I. Introduction
This letter serves as a comment on the Environmental Protection Agency (“EPA”)’s “Technical Documentation for the Framework for Evaluating Damages and Impacts (FrEDI).” 89 Fed. Reg. 13717 (Feb. 23, 2024). EPA explains that “[t]he main objective of the framework, implemented through the associated FrEDI R package, is to provide projections of annual physical and economic impacts of climate change in the U.S. through the 21st century under any custom temperature scenario, for a broad range of economically important impact category sectors (e.g., impacts across human health, infrastructure, labor, electricity, agriculture, and ecosystems and recreation).” EPA, 430-R-24-001, Draft Technical Documentation for the Framework for Evaluating Damages and Impacts (FrEDI).
We write to explain that FrEDI’s projections are fatally flawed because they systematically overestimate damage in two ways.
First, and most importantly, all but one of the studies FrEDI relies on project damages using the RCP8.5. RCP8.5 is an emissions pathway generated to inform the Intergovernmental Panel on Climate Change (“IPCC”) in 2005 and was intended to show the impact of very high emissions consistent with a fivefold increase in the use of coal and effectively no policies to limit greenhouse gas emissions. This reference scenario was always exceedingly unlikely and is now only of use as a counterfactual. FrEDI’s reliance on this outdated and extreme scenario results in much larger damages at lower temperatures and introduces a significant bias in its results, predicting elevated damages even when there is virtually no increase in the underlying projections.
Second, many of the damage projections in FrEDI effectively exclude the possibility of adaptation to the effects of rising atmospheric greenhouse gas concentrations, adaptations which in many cases could reduce projected damages with minimal expense. It beggars belief to suggest that communities across the United States will do nothing to modify their infrastructure to protect themselves from, for example, increased inland flooding. But this is what EPA assumes.
This comment explains how an adaptation-free RCP8.5 trajectory is wholly unrealistic, and how its lingering presence in the scientific literature, EPA’s social cost of carbon, and FrEDI is a black mark on scientific integrity. The attached expert report of Prof. Roger Pielke details how these assumptions infect nearly every part of FrEDI’s damage projections, how this causes FrEDI to systematically overproject damage, and why this means FrEDI cannot be used to usefully project temperature related mortality, air quality, flooding, or anything else.
This comment further explains why the framework if adopted would violate the Information Quality Act and EPA’s Scientific Integrity Policy. These flaws would fatally undermine any future action that relies on FrEDI. Finally, the comment explains that giving official government endorsement to these wildly inaccurate projections of damages misleads the public and propagates the misinformation that the Biden Administration purports to hate.
Climate science and climate policy are difficult and complex, but at their root, they both depend on the credibility of scientific and governmental authority. As proposed, FrEDI undermines that credibility. EPA should not adopt or use FrEDI in any fashion without first correcting the fundamental errors in its methodology.
Comments on Technical Documentation for the Framework for Evaluating Damages and Impacts (FrEDI)
I. Introduction
This letter serves as a comment on the Environmental Protection Agency (“EPA”)’s “Technical Documentation for the Framework for Evaluating Damages and Impacts (FrEDI).” 89 Fed. Reg. 13717 (Feb. 23, 2024). EPA explains that “[t]he main objective of the framework, implemented through the associated FrEDI R package, is to provide projections of annual physical and economic impacts of climate change in the U.S. through the 21st century under any custom temperature scenario, for a broad range of economically important impact category sectors (e.g., impacts across human health, infrastructure, labor, electricity, agriculture, and ecosystems and recreation).” EPA, 430-R-24-001, Draft Technical Documentation for the Framework for Evaluating Damages and Impacts (FrEDI).
We write to explain that FrEDI’s projections are fatally flawed because they systematically overestimate damage in two ways.
First, and most importantly, all but one of the studies FrEDI relies on project damages using the RCP8.5. RCP8.5 is an emissions pathway generated to inform the Intergovernmental Panel on Climate Change (“IPCC”) in 2005 and was intended to show the impact of very high emissions consistent with a fivefold increase in the use of coal and effectively no policies to limit greenhouse gas emissions. This reference scenario was always exceedingly unlikely and is now only of use as a counterfactual. FrEDI’s reliance on this outdated and extreme scenario results in much larger damages at lower temperatures and introduces a significant bias in its results, predicting elevated damages even when there is virtually no increase in the underlying projections.
Second, many of the damage projections in FrEDI effectively exclude the possibility of adaptation to the effects of rising atmospheric greenhouse gas concentrations, adaptations which in many cases could reduce projected damages with minimal expense. It beggars belief to suggest that communities across the United States will do nothing to modify their infrastructure to protect themselves from, for example, increased inland flooding. But this is what EPA assumes.
This comment explains how an adaptation-free RCP8.5 trajectory is wholly unrealistic, and how its lingering presence in the scientific literature, EPA’s social cost of carbon, and FrEDI is a black mark on scientific integrity. The attached expert report of Prof. Roger Pielke details how these assumptions infect nearly every part of FrEDI’s damage projections, how this causes FrEDI to systematically overproject damage, and why this means FrEDI cannot be used to usefully project temperature related mortality, air quality, flooding, or anything else.
This comment further explains why the framework if adopted would violate the Information Quality Act and EPA’s Scientific Integrity Policy. These flaws would fatally undermine any future action that relies on FrEDI. Finally, the comment explains that giving official government endorsement to these wildly inaccurate projections of damages misleads the public and propagates the misinformation that the Biden Administration purports to hate.
Climate science and climate policy are difficult and complex, but at their root, they both depend on the credibility of scientific and governmental authority. As proposed, FrEDI undermines that credibility. EPA should not adopt or use FrEDI in any fashion without first correcting the fundamental errors in its methodology.