions such as rain [!], wind and sea-level rise that will cause dead zones throughout the world to intensify and grow…

Dead zones are (sometimes) large regions of hypoxic seawater that appear every summer. Because of their seasonality, obviously global warming is making them worse, right? (see 2) above) Or is it due to the fact that, on the average, humans are flushing more agricultural nitrates into the ocean as we produce ever more food? So the nitrates fertilize the ocean, algae bloom and die, bacteria decompose them and in the process, water becomes hypoxic, and fish die.

The authors, Andrew Altieri and Keryn Gedan, both with Smithsonian Institution affiliations, state there’s been quite the change in the number of dead zones (see 1) above). There’s a whole lot of stinking water, as according to Fears, they show that “Dead zone events have doubled each decade since the 1950s”.

But, according to Gedan, “we just don’t know how much of this doubling is due to climate change or nutrient runoff”. According to her, we need more studies and “more sophisticated modelling” (see 3) above).

Math time. That means they doubled from the 50s to the 60s, increased fourfold in the 70s, etc…to the first decade of the 21st century in which they have purportedly gone up from 16-fold in the 1990s to 32-fold over the 1950s.

Speaking of decadal scales, according to Cato’s Ross McKitrick, the “pause” in warming is now 19 years in length. So how do you get a doubling in the dead zones (and a 32-fold increase over the 1950s) without warming? Perhaps there’s not much of an effect from warming, and a much bigger one from nutrient runoff.

Evidence? The doubling of dead zones in the absence of warming not unique. From the 1960s to the 1970s, global surface temperature actually declined.

Gedan is certainly correct that you really would need “more sophisticated modelling” to pin the huge increase on the tiny amount of warming since 1950, and a doubling per decade even when two decades don’t warm. And wouldn’t the three millennia after the end of the ice age, when it was warmer (at least in our hemisphere) have been a very stinky time?

Given that dead zones maximize during the summer’s hottest temperatures, there is surely some component from warming. But the more obvious answer is that the massive flushing of nitrates into the world’s nearshore regions is changing a minor (and possibly undetectable) amplification into a stinking roar.

Or, given the fact that the earth has been warmer than it is today for about 95% of the last 100 million years, is it possible that the world’s biota really don’t care?

If the dead zone increase is real and caused by human activity, then there actually is some hope. There’s a real ecological problem here—the massive dumping of nitrates into our onshore ecosystems—that can actually be significantly reduced with relatively simple measures. On the other hand, there is simply no way that any conceivable climate policy will have a meaningful effect on global surface temperature.

Ted Galen Carpenter

Two countries that have the capacity to cause serious headaches for the United States are Russia and China.  Yet Washington is committing a cardinal sin in foreign policy: getting on bad terms simultaneously with those two major powers.  As I discuss in a recent article at China-U.S. Focus, that approach is especially unfortunate because Beijing has boundary disputes and an array of historical grievances against Russia.  In addition, China is now uneasy about the precedents being set by the Kremlin’s support of secessionists in Crimea and eastern Ukraine.  Those concerns and would normally cause Chinese officials to be wary about close cooperation with Russia.  But because Washington’s own relations with China have become frosty, the Obama administration may be forfeiting an opportunity to keep Moscow and Beijing from developing a common policy directed against the United States.

Two high-priority Chinese foreign policy objectives are now in conflict.  Beijing does not want to encourage the increasing popularity of secession in the international system.  The breakup of the Soviet Union, the violent fragmentation of Yugoslavia, the emergence of South Sudan, and the increasing likelihood of an independent Kurdistan arising from the wreckage of Iraq and Syria, all confirm a powerful trend.  Russia’s actions in Georgia in 2008 (supporting the breakaway regions of Abkhazia and South Ossetia) and now in Ukraine have given that trend a major boost, much to Beijing’s dismay.  Chinese leaders fret about separatist sentiments in Tibet and Xinjiang, as well as Taiwan’s continuing de facto independence.  From Beijing’s perspective, Moscow’s embrace of secessionist movements in neighboring states is most unhelpfu

However, the Chinese government is reluctant to join the West’s campaign of coercion against Moscow.  Not only is Russia an important partner of China’s in the Shanghai Cooperation Organization, the two countries have significant mutual economic and security interests throughout Central Asia and the Middle East.  The multi-billion dollar energy deal that the two governments recently signed underscores yet another aspect of the growing bilateral ties.

China also is receptive to a cooperative relationship with Russia because of pressing security concerns in East Asia.  The upgraded military alliance between the United States and Japan alarms Beijing, as does Washington’s vocal support for Vietnam, the Philippines, and other Chinese rivals regarding territorial claims in the South China Sea.  The last thing Chinese leaders want to do is help the West weaken Russia at a time when Beijing may need Russian support (or at least benevolent neutrality) as the United States and a growing roster of U.S. security partners tighten an implicit containment policy against China.

Ideally, the Obama administration should follow Thomas Jefferson’s advice to seek “peace, commerce, and honest friendship with all nations.”  Washington would be wise to reconsider some of its actions and move to repair relations with both Russia and China.  If U.S. leaders cannot bring themselves to do that, they should at least avoid antagonizing China at a time when tensions with Moscow are reaching alarming levels.

