Friday, February 25, 2011

nuclear power and conflicts of interest

Just scanned a new article by Kristin Shrader-Frechette in Science and Engineering Ethics. She provides evidence from 30 nuclear power cost estimates and shows that the industry consistently ignores certain costs, trims others and generally makes estimates of other parameters which make the final result appear favorable to the nuclear industry.

She attributes the underestimates of cost that result from these studies are most likely due to the obvious conflict of interest that industry-funded studies encounter. Further, most of the data are provided by the industry themselves, and many are shielded under proprietary privilege.

In any case, a very nice piece of work with interesting parallels for others in the energy sector.

Shrader-Frechette, K. (2011). "Climate Change, Nuclear Economics, and Conflicts of Interest." Science and Engineering Ethics 17(1): 75-107.

Monday, February 14, 2011

A letter to Governor Brown re: California Transportation Commission appointments

I just sent in this letter to Governor Brown via this link.

Dear Gov. Brown,

The current membership of the California Transportation Commission (CTC) is troubling. Not a single civil engineer or urban planner sits on the body charged with approving the State Transportation Improvement Plan - the key document outlining the state's vision for transportation as embodied in the projects listed within it. Instead, the commission is overwhelmingly populated by real estate developers. While their voice is surely important, it ought not dominate the discussion. Pursuit of the objectives of developers is often not the best course for the state as a whole.

As you consider new appointees to the CTC, I urge you to choose individuals who have demonstrated an ability to think critically about the state's transportation policies and priorities. California has a substantial amount of transportation research talent housed within the Institute of Transportation Studies spread across several University of California campuses (Davis, Irvine, Los Angeles, and Berkeley). Professors and researchers at these institutions have been on the leading edge of transportation and land use planning research for decades. Many of them would make excellent candidates capable of providing the well-reasoned input necessary to place California on a path to meet its ambitious 2050 greenhouse gas emissions reductions goals as required by AB32 and to improve land use planning as required by SB375.

With kind regards.

Friday, February 4, 2011

ab32 lawsuit

Looks like a devastating result for EJ advocates. I don't see how finding the alternatives analysis of CEQA to be in violation is going to lead to an improvement in EJ outcomes. The CARB will simply prepare an updated alternatives analysis that will still lead to cap and trade as the preferred alternative. California agencies have never (or, perhaps, rarely) seen an alternatives analysis as an occasion to change a preferred policy.


  • "Arbitrary and capricious" is the relevant standard against which the court will judge the ARB.
  • ARB's interpretation of the 2020 target as a floor on reductions is fine.
  • Costs are properly evaluated for the plan as a whole - not individual measures.
  • Exclusion of agriculture also okay.
  • "The statute does not support the argument that ARB must demonstrate that cap and trade will result in the same reductions as any direct regulation."
  • CARB justified in choosing cap and trade
  • "In the analysis of voluntary and incentivized measures for the agricultural sector, the record does not demonstrate that ARB used the best available models as required by AB 32."
  • AB 32 does not specify that analyses have to be quantitative (?)
  • Public health analysis fine (but no mention of the question of co-benefits)
  • No AB 32 revisions necessary - CARB gets wide latitude as a quasi-legislative agency
  • This is a program- as opposed to project-level EIR. They are assessed on different merits.
  • Location of biofuel plants was speculated upon in the SP, but CARB was justified in only giving a vague description of possible impacts. The case cited here (Rio Vista) refers to a county that generated a hazardous waste landfill plan, but did not specify particular locations, so it seems to be a little different.
  • The impacts portions of the FED are complete.
  • The "programmatic" label cannot be used to justify an analysis which is inadequate for informed public review and informed decision making by the ARB. Respondent has argued that more detailed analysis of alternative may come later during the implementation process. This claim has no credibility because the ARB has already proceeded, prematurely, with the implementation process.