To meet the challenge of addressing climate change requires both rethinking how regulation needs to change and, critically, to highlight policy success to provide fertile ground for reform elsewhere. This latter imperative motivated us to review a recently published book by Roger Karapin and David Vogel, two leading regulation scholars, When Federal Climate Policy Works (MIT Press, 2026). It is a depressing – and we argue an ultimately flawed – read.
Karapin and Vogel’s argument is that policy makers must ‘aim low’. This is not mere opinion, but rather a well-argued and empirically supported analysis that, given past experience, ‘aiming low’ is the only way to nudge policy forward given the power of fossil fuel interests, the divide between Republicans and Democrats over climate change, and the role of money in US politics. Federal climate policies only came about they argue when they were narrowly focused, pursued climate mitigation covertly (ideally without mentioning climate change at all) or even unintentionally, did not generate new costs for industry and did not attempt to reduce greenhouse gas emissions or fossil fuel consumption. Draft policies that did not share these characteristics did not see the light of day.
This litany of half-baked successes is their story of policy that “works.” Read differently When Federal Climate Policy Works is a tale of exhaustion – exhaustion of two kinds.
First, the exhaustion of policy as problem-solving. Nowhere is this clearer than in the recommendations Karapin and Vogel address to aspiring climate policymaker: keep your aims narrow, do not be too ambitious, wait until consumers are ready, do not frame your policy as “climate” policy and do not attempt to directly reduce greenhouse gas emissions or fossil fuel consumption. In short: curb your enthusiasm. These are so pessimistic one might think they were written in jest; yet, there is no irony here. The authors, serious scholars and leaders in their field, have little hope that US institutions, businesses or citizens will ever tackle climate change head on. If policy cannot solve problems overtly any longer, policymakers should rather act by stealth, and hope for second order, even unintentional benefits. Karapin and Vogel’s work illustrates their own advice: having little hope in their object, they find “climate policy” in places where there never was any, and more than once throw “unintentional climate policies” into the mix of “climate policies that work”.
At a deeper level, this book illustrates the exhaustion of policy analysis. The authors’ conclusions and recommendations are based on problematic and outdated assumptions: The future will be like the past, therefore makers of future policies should stick to what “worked” for the last 50 years of US policies, however disappointing that may have been. Citizens and businesses have fixed interests, and since protection from climate change is not one of them, they will never support explicit climate policy. Climate change being a slowly evolving reality with negligible impacts on citizens or businesses, it will not disrupt the status quo nor trigger a policy response.
Yet, it is a serious error to assume the future will be like the past given the impact of global warming itself. The climate literature highlights both the tangible impact of global warming and the intricate relationship between global warming and our fossil fuel economy. ‘More of the same’ will exacerbate climate change and its consequences including the intensity and frequency of extreme weather, the growing unreliability of food supply and accelerating sea level rise.
Global warming affects everything – and consequently the regulation of everything. Workplace safety, transport, agriculture, healthcare, housing, insurance, energy are all being impacted in increasingly obvious and costly ways. Anyone paying attention knows that global warming is already affecting people who rear animals or grow plants, work outside, work in process industries where continuous cooling is essential (e.g. refining, chemicals or water treatment), in building construction and maintenance; manage and maintain roads, train tracks, drainage systems and water storage; look after vulnerable people in schools, hospitals or care homes; work in commercial kitchens; experience now routine pre-emptive power cuts in wildfire-prone zones; live in areas that are newly uninsurable due to risk of flooding or wildfire; or have lost their livelihood and home to extreme weather.
Global warming thus injects unprecedented and radical disruption, which analysts like Karapin and Vogel and policymakers ignore at their peril. Far from abstract or slow, global warming is having an increasing impact on all that citizens care about. Global warming is grounding us, bringing us “down to earth” (Latour), so that soon, basic things we Westerners take for granted will be no longer certain: food, water, breathable air, healthcare, education. If affordability can be a winning proposition in post-Mandani US politics, then what of climate action to protect access to food, water, breathable air, healthcare and education?
And it is not only citizens. Businesses too are experiencing global warming. The insurance sector is sensing its extinction in some markets even if its lobbying position currently contradicts that view. The agri-food sector is in a similar position, defending policy positions (e.g. in Europe) that, for now, contradict how alarmed agri-food businesses are about their growing losses to climate extremes. Time will tell for how long such a contradiction can be maintained.
In overlooking the impact of climate disruption the authors buy into the illusion that the future will be the same as the past. Karapin and Vogel’s book keeps the policies and the interests of business and citizens in fixed, neat little boxes, demonstrating a deeply ingrained cultural refusal to recognise climate change as a threat to society and prosperity. In doing so they participate in the many forms of denial perpetrated by industry-funded disinformation and discussed eloquently by Tad Delay, Laura Horn and others. By not questioning the misinformation and bias that has been perpetrated, they become a manifestation of it.
How did the USA and its political system end up in this state of intentional oblivion? What will be the consequences of policies that make the mistaken assumption that the future will the same as the past? It would have been helpful to address such questions. Instead, the book feels outdated in its implicit and factually wrong vision of climate change as a slow-moving train wreck that will continue to barely register in the consciousness of voters and policymakers alike for the foreseeable future. The book's conceptualisation of regulation is stuck – as is the reality of American regulation – in the era of deregulation: the state is essentially bad, the market can cope with whatever will happen, citizens are essentially just consumers, and therefore demands for regulation can only be made when consumers are ready, additional costs are avoided or, better still, when additional and immediate benefits for firms can be accumulated. There are no lessons learned and no warnings heeded, neither by the politicians nor the analysts.
In sum, When Federal Climate Policy Works presents us with a 'world leader' unable to learn from either science or the physical signals of trouble, and, most problematic of all, protect their citizens. And yet, it calls it a study in policy that “works”. Overall, the book by Karapin and Vogel is a depressing read with little to offer in the way of improvement. It shows how a religious adherence to the benefits of markets that ignore their ecological impact, and a political system unable to compromise, block the ability to think policy so that societies can adapt to such radical changes and be protected against the worst outcomes. This book shows us how not to do it and – against its proclaimed intentions – what blocks a reasonable political response to climate change.