Comments on Proposed EPA Endangerment Technical Support Document
Alan Carlin | July 9, 2009
On June 25th the Competitive Enterprise Institute (CEI) released a draft copy of my report critical of the science underlying EPA’s proposed position on Endangerment under the Clean Air Act and the role of CO2 in global warming saying:
“The released report is a draft version, prepared under EPA’s unusually short internal review schedule, and thus may contain inaccuracies which were corrected in the final report. While we hoped that EPA would release the final report, we’re tired of waiting for this agency to become transparent, even though its Administrator has been talking transparency since she took office. So we are releasing a draft version of the report ourselves, today,” said CEI General Counsel Sam Kazman.
CEI noted that: Internal EPA email messages, released by CEI earlier that week, indicate that in their view the report was kept under wraps and that I was silenced because of pressure to support the Administration’s agenda of regulating carbon dioxide. On June 26 I was given permission by EPA management to post the report on my personal website but not on the EPA website. Instead of posting the earlier draft released by CEI on June 25 I instead posted the last version prepared before the deadline for internal comments modified only to correct a few of the non-substantive problems. On August 5, EPA posted the last version of my Comments prepared prior to the end of the internal EPA comment period on March 16. This does not include the modifications to correct a few of the non-substantive problems. Thus there are now three different versions on the Web to my knowledge:
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The early version made public by CEI on June 25
The last version prepared on March 16 completely unchanged and as distributed by EPA in response to FOIA requests.
The non-substantively modified version of the March 16 version which I prepared in late June
The major differences are between the CEI version and the last two, which are substantively identical. Unfortunately, many readers do not realize that the CEI version is an early version rather than the last version. EPA released the original March 16 version on August 5 as a frequently requested record under the Freedom of Information Act.
For further background information on all this, see press coverage including the following: CBSNews, NYTimes, Wall Street Journal news and opinion, and London Telegraph. For commentary on a September NYTimes story see here.
The title page of the last two versions of the report listed above reads as follows:
Comments on Draft Technical Support Document for Endangerment Analysis for Greenhouse Gas Emissions under the Clean Air Act
By Alan Carlin
NCEE/OPEI
Based on TSD Draft of March 9, 2009
March 16, 2009
I prepared an update to this document, which is on page iii of the last version listed above, so that readers can better understand the conditions under which this report was prepared. I’m reproducing it here:
Important Note on the Origins of These Comments
These comments were prepared during the week of March 9-16, 2009 and are based on the March 9 version of the draft EPA Technical Support document for the endangerment analysis for Greenhouse Gases under the Clean Air Act. On March 17, the Director of the National Center for Environmental Economics (NCEE) in the EPA Office of Policy, Economics, and Innovation communicated his decision not to forward these comments along the chain-of-command that would have resulted in their transmission to the Office of Air and Radiation, the authors of the draft TSD.
These comments (dated March 16) represent the last version prepared prior to the close of the internal EPA comment period as modified on June 27 to correct some of the non-substantive problems that could not be corrected at the time. No substantive change has been made from the version actually submitted on March 16. The following example illustrates the type of changes made on June 27. Prior to March 16 the draft comments were prepared as draft comments by NCEE with Alan Carlin and John Davidson listed as authors. In response to internal NCEE comments this was changed on March 16 to single author comments with assistance acknowledged by John Davidson. There was insufficient time, however, because of deadlines imposed by the Office of Air and Radiation, to make the corresponding change in the use of the word “we” to “I” implicit in the change in listed authorship. This change has been made in this version.
It is very important that readers of these comments understand that these comments were prepared under severe time constraints. The actual time available was approximately 4-5 working days. It was therefore impossible to observe normal scholarly standards or even to carefully proofread the comments. As a result there are undoubtedly numerous unresolved inconsistencies and other problems that would normally have been resolved with more normal deadlines. No effort has been made to resolve any possible substantive issues; only a few of the more evident non-substantive ones have been resolved in this version.
It should be noted, of course, that these comments represent the views of the author and not those of the US Environmental Protection Agency or the NCEE.
Alan Carlin
June 27, 2009
Alan, congratulations!