Nicole Kaeding

Ivanpah in California is the world’s largest solar project. The project is owned by Google and NRG Energy, and is heavily subsidized by taxpayers. Ivanpah originally received a $1.6 billion loan from the Department of Energy (DOE) in 2011. Now the company is asking for another government subsidy to pay off its original loan.

Ivanpah’s loan guarantee came from the Section 1705 program created by the 2009 stimulus law. Section 1705 provided up to $18 billion in loan guarantees to “certain renewable energy systems, electric power transmission systems and leading-edge biofuels.” The program was temporary, with loans available until the end of fiscal year 2011. Unlike previous energy loan guarantee programs, Congress even provided subsidies to borrowers to pay the fees on loans.. As a consequence, firms were able to get a federal loan guarantee without any direct expenditure, providing a large incentive for firms to take advantage. By the end of the Section 1705 program in September 2011, DOE approved 27 projects totaling $14.5 billion.

Business failures among these loan recipients were common, the most famous being Solyndra. Solyndra, a solar-panel manufacturer, received a $535 million loan guarantee before filing bankruptcy. An analysis by the Reason Foundation found that 10 of the 27 recipients under Section 1705 experienced some sort of financial trouble.

The survival of Ivanpah is still up in the air. The project came online in December 2013. From January to August 2014, the project generated just one quarter of its predicted amount of electricity.

In February, the company asked DOE for permission to delay payments on its loan. According to the Wall Street Journal, DOE gave Ivanpah a one-year extension on the $132 million first payment. A second subcomponent—the loan is divided among three subcomponents—delayed a June payment of $159 million to December.

Now, Ivanpah is asking for $539 million in cash from the federal government. This time, Ivanpah is targeting a Department of Treasury tax credit program that reimburses renewable energy projects for up to 30 percent of project costs.

 

Ivanpah would use the proceeds to pay off a large portion of its $1.6 billion loan. The company is asking the federal government to provide it with an enormous amount of cash to be used to payoff its debt to taxpayers. DOE actually requires Ivanpah to apply for a tax credit to aid loan repayment.

The process is absurd. First, the government uses tax dollars to provide a loan guarantee to a risky firm. Then, it functionally forgives a large share of the outstanding balance after providing a large tax credit. This is an unjustified giveaway to investors in Ivanpah and a horrible deal for taxpayers.

Energy subsidies have a long history of waste and mismanagement, but Congress ignores the record and keeps the money flowing. If approved, the Ivanpah tax credit would be another $539 million flushed down the drain.

Neal McCluskey

This morning NPR published an interview with Sen. Lamar Alexander (R-TN), the presumptive next chair of the Senate Health, Education, Labor and Pensions Committee. Unfortunately, if you were hoping the new GOP Senate would move decisively in the right direction on education, you may be disappointed. While the interview suggests we could see a moderate move in the right direction at the k-12 level, there is little reason for hope in higher or early childhood education.

For elementary and secondary education Alexander certainly says the right thing – the states should be in charge – and it is better that federal funds be block granted with few rules attached than delivered via numerous, micromanaged streams. So he is moving in the right direction when he says under a Republican plan, “Tennessee, Texas or New York would decide what the academic standards would be, what the curriculum would be, what to do about failing schools and how to evaluate teachers.” His general inclination is also right when he says he wants to “give states the option — not mandate — to take federal dollars and let those dollars follow children to the schools they attend.” Empowering parents beats simply feeding government monopoly schools.

Unfortunately, moving somewhat in the right direction isn’t the same as doing the clearly right thing. The Constitution does not allow federal funding of education (outside of D.C. and federal installations), nor does the record indicate that federal funding is educationally effective. The feds should therefore get out of education, including abandoning plans to provide private school choice, which if voucherized would eventually deliver stultifying federal rules and regulations to private schools nationwide.

Alas, things only go downhill in the interview after tackling k-12.

On higher education, as I feared, Alexander gives no indication he will do what must be done to address colossal waste and crippling price inflation: significantly reduce student aid. Indeed, what he seems most intent on doing is simplifying the Federal Application for Federal Student Aid, which makes sense from a paperwork-reduction standpoint but might actually lead to more aid flowing from Washington as more people complete aid applications. At least, though, Alexander recognizes the danger of the federal government trying to rate all of the nation’s postsecondary institutions, ranging from “Nashville Auto-Diesel College…[to] Harvard.”

And then there is pre-kindergarten. Again, Alexander rightly warns about federal micromanagement, but he seems to fully accept that Washington should be spending tens-of-billions of dollars on pre-k. Indeed, he states that, “The question is not whether early childhood education is a good idea. It’s how best to encourage it.” But the question absolutely is – or at least should be – whether early childhood education is a good idea. As the Cato Policy Analysis published last month by George Mason University professor David J. Armor made abundantly clear, the pre-k research simply does not support the conclusion that early childhood programs work, and talking like it is a settled issue does not make it so.

Based on this one interview, the good news is that Senate Republicans might try to make horrible federal education policy a little bit better. The bad news is that something made a little less horrible is still awfully bad.

