Carlin Economics and Science

Applications of economics and science for rational public policy by Alan Carlin
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  • Publications
    • An Evaluation of U.S. Government Aid to India, June 1964
    • Environmentally Responsible Energy Pricing, 1993
    • The United States Experience with Economic Incentives to Control Environmental Pollution 1992
    • Environmental Investments, The Cost of a Clean Environment, A Summary, 1990
    • Environmental Investments, Cost of a Clean Environment, Report by the Administrator of the Environmental Protection Agency to the Congress of the United States, 1991
    • Implementation and Utilization of Geoengineering for Global Climate Change Control, 2007
    • Mr. Udall’s Analysis, An Unrepentant Rejoinder
    • Risky Gamble
    • Vehicle Safety, Why the Market Did Not Encourage It and How It Might be Made to Do So, 1968
    • Why a Different Approach Is Required if Global Climate Change Is to Be Controlled Efficiently or Even at All
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Why the Whole AGW/Warmist Narrative Is Even Weaker than Its Components

Alan Carlin | February 12, 2010

Current scrutiny of the AGW/alarmist/warmist positions quite deservedly centers primarily on the scientific integrity of the UN/IPCC reports, which in the United States may be crucial in the question of whether EPA acted in accordance with EPA regulations in determining that GHGs endanger public health and welfare. It is important, however, not to lose sight that the larger AGW/warmist view of the world makes a long series of crucial assumptions starting with the science and ending with the implementation of their proposed solution. This larger view of their assumptions suggests that some of the other assumptions are even less well grounded in reality than the ill-supported conclusions currently being discussed concerning the IPCC reports.

The publicized goal of the AGW alarmists/warmists and the European Union is to prevent more than a 2oC increase in global temperatures above preindustrial levels by reducing GHG emissions. They appear to have made a number of critical assumptions in order to arrive at this goal and their approach to achieving it, including the following:

    (1) Significant global warming is taking place and will take place in the future.
    (2) This warming is primarily due to increasing levels of greenhouse gases (GHGs) in the atmosphere.
    (3) These increasing GHG levels are primarily due to human activity in releasing GHGs.
    (4) It Is Realistic to Rapidly and Drastically Reduce Emissions of GHGs.
    (5) A United Nations consensus can be reached on a new global treaty to reduce GHG emissions.
    (6) But to obtain a consensus it would desirable and feasible for developed countries to pay large amounts to the developing countries.
    (7) If a consensus should be reached, each country would actually implement whatever it may agree to.
    (8) These actually implemented reductions would reduce global warming sufficiently so as to avoid a 2oC increase in global temperatures.

Each of these assumptions appears to be essential for the overall warmist narrative if they are to make a well-rounded case that their solution might have credibility. The first three are related to the IPCC science conclusions and therefore the EPA endangerment finding. The remainder, however, are not really discussed in the EPA endangerment finding since they involve potential regulatory action. But they may be relevant to future EPA rulemaking and are very relevant to the real world viability of the warmist narrative as a whole.

(1) There Will Be Significant Warming

It appears clear that there has been significant warming since the end of the Little Ice Age and in the 1930s (well before any significant impact of fossil fuel use is likely). There also was some modest warming in 1998, which shows no apparent relation to changes in CO2 levels. Otherwise it is difficult to make the case for significant warming in the last 70 years.

There is increasing evidence that the alleged warming in the 1980s and early 1990s may be more the result of the urban heat island effect and attempts to manipulate the ground-based station data than it is of actual temperature increases. The satellite temperature data (which started in 1978) shows an increase only in 1998 leaving aside periodic oscillations probably related to ENSO. See here and here for a more detailed discussion.

Now as to the future, the principal argument advanced for higher temperatures is that a number of computer models used by the UN IPCC, which have all used similar assumptions, all show increases for the remainder of this century. But these models reflect the assumptions used in constructing them rather than having any actual predictive power (see Section 1.7 of my Comments). If this first assumption is incorrect the later assumptions should make little difference since there will be no alleged problem to solve. I give this assumption a chance of being correct a generous 2 out of 10 or 20% because of our limited understanding of climate despite the lack of any real evidence for the warmist view.