I am sure this will be a great site to contribute to public debate about all important issues regarding economic policies and climate changes in particular.
It is obvious to this reader that the EPA, being a political agency of the Obama regime, rushed to a political decision and not a scientific one.
The Dumbocrats by their refusal to listen to any fact or viewpoint differing from their own are taking us down a path of economic destruction. The end result will be that our dear country will be so poor that it could not effect any change to its industrial processes if the effect of Global Warming is found to be real. Its not beyond the realm of possibility the United States becomes as poor as the country of Haiti, and we resort to burning wood and charcoal for our needs.
I truly believe the Dumbocrats and the radical left, led by an imposter president Obama are determined to destroy the United States as we know it.
Its time we organize to take back our government from the communists in the White House, and see that they are charged for high crimes against the people, and violations of theUS Constition. It is hoped that punishment for such crimes would not be limited, with the intent that such crimes constitute Treason.
It is shamful what this government has done to the Author of this website, as this man has worked for the good of mankind and the citizens of the United States.
I encourage all readers to investigate the EPA’s rush to judgement in ruling that Carbon Dioxide is harmful to humans, therefore enabling them to regulate it. If their logic and methods were used on the common, everyday items we use and eat, they would ban all, including H20—water !
It is mandatory that all readers call or write their elected representatives and demand that the Waxman-Markey bill be defeated. These two men represent grave danger to this country, as I believe they are communists of the highest order.
Alan,
I have posted the following on several climate blogs in hopes of getting some critical scientific review. It makes google if you enter “Fred H. Haynie”+climate. Yet I have had little response from either side of the debate.
To all concerned,
One reason I retired early from research at EPA years ago was good
science was beginning to be sidetracked for political purposes. In this
case EPA has been completely derailed. I have spent the last four years
of my retirement studying all the data I could find to get to the truth about climate change. I just finished a presentation that shows ample evidence that anthropogenic emissions of carbon dioxide do not cause global warming. Carbon dioxide has been falsely convicted on circumstantial evidence by a politically selected jury. A just retrial could overturn this conviction before we punish ourselves by trying to control emissions that will have no effect on climate change. You can view the presentation and be your on judge and jury at http://www.kidswincom.net/climate.pdf
Sincerely,
Fred H. Haynie
Retired Environmental Scientist
Dear Dr. Carlin:
It was with a great deal of interest that I read your Comments on Proposed EPA Endangerment Technical Support Document. Though I am not a scientist, I have had great reservations about the hypothesis of antropogenic global warming. Unfortunately, it seems that political science has usurped the scientific method. Somehow the likes of Mr. McGartland et. al. are allowed to follow the maxim that when the facts do not fit the politically accepted hypothesis then change the facts.
Including the paper above submitted by Fred H. Haynie, which confirmed my suspicions (doubts) about anthropogenic CO2 being trapped in the atmosphere and/or its effects on temperature, I have read dozens of peer reviewed articles that debunk the hypothesis of global warming. I have yet to find a set of data based on scientific fact that supports the IPCC conclusions and/or forecasts. In fact, Most of the data that I find supports (with reasonable correlation) solar variatations as the most significant cause of temperature variation. My point is that even as a non-scientist, can see the observations (data) do not fit the Global Warming hypothesis. In short, I cannot peer review your paper but certainly I can understand it.
I can tell you, Dr. Carlin, I am very much angered by this debacle and intend to write a letter to my representatives as well as the EPA. Mr. McGartland, has commited an attrocity against the American People – you know, the people who pay his wages for truth and honesty.
I want to thank you very much for persistence in bringing this to the fore and allowing me to download your paper. I intend to spread the word as to the existence of this document.
Best Regards
Charles G. Edmiston
Dear Dr. Carlin:
When you say that EPA has not paid attention to the science of global warming I fully understand. Reading those emails shows clearly that the fix was in and they did not want any scientist to have a say about it. My work, currently up on ICECAP, has also been rejected by Science, Nature, and PNAS, which publishes trash from Hansen’s group at NASA. I have a problem similar to yours with multiple versions of my global warming paper out. And I still have to revise it to include the work of Kaufman et al. on arctic warming. I just may have to publish it myself if one of those Lysenkoist editors does not get second thoughts. In my paper I go further than any other “denialist” because I flatly assert that there is no AGW an there never was any. It follows clearly from my analysis of the satellite temperature records, available for of the last thirty years. During this period there were only two real warming incidents – the 1998 super El Nino and the twenty-first century high, a run of warm years from 2001 to 2007. Neither one was caused by carbon dioxide. The twenty-first century high came to an end with a La Nina cooling in 2007, signifying resumption of ENSO oscillations that existed before the super El Nino showed up. My paper also identifies the mechanism driving ENSO oscillations. Knowing that mechanism makes it easy to identify Indian Ocean overflow as the cause of that super El Nino. The twenty-first century high is caused simply by leftover heat from that super El Nino. If you take the time to read my paper with comprehension you will realize that global warming “science” as practiced by EPA’s favorite sources has no basis in science. Especially since Hansen’s claim that carbon dioxide warming started with the warming trend which began in 1977 is physically impossible. That immediately takes away any reason for IPCC to exist. Right now I am thinking of changing the title of my paper to better correspond to additions I have made. I will not post my revised version yet but if you are interested I can send it to you. Arno Arrak
If nothing else, this episode blows the field of economics to smithereens. One of the basic assumptions of micro is that “given perfect information, people will act in rational self-interest.” Presumably, then, the closer we get to the unattainable state of perfect (complete and accurate) information, the closer we will get to rational responses.
Well, science has been getting us closer and closer to that state for a number of years now with regard to GHG and climate change, and yet here comes a Ph.D economist telling us that because there is SOME uncertainty (never mind how poor the quality of some that uncertainty is), we should do NOTHING.
How the heck is that rational self-interest? It seems completely irrational to me.
That’s like saying because you aren’t 100% sure that it will rain, don’t carry an umbrella. Or because you aren’t 100% sure you are driving over a cliff, don’t bother to apply the brakes (you wouldn’t want to incur the expense to replace the brake linings).
As for suppression, well, I do wish the EPA had allowed Dr. Carlin to submit a “minority views” document. It isn’t as though the American people are so stupid that we don’t realize that there are some questions and that the information is not perfect. Wait, actually, the American people are that stupid but they do realize that there are different views. So put all the views up on the agency website and explain why the agency came to its conclusion and why it chose a particular action. That’s what they do with regulatory matters. It won’t hurt to show that they had internal discussions and some people disagreed. I’d rather know that the agency considered all views and all information – and carefully assessed the quality of that information – than have this silly distracting public argument about suppression.
Janet – How about NO uncertainty? It still does not help once the fix is in and the decisions are made. Those decisions are made by a select group that does not care what science says – they have full cover from that in the form of environmental activists. To eliminate your uncertainty read my paper – it requires intelligent concentration but no Ph. D. degree to comprehend. Take your time – there is much in it and it is twice as long as journal articles are allowed to be. In short: satellites show that there is not and never was any AGW from carbon dioxide. There was warming, starting with the super El Nino of 1998 but it was not due to carbon dioxide. The warming is over, model makers are going crazy because all their predictions are wrong, and ENSO will control our climate from now on. Enjoy
Dear Dr. Carlin, thank you for connecting the dots between solar inputs and atmospheric temperature fluctuations. As an astronomy minor undergrad, I have long felt that solar physics was too large of a component to leave out of the equation.
However….it isn’t global warming that is the problem! In fact, my primary concern is increasing acidification of the oceans, which is quite well documented. Early predictions that the oceans would be a “sink” for carbon dioxide via conversion into carbonates are not holding true, I suspect because no one foresaw the rise of Chinese industrialization and its concomitant coal consumption.
To this end, my colleagues and I are working on some rather unique solutions. Please visit our website and email if you have questions. Cheers, Chuck Stack, DrPH (candidate), University of Illinois School of Public Health and Vice-President, Constant Compliance Inc.
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Dr. Carlin,
Many of us bottom feaders (NWS) read your (hidden paper) and know its true. I liked Sen. Brasso bringing it up. Keep politics out of science!
Best Regards,
Todd
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