Defense of the Regulatory Studies Center presented misleading portrayal

Taylor Lincoln is a research director for Public Citizen.

Two GW professors affiliated with the Regulatory Studies Center wrote a recent op-ed seeking to “clarify misperceptions” about the center. As the author of a report on the RSC, I think some additional clarification is needed.

The op-ed’s authors wrote that “no one affiliated with the RSC questions the science behind climate change.” This is misleading, at best.

A senior fellow at the libertarian think tank Reason Foundation, Julian Morris, submitted a public interest comment in 2018 on behalf of the RSC – following a process that allows members of the public to offer input to the government on proposed regulations – endorsing the Trump administration’s proposal to lower vehicle mileage standards. The Environmental Protection Agency cited this comment in support of the rollback.

Morris is a prominent climate change skeptic. He has called global warming a myth created by a coalition of self-interested scientists, governments and environmental groups, and he founded a United Kingdom think tank that disputed climate science. The think tank formed its own coalition to combat “biased and alarmist claims about human-induced climate change.”

In 2018, Morris published a report for a different think tank on the social cost of carbon, which refers to the U.S. government’s estimate of harms from carbon emissions. Morris concluded that the benefits of climate change “may well be greater than the costs” and that the cost of carbon should be set at $0. “Regulations or taxes on emissions,” he wrote, “are not currently justified.”

RSC Director Susan Dudley and RSC scholar Brian Mannix submitted a public comment in 2014 criticizing the Obama administration’s proposal to increase the social cost of carbon. They argued that the administration’s analysis was “one-sided” because it did not account for the potential of human-induced warming to prevent another ice age.

“Absent warming, we know that glaciers will cover New York City again one day,” they wrote. “Moreover, the effects of the glacial advance will not be limited to coastlines; we will likely lose Chicago, too, and most of Canada.”

This is subterfuge, not science. While scientists do believe we’re due for another ice age in 20,000 years or so, they consider the risk of natural, cyclical cooling trivial compared to the dramatic ongoing warming caused by humans.

Before joining the RSC, Mannix likened those seeking to regulate carbon to a profit-driven “carbon cartel” that posed “perhaps the greatest threat to freedom and prosperity that looms in the 21st century.”

In a 2012 speech to a religious group, RSC scholar Andrew Morriss said the costs of dubious “magic technologies that produce energy out of sunlight and wind” were robbing his children and unborn grandchildren.

“God gave us energy and he gave it to us to use,” Morriss said of fossil fuels. “He didn’t give it to us to admire in the ground.”

These examples do not reflect the thoughts of people who accept scientists’ consensus on climate change.

Of the RSC’s comments on specific regulations in the period I studied – from 2013 to 2018 – 96 percent recommended less-stringent regulation. The one comment I deemed otherwise was a close call. It endorsed limiting nicotine in conventional cigarettes in exchange for leaving vaping devices alone.

On regulations affecting fossil fuel emissions, RSC comments opposed proposals to regulate power plant pollution, appliance efficiency, vehicle mileage standards and carbon. I did not find RSC comments expressing competing views.

Most of the academics the RSC has listed over the years did not submit comments. The majority of those who did submit comments have past or present affiliations with other groups funded by Koch Industries CEO Charles Koch, who also funds the RSC. These individuals authored or co-authored three-fourths of the comments the RSC submitted.

Koch has crusaded against regulation throughout his life. He has funded and coordinated opposition to carbon regulation since the earliest days of such proposals. He reportedly believes carbon regulation poses an existential threat to his company, which is rooted in fossil fuels.

The RSC bears a remarkable likeness to a vision that Koch laid out nearly a half-century ago. In 1974, Koch recommended supporting “free-market scholars” to influence policy. Koch’s personal aide soon delivered a paper reflecting Koch’s thoughts on how to invest in scholarship to bring about social change. The paper recommended funding organizations associated with universities that would be primarily answerable to their donors.

Koch has turned this vision into reality. He was funding more than 50 university centers as of 2016, according to the Charles Koch Foundation’s director of university investments.

The Koch network takes steps to “leverage” its researchers’ work and ensure their “ideas have a seat at the table in public policy,” the investments director said, “helping wring every last drop of liberty-advancing value out of every single activity that happens at every single one of these centers.”

The RSC’s output matches the wishes one would attribute to its funders – not just Koch, but other conservative foundations and business interests, such as the U.S. Chamber of Commerce and oil giant ExxonMobil. A likely explanation for this alignment is simply that the funders and Dudley came together because they think alike.

Dudley previously directed the Regulatory Studies Program at George Mason University’s Mercatus Center, which is Koch’s flagship university center. While Dudley was there, Mercatus’s RSP was legendary among lobbyists for its effectiveness at targeting regulations. It even served as a coordinating center for lobbyists seeking to block regulations, according to a Chamber of Commerce lobbyist.

GW’s RSC owes its creation, in late 2009, to a libertarian donor that often funds the same groups as Koch. The RSC’s web site once said, “RSC was made possible by an initial grant from the Searle Freedom Trust.” Koch began funding the RSC the following year.

Searle likely would not have funded the RSC if it did not trust Dudley to run a program that would advance its agenda, nor would Koch or the others that have followed.

A funder providing a platform to an ideological soulmate would not be notable if a university’s name – and the credibility it conveys – were not on the letterhead. But a university must not allow outside interests to use its name for purposes that conflict with its mission. A university allowing money from special interests to influence its decision to open a research center, as apparently happened here, raises questions.

Would the University have designed the RSC the same way absent funding considerations? Would the donors continue giving if the RSC suddenly began endorsing regulations, such as on carbon? Would the University maintain the RSC if its special-interest funding disappeared?

If the University cannot confidently answer “yes” to these questions, then the marriage between the RSC and its funders is not as innocuous as the recent op-ed suggests.

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