Doug Bandow

It’s easy to be pessimistic about the future of liberty.  Yet sometimes freedom advances with extraordinary speed.  Like 25 years ago in Europe.

As 1989 dawned communism had ruled what was the Russian Empire reborn for seven decades.  The system failed to fulfill its promise of human liberation, but survived with the backing of secret police, gulags, and the Red Army.

Then in an instant it all was swept away.  On November 9, 1989, the Berlin Wall was open.  One of the most dramatic symbols of human tyranny was gone. 

Tens of thousands of East Germans were imprisoned for “Republikflucht,” or attempting to flee the East German paradise.  Some 1000 people died trying to escape East Germany, about 200 from Berlin.

As 1989 dawned there was obvious unrest in what Ronald Reagan had called the Evil Empire.  Hope was rising, but no one could forget that previous popular demands for freedom always had been crushed by Soviet tanks. 

In 1989 Hungary led the way.  Plans were made for multiparty elections.  The Communist Party dissolved.  When the new leadership tore down Hungary’s wall with the West the Iron Curtain had a huge hole.

Poland’s communist regime made a deal with a revived Solidarity Union and held free elections.  The liberal tide rose in Czechoslovakia, sweeping away the hardline leadership installed to squelch the Prague Spring of 1968.

The East German regime remained tough.  Frustrated East Germans began escaping through Hungary, with its open border. 

Protests spread, causing the communist leadership to temporize.  On November 4 a million people gathered in East Berlin. 

On November 9 visibly struggling Politburo member Guenter Schabowski declared that East Germans would be free to travel to the West “immediately.”  Border guards desperately sought guidance as tens of thousands of people gathered demanding to be let through. Just before midnight the security forces stood aside. 

The rest of the European communist dictatorships soon fell.  These revolutions were mostly peaceful.  But Romania capped the year with the Christmas Eve execution of Nicolae and Elena Ceausescu, the most odious members of Communism’s ruling menagerie. 

The transition from totalitarian communism to democratic capitalism turned out to be far more difficult than most anyone expected.  But it is important not to forget how awful communism truly is.  The Black Book of Communism figured the overall death toll to be more than 100 million.  In Death By Government the late R.J. Rummel estimated the butcher’s bill to be nearly 160 million. 

As I point out in the Freeman, “we should celebrate a quarter century after the collapse of communism.  The events of 1989 represent a massive increase in liberty, a fantastic triumph of the human spirit.  With so little bloodshed everyday people ousted a gaggle of tyrannies.  They have given hope for future generations, and themselves, that freedom can emerge against seemingly impossible odds.”

There were many heroes in the battle for liberty.  Particularly important were Mikhail Gorbachev and Ronald Reagan.  The former ended the Soviet police state and kept the Red Army in its barracks as the Soviet satellites fell out of orbit. 

Ronald Reagan understood that communism was morally evil.  On June 12, 1987 he stood in front of the Brandenburg Gate and said:  “General Secretary Gorbachev, if you seek peace, if you seek prosperity for the Soviet Union and Eastern Europe, if you seek liberalization:  Come here to this gate!  Mr. Gorbachev, open this gate!  Mr. Gorbachev, tear down this wall!”  But Reagan did something else equally important:  he recognized that Gorbachev was different than previous Soviet leaders and would be willing to accept the opening of the Berlin Wall.

There is much today to frustrate those who believe in liberty.  Yet we must not give up hope.  May the spirit of liberty from 1989 remain strong among us.

 

Paul C. "Chip" Knappenberger

The front page of yesterday’s New York Times included the beginning of a long article about geoengineering—in this case, as it applies to purposeful activities aimed at changing the earth’s climate at a large scale. Why on earth would anyone even think of doing something like that? Why to avoid catastrophic global warming, of course!

Thankfully, most signs point to only a modest global temperature increase resulting from our fossil fuel usage—a rise that will be readily adapted to and which actually may work out to be more beneficial than detrimental. Thankfully, we say, because geoengineering schemes seem like really bad ideas full of nasty consequences (unintentional and otherwise) and we are glad that no one is seriously entertaining them.

Most folks who spend much time critically thinking about geoengineering the climate arrive at the same conclusion.

Here are a couple of reasons why:

● Who would be in charge of the global thermostat?

● What temperature would it be set to?

●  Who gets to decide?

● What if a country doesn’t like the decision?

● Does the thermostat control rotate between counties every so often?

● If you don’t like the weather can you lobby someone to change it?

● If you don’t like the weather can you sue the entity responsible?

● The unintended consequences are mind-boggling!

● How do you know it is effective (climate models can’t accurately foresee annual to decadal variability)?

● Schemes to remove CO2 from the air are detrimental to agriculture.

These are just tastes of the problem, it shouldn’t be hard to come up with more on your own. If you need some help, the always insightful Roger Pielke Jr. has a series of articles on his blog over the years dedicated to this highly controversial topic (see here for starters).

So next time you hear someone offer up geoengineering as a way to “offset” anthropogenic climate change, just say “No, thank you, I’d much rather take my chances with the climate that comes than risk the alternative.”

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