(2) Alleged Warming Primarily Due to Rising GHG Levels

There is very little empirical evidence for rising GHG levels as the primary cause for global warming. Ice core data suggests that CO2 levels follow temperatures rather than the other way around. In fact, the all-important scientific tests of this hypothesis show that increases in GHG levels are not a significant cause of warming, as discussed here. A new study suggests the same thing. There is even a theoretical hypothesis by Miskolczi that argues that the Earth simply reduces atmospheric water vapor (a more important greenhouse gas) to offset higher GHG levels. If correct (and it at least has a real world empirical basis, unlike the AGW hypothesis), this means that increases in GHG levels would have no effect on global temperatures! So it seems reasonable to give this assumption a 1 out of 10.

(3) Rising Atmospheric GHG Levels Primarily Due to Human Releases of GHGs

There is little doubt that atmospheric GHG levels are increasing, but whether human-caused emissions are the primary cause is doubtful but more uncertain than assumption (1). Rather, the increasing GHG levels may be primarily due to increasing ocean temperatures over hundreds of years since water cannot absorb as much CO2 at higher temperatures. This appears to be a major scientific uncertainty, so I propose to assign this assumption a 3 out of 10.

(4) It Is Realistic to Rapidly and Drastically Reduce Emissions of GHGs

Warmists assume that GHG emission reductions are the solution to (1), (2), and (3), but this is far from obvious. They generally propose reductions in CO2 emissions of about 80% by 2050, often compared to 1990. Taking account of population growth and increases in energy use since 1990, the reductions “needed” per person would be almost 90% (see p. 721 here). Given the rapid spread of new energy using technology such as computers, server farms, and cell phones, this appears more than unlikely.

In reality, most experience to date has been that in political jurisdictions where the most serious energy efficiency efforts have been made, the “best” that has been achieved is that GHG emissions have been held steady because the emissions reductions have been balanced out by increases brought about by demand for increased uses by increasing urban populations (for added discussion of all this see pp. 721-5 here). Finally, analysis (see, for example, here and here) suggests that various geoengineering solutions such as stratospheric solar radiation management would much more reliably achieve cooling at a small fraction of the huge costs of reducing GHG emissions. So I’ll give this assumption a generous 1 in 10 chance of being correct.

(5) A New Binding International Treaty Can Be Reached to Reduce GHG Emissions

Since even countries with large emissions could theoretically have only a small effect on global emissions and emissions reductions by one country would disadvantage it economically compared to those that do not reduce them, the only way to reduce emissions (assuming that this could actually be done) effectively would be for most large emitting countries to enter into a binding treaty to reduce emissions. This may require the intervention of a world body such as the United Nations. But the Copenhagen Conference and those leading up to it strongly suggest that a new UN consensus would be very difficult to reach, at best. The UN did earlier reach consensuses on both the UNFCCC and on the Kyoto Protocol to it, but there has been no evidence that a new consensus agreement is even possible. So I’ll give this assumption a very generous 1 out of 10.

(6) Funding Can Be Found to “Buy” Support/”Reimburse” Less Developed Countries

Assuming that a new consensus could be reached, it is very likely that it would include large payments from developed to developing countries. Many less developed countries have suggested that they would be willing to concur on a new accord only if the developed countries pay them quite large sums presumably for the expenses they might incur for reducing emissions and/or the damages they may have incurred by the higher temperatures allegedly resulting from GHG emissions from the developed countries.

The principal problem is that even if developed countries should agree philosophically with this position, they must find the funding for these payments. This may not be very popular with voters in developed countries; it is certainly not in the United States. Indications so far are that most of the money so far promised may come from existing foreign aid budgets, which means that total foreign aid would probably change very little, which is consistent with the idea that the voters in developed countries are unlikely to approve significantly higher foreign aid levels. The leading proposal considered at the Copenhagen Climate Conference was that the funds would be allocated by the UN, which may not reassure voters in developed countries who would have to foot the bill. So I’ll give this assumption a generous 1 in 10.

(7) Most Major Emitters Would Actually Carry Out Whatever GHG Reductions They Might Agree to

Voluntary international agreements do not have a very good record of actually being implemented. Witness the Kellogg-Briand Treaty renouncing war as an instrument of national policy in 1928, or more to the point, the Kyoto Protocol negotiated in 1997. Neither one was/is being implemented in any serious way (see pp. 725-6 here). But without effective implementation there will certainly be little reduction in GHG emissions, and, even if the above assumptions should be correct, in global temperatures. So give this assumption a generous 1 in 10.

(8) Proposed Actual Reductions in GHG Emissions Would Achieve the 2oC Goal

Besides the ability to predict climate decades in advance, this assumption assumes that we know the so-called climate sensitivity factor, which relates changes in temperature to a doubling of CO2 levels. Unfortunately this is one of the most controversial issues in climate science and is not known with even moderate confidence. Hence any claims that a given change in emissions will result in a particular increase in temperatures cannot be ascertained. Thus it is not possible to know what change in global temperatures might result from any given change in GHG emissions. Finally, it can be shown (pages 712-6) that if the IPCC assumptions and data were all correct that the 2oC goal could not be achieved using this approach. So I give this assumption a 1 in 10 probability.

Taken together, the odds that all eight of these crucial warmist assumptions would prove to be correct appears to be close to zero. There is no rational expectation that assumption (8), their ultimate objective, would actually be achieved if the world actually tried to implement the warmist narrative. The last five assumptions are particularly indefensible, but are receiving less attention than the first three. This post explains why each of these critical assumptions are very dubious and why the assumption that taken together they are all correct is not reasonable.

Despite the dismal prospects that all these assumptions are correct, many prominent politicians (including the Obama Administration), US mainstream media, and academics continue to pursue the warmist narrative. Even if the prospects for each assumption were magically doubled, it remains unclear why rational people would support more than one of the warmist assumptions and particularly the overall narrative.

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How EPA Seeks to Unilaterally Impose GHG Emission Regulations Using UN “Science” Whether Anyone Likes It or Not

Alan Carlin | January 24, 2010

(Additional sources added January 30, 2010)

The Obama Administration decided in its first month in office to try to use the authority given to EPA by the Supreme Court in Massachusetts vs. EPA to regulate the emissions of greenhouse gases (GHGs) under the Clean Air Act. Instead of conducting its own independent analysis of the science, as I had strongly recommended and as it has traditionally done, however, EPA decided to basically use the summary reports issued by the United Nations under its Intergovernmental Panel on Climate Change and reports based primarily on these reports by the US Climate Change Science Program (CCSP). They claim that these reports represent a comprehensive analysis of the science and that there was no need to conduct its own analysis given the “rigorous” guidelines issued by these organizations.

In this way, EPA both expedited its task by using “ready made” external reports, and avoided any real discussion of the many scientific uncertainties surrounding climate change. The net result of EPA’s action thus far on climate change has been to avoid a vote by any legislative body as well as an independent analysis of the science. So no pesky legislators or skeptical scientists to placate. An explanation given by the Obama Administration was that they would prefer that GHGs be regulated under “cap and trade” legislation, but that perhaps the threat of administrative regulation would spur Congressional action. Since there has not been and is unlikely to be any major legislative action on cap and trade over the next few years due to strong opposition in the Senate, the US response to climate change is likely to largely come down to the actions that EPA takes.

US Public May Resent Such EPA Efforts

It has been my view that the American public would resent attempts by EPA to unilaterally impose regulations that would have the effect of greatly increasing the costs of energy use or imposing other constraints on energy-related activities without a new legislative mandate for this purpose, particularly without meticulous and truly independent EPA review of the science rather than depending on UN science. There is increasing evidence that the UN reports relied on by EPA are at best questionable in some of their major conclusions and may even be fraudulent in important aspects. But EPA has had such apparent faith in the UN science that they proceeded without carefully checking either the plausibility of the science or even its honesty.

Whether EPA’s decision was based on expediency or as an end run around the normal bureaucratic process is not known, but both motivations appear plausible. As a result of recent disclosures of the Climategate Emails (for a detailed analysis see here) and computer files it is now evident that not only are important parts of the science questionable but those who were primarily responsible for it may have been less than professional in their conduct and quite possibly engaged in scientific fraud. This was actually known prior to the release of the final EPA endangerment decision on December 7, 2009, but did not stop their finding on endangerment, perhaps out of the belief that this would somehow “save” the ill-fated UN Copenhagen conference. This finding became effective a week ago on January 14, so this seems an appropriate time to review the overall situation.

EPA’s Basic Argument Is that the UN Has Already Considered All Viewpoints

A review of EPA’s responses to public comments to the endangerment finding that their basic argument (see response 1-2) is that by using IPCC and other reports largely based on it that they have by proxy considered all relevant viewpoints. Generally speaking, any other ideas proposed by commenters that were inconsistent with the UN viewpoints were downplayed using various UN-based arguments and then rejected. They justified doing this primarily on the basis of the guidelines stated to have been used by the IPCC (see Appendix A of the EPA responses) and others in reviewing their reports. The very comprehensive 888 page skeptic NIPCC report was dismissed (see response 1-12) primarily on the basis that it does not detail an elaborate review process that had been followed. In other words, EPA appears to believe that stated procedure is more important than scientific substance.

Nowhere that I have found does it say how EPA verified that the UN reports were not biased and actually did consider all relevant viewpoints, or even that they tried to do so. Apparently the UN guidelines were sufficient in EPA’s view. But what if the UN guidelines were not carefully implemented and certain viewpoints were excluded, either by accident or perhaps even on purpose, as suggested by some of the Climategate Emails and the alleged disappearing Himalayan glaciers? What did EPA do to verify that this did not happen? Since the ultimate costs of EPA’s actions could run into many trillions of dollars, it is really important to be certain as to the science, something which EPA has not demonstrated.

The answer is that EPA did not do much if any verification in their headlong rush to respond to the new Administration or even under an earlier abortive effort during the Bush Administration. They were and are convinced that the UN science is reliable despite the many questions raised by skeptics. They accepted the assertions of the UN and other groups that their procedures were carefully implemented. But maybe these groups had conflicts of interest not covered, of course, by EPA ethics rules? And we are beginning to see evidence that less than careful implementation of these guidelines is a major problem with at least the IPCC reports, on which all the others are largely based. See, for example, the Climategate Emails, the Himalayan glacier problem referenced above and analyzed in terms of its implications for IPCC procedures here, the references here, Steve McIntyre’s analysis of some instances where the reports EPA relied on do not meet EPA’s requirements for such reports, and Chip Knappenberger’s summary of some of the instances where the IPCC did not follow its own procedures, to mention just a few.

But the UN Appears Not to Have Really Considered all Viewpoints, Particularly Those Held by Skeptics

Even before Climategate there were many indications that the IPCC might be less than objective in its reports. Consider, for example, the resignation letter by Chris Landsea from the preparation of the AR4 IPCC report which concluded that: “I personally cannot in good faith continue to contribute to a process that I view as both being motivated by pre-conceived agendas and being scientifically unsound.” After Climategate there can be little remaining doubt that Landsea was correct.

Dr. Benny Peiser, a long time and informed observer of the climate change scene, expressed it very clearly a few days ago as follows: “The IPCC review process has been shown on numerous occasions to lack transparency and due diligence. Its work is controlled by a tightly knit group of individuals who are completely convinced that they are right. As a result, conflicting data and evidence, even if published in peer reviewed journals, are regularly ignored, while exaggerated claims, even if contentious or not peer-reviewed, are often highlighted in IPCC reports. Not surprisingly, the IPCC has lost a lot of credibility in recent years. It is also losing the trust of more and more governments who are no longer following their advice – as the Copenhagen summit showed.”

Surely even if it used the UN science it was incumbent on EPA to carefully check whether the elaborate guidelines of the IPCC and CCSP were carefully and faithfully implemented. But it appears that they could not find time for this or perhaps more likely, did not want to, even after Climategate.

So EPA Apparently Intends to Proceed Unless Stopped by Congress or the Courts

Yet it appears to be the intention of EPA to regulate GHG emissions in the United States on the basis of this UN science, presumably as soon as they are able to finish the paperwork and observe some of the bureaucratic requirements. In these circumstances, only Congress and the courts have the authority to prevent this from happening, but would have to take one of several actions to bring this about. So far Congress has not chosen to do so, and it will take some time to see whether or not the courts may decide to block the implementation of various EPA regulations. I see no indication to date that EPA plans to back off its announced determination to impose its regulations without any serious independent analysis as to whether they are needed or would actually promote the purposes of the Clean Air Act. Whether Americans will be happy buying smaller, lighter-weight, less crash-worthy vehicles or paying more for energy remains to be seen. But they will not be given any real choice in the matter on the basis that EPA believes the UN science without the bother of careful, extensive, and particularly independent review. In other words the UN knows best and EPA must implement what they recommend as rapidly and with as little examination as possible.

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The Politicization of EPA: The Administration’s Radical Endangerment Gamble

Alan Carlin | December 8, 2009

On Monday EPA announced its endangerment finding for greenhouse gases. One can infer from the timing of the announcement that the Administration may have taken this action at this time in order to bring something to the table at the Copenhagen COP15 meeting. From a scientific viewpoint it was an odd time to do so given that the very recent Climategate disclosures would presumably have taken some time to digest and analyze for their possible effects on vital conclusions. So the timing may have been based more on the political rather than the scientific factors involved.

But from a larger viewpoint, the Obama who was going to find a way to resolve partisan bickering in Washington has now embarked on a major escalation of the conflict by using the power he holds over Executive Branch agencies to fight its enemies in Congress over the issue of global warming. Although EPA has always been organizationally an arm of the Administration in power, it has until this Administration been able to largely maintain the appearance if not the reality of being science based. That is now much harder to maintain.

Originally the rumor was that the purpose of the endangerment finding would be to pressure Congress into approving a cap and trade bill. But by now it appears fairly clear that the Administration will not be able to gather the needed votes in the Senate to pass the bill at least this year and probably even next year either with or without an endangerment finding. So there would seem to be little reason to push the endangerment finding now unless they intended to attempt to use it as the basis for negotiating at COP15.

Some Major Political Risks

This EPA endangerment approach carries some major risks for the Administration, however. The first risk is that EPA’s apparently politically motivated endangerment finding may be overturned in the now inevitable court reviews.

The second risk is that when implementing greenhouse gas regulations should be announced and certainly when they should ever be implemented the full responsibility will obviously fall onto the Administration rather than being shared between the Administration and Congress, which is what would occur if Congress ever adopted a cap and trade bill. So if many constituents end up being unhappy with the resulting regulations and particularly the greatly increased energy costs and decreased employment that will result it will be obvious who was responsible. And there may well be some unhappy constituents.

A third risk is that they will not be able to contain EPA’s actions since the law clearly specifies that much smaller sources are subject to regulation than they now contemplate, and legal action may force EPA to regulate smaller sources whether it wants to or not.

A fourth risk is that the added uncertainties created by the finding and the added costs in terms of higher energy prices and reduced employment will further weaken the Administration’s claims to be primarily interested in combatting the recession, the issue currently most on the mind of voters.

Some Additional Risks from the International Negotiations Needed to Insure a Worldwide Effort

But there are other risks as well. Suppose the COP15 meeting is unable to reach any agreement that the Administration can sell domestically? Or suppose that there is agreement on a new climate protocol and it comes into force but only a few countries actually live up to what they have agreed to, as has been the case for the Kyoto Protocol, so that what little effect reductions in CO2 may have on global temperatures is lost in the increased emissions of those countries that do not take promised reductions seriously. Or suppose that the developing world says that they will only support a new treaty if the developed world pays the bill, as they have so far done? Is the Administration willing to support a massive foreign aid bill providing funds to the UN, or one of its agencies such as the World Bank, to disperse as they may decide in the middle of the most serious recession of the postwar era to meet these demands by the developing world? Suppose the Russians will agree to a new treaty only if their credits resulting from the collapse of Soviet era manufacturing are honored in a new protocol, meaning that they would face very limited requirements? So the Administration seems to be gambling not only that Americans will not rebel against the potential EPA restrictions but that it can push through a massive UN-administered foreign aid program. And then there is the problem of how to get any possible new protocol through the Senate, which this time would require 67 votes rather than 60 needed for cap and trade. All this seems to me to be quite a gamble.

And just to make things worse from the Administration’s viewpoint, it is not only now clear that key parts of the global warmists’/UN science is scientifically incorrect (see my March Comments and my more recent blog post); it is now also clear how it is that their science came to be the way it is since we now have some of the actual programs used to bring this about as well as some of the Email and programming comments of some of those working to bring this about. Even Mother Nature is not cooperating with very cold, wintry weather sweeping the United States this week.

Finally, public support for the global warming/UN science and greenhouse gas regulation is dropping rapidly. So is it wise for the Administration to take all these risks from a political viewpoint? Or is the outcome going to be similar to the recent one in Australia, where last week Parliament turned down a cap a trade bill for the second time. Unless the Administration is driven solely by a radical environmental agenda come what may, the only rational conclusion is that they think they can somehow overcome all these major risks. The loss of even one of these sub-gambles may doom the lot. So perhaps they are driven primarily by environmental dogma rather than political calculation? Maybe they actually still believe that they are saving the world despite the demonstrably bad science they have endorsed in order to support this view?

The Skeptics Are Also Unlikely to Be Willing to Compromise

On the other side of the issue, the skeptics are unlikely to be willing to compromise given the recent confirmation of their suspicions concerning how the warmists’ science was derived. From their viewpoint there appear to be only a limited number of options:

  1. Assume that at least one of the lawsuits that may emerge will be upheld by the courts.
  2. Look for a must-pass bill to attach a rider that prohibits funds being used to implement greenhouse gas controls under the Clean Air Act.
  3. Use the Congressional Review Act to overrule the endangerment finding.

Whichever of these options the skeptics may pursue, the outcome will be the still further politicization of EPA. This may have much longer lasting effects than the current fight over global warming control and could lead to the end of EPA as a primarily science-based Agency.

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Climategate and EPA

Alan Carlin | December 1, 2009

In my view the Emails and computer files from the Climate Research Unit (CRU) in Great Britain may prove to be of some importance to the USEPA’s current attempts to control greenhouse gases (GHGs) under the Clean Air Act. This is because EPA, perhaps at the urging of others in the Obama Administration, has proposed to regulate GHG emissions on the basis of the Intergovernmental Panel on Climate Change (IPCC) reports and reports primarily based on these reports. This is highly unusual in EPA’s almost 39 year history. I cannot think of any instance where EPA depended so heavily on non-EPA synthesis reports to justify proposed regulatory action.

As a result of this EPA decision, EPA’s fortunes in regulating GHGs are directly tied to the fate of the IPCC reports. Although it is hard to argue that any one CRU Email or computer file notation proves the IPCC conclusions wrong, taken as a whole they do strongly suggest two conclusions: First, the CRU and many of its associates (and Email recipients) elsewhere (henceforth CRU et al.), are very tightly tied to the IPCC both in influence and belief and do not appear to be paragons of scientific objectivity and ethics. Second, their data handling leaves something to be desired in terms of data retention, database documentation, and questionable data manipulation.

CRU et al’s Lack of Scientific Objectivity

It seems clear to me that if a group (such as EPA) wanted to get an objective scientific judgment on climate change science, CRU et al., and therefore the IPCC, might be the last place that they would want to rely on. Each “trick” CRU et al used to torture the data they had to yield what appears to be their desired conclusions may have fooled a few more readers into thinking that their basic arguments were valid, but has to decrease the overall assessment of their objectivity. Attempts to manipulate peer reviews and journal acceptances are not acceptable scientific activities. Withholding key scientific data can only make one question their dedication to scientific principles. Hiding their alleged destruction of the basic temperature data that would allow reconstruction of what they have done is almost as bad as discarding such critical data in the first place. Using data that cannot be reproduced is not very useful scientifically or from a regulatory viewpoint.

Yet despite these now evident problems with the CRU et al’s data and research, EPA is now stuck with the IPCC reports, and therefore the closely associated CRU et al’s data and research has become central to its attempts to regulate GHGs. Given that it currently appears unlikely that the Senate will agree to anything resembling the current cap and trade bill, this EPA decision may well greatly decrease the chances that the US will in the end implement serious regulation of GHGs since EPA regulations under the Clean Air Act must survive judicial review of any regulatons that EPA may promulgate.

Need for New Approach

If EPA wants to pursue the regulation of GHGs despite the weak scientific basis for it, there is an evident need for a whole new approach based on truly independent and careful review of the problem using the highest standards of scientific intergrity which does not rely on what appears to be biased research and sloppy data from CRU et al. Although I did not know of the recent revelations concerning CRU et al last March, my Comments strongly called for such a reappraisal. This problem will not go away and may even get worse if we should learn more about the CRU et al’s work. There exists a possibility that EPA’s current approach might succeed by some judicial fluke, but the chances seem to be decreasing with each new revelation concerning the CRU et al.

Presumably one of the reasons that EPA decided to rely on the IPCC and indirectly on the CRU is that the Obama Administration may have felt some urgency to move rapidly on global warming control. Given the downtrend in global temperatures over the past 11 years and the likelihood that this will continue for some time (see Section 2.4 of my Comments) because of the Pacific Decadal Oscillation (PDO), there would appear to be ample time to start over and do it carefully and thoroughly this time with full input by everyone that may be interested.

Basic Problem Remains

Despite the uproar concerning CRU et al’s data and research, the basic problem remains that the UN hypothesis that increases in GHGs/CO2 will result in significant increases in global temperatures has not been confirmed by comparisons with real world data. Unless it is, attempts to decrease GHG/CO2 emissions in order to significantly change global temperatures are very likely to fail. This is the primary question that EPA and climate scientists need to address before any control efforts are undertaken. Happily we appear to have the time to do so, and to do so objectively using reproducible data.

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Why the Choice of Energy Sources Should Be Left to the Market after Externalities Are Taken into Account

Alan Carlin | September 13, 2009

One of the major problems with attempts by government to select winners in the selection of energy sources is that they are almost certain to select inefficient and quite possibly even environmentally inferior choices compared to leaving these choices to the workings of the market. The choice of energy sources is complicated, region specific, and subject to being influenced by the many special interests with something to gain by the choice made. Industries that make solar panels or windmill parts are more than likely to lobby for their particular solutions without regard for the larger national interest.

The national interest is not to satisfy various interest groups but to supply energy at the lowest possible cost after fully taking into account the adverse environmental effects of each alternative. Energy is an input to many products and services; higher cost energy increases the cost of these products and services, and makes them less competitive in the marketplace.

Cap and trade, if implemented without favoratism (a big if, of course), is one way to try to take into account the adverse environmental effects of energy use on climate change. But attempts to use this approach assume that there is a significant relationship, and that if there is, that we can accurately determine the exact “cap” that would avoid the alleged adverse effects of the resulting increased emissions of CO2. As explained in an earlier post, the hypothesis that there is a significant relationship is not supported by current observations. Hence there is currently no basis for a cap on CO2 emissions.

With some significant exceptions, the choice of energy sources to be built and used has traditionally been decided in the United States by the market rather than by government. In order to insure that the environmental effects of each source are fully taken into account it is necessary that the full social costs of these adverse effects be taken into account by those making the choices. This is ideally done by including these environmental costs in the price of energy from these sources.

Adverse Environmental Effects of Energy Sources Can Be Determined or at least Attempted

About 15 years ago several economists and I attempted to compare then existing taxes on various energy sources with the adverse environmental effects each of these sources cause. In doing so, we excluded solar, wind, and the possible adverse effects of CO2 on climate to simplify the effort. Our findings can be found here and more fully here. Generally speaking, we found that coal was somewhat “undertaxed,” gasoline was about neutral, and natural gas “overtaxed” compared to their adverse environmental effects. Now that we know that there are no significant adverse effects resulting from increased CO2 levels in the atmosphere (at least based on currently available information), the results from this earlier study appear to be as valid today as they were then (although they could be usefully updated and expanded to additional sources, of course). The National Academy of Sciences is now making such an effort.

So contrary to current efforts to impose “renewable energy standards” the most economically justifiable approach would be to adjust existing taxes on various energy sources to account for the adverse environmental effects that we know exist and allow the market to work its will. This effort might start with our previous findings and add the adverse environmental effects of solar and wind sources. For example, wind turbines take a significant toll on migratory bird species that needs to be taken into account to the extent possible.

Renewable Energy Standards Can Be Very Expensive

Many economic decisions are best left to the workings of the market. Since markets generally result in more economically efficient solutions it makes sense to use them to make those decisions rather than using politically-based decisions. The choice of energy sources is an excellent example.

Some politicians may regard renewable energy standards as a “free” consolation prize for environmentalists if cap and trade should be turned down. Unfortunately, it is far from free. It is likely to lead to higher energy costs for many years and quite possibly inferior environmental choices. Where the energy source is intermitant, such as wind and solar, the cost of building substitute sources to insure availability needs to be taken into account, as they would be in private markets.

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Why the Basic Ground-measured Global Temperature Data Presented by AGW Supporters Is Suspect

Alan Carlin | August 28, 2009

(One source added January 28, 2010)

One of the basic problems in reaching rational conclusions with regard to global climate change problems is that AGW proponents and skeptics largely use different data sources and very different analyses of the global temperature data to support their cases.

Global Temperatures According to NOAA
Global Temperatures According to NOAA (click to enlarge)

This first chart shows a typical global temperature chart similar to those often used by AGW supporters. Like most such charts, it represents global temperatures based on ground-based readings, and is apparently constructed by smoothing annual data. It shows the familiar “hockey stick” emphasizing the rise in temperatures since the mid-1970s that has become so familiar in AGW presentations.

The Satellite Data Shows What Appears to Be a Very Different Picture


And Using Satellite Data
And Using Satellite Data (click to enlarge)

AGW supporters almost never use satellite data on near-ground temperatures despite its availability since 1978. This second chart shows what appears to be a very different picture using it. One would think that the two sources of data would yield quite similar trends and have important similarities since they attempt to measure air temperatures so close to each other. But this appears initially not to be the case.

What the satellite data shows is a roughly flat trend with 3-5 year cycles from 1978 through about 1996. This cycle appears to be closely related to the El Nino Southern Oscillation (ENSO) which shows a very similar pattern. But the flat trend shows no obvious effects from the increasing atmospheric CO2 levels during this crucial period for the AGW’s point of view.

Then in 1998 there was a large spike in temperatures (which appears to be largely unexplained by anyone and has no obvious relation to changes in CO2 levels) that occurred just when the 3-5 year cycle might have been expected to bottom.

In the early 21st Century the same essentially flat pattern of 3-5 year cycles appears to reestablish itself in the satellite data but at a slightly higher temperature until a breakdown occurred in late 2007 back down towards what may turn out to be the original levels in the 1978-96 period.

So it appears that the the two charts suggest very different things. The AGW presentation obscures the 3-5 ENSO cycle and emphasizes what appears to be a fairly steady increase in temperatures from the 1970s on that makes the presumed influence of rising CO2 more plausible. The satellite chart, on the other hand, highlights the ENSO cycle and the abrupt changes in 1998, and makes the presumed influence of CO2 appear implausible.

Comparison of Ground (blue) and Satellite (red) Temps
Ground (blue) and Satellite (red) Temps (click to enlarge)

If both monthly ground-based and satellite data are combined on one chart (the third one), there appear to be more similarities between the two charts. In the 1978-96 period the ground data (highlighted in blue) appears to increasingly diverge from the satellite data and increases during the 1978-96 period rather than showing the flat trend exhibited by the satellite data. But there appear to be substantial similarities between the two data sets thereafter.

So in the ground-based case there appears to be a gradual rise in temperatures during 1978-2005 which appears to be at least somewhat consistent with the increase in CO2 levels. And in the satellite case there is no visual support for a gradual increase or any apparent role for CO2 during the whole period.

Increasing Reason to Question the Ground-based Data

There is increasing reason to question the basic ground-based data as well as the rationale for the AGW interpretation of it. There have been a number of studies suggesting that ground-based data is severely compromised by urban heat island effects, inappropriate placement of monitors that increase recorded temperatures over what they would have been if the instruments had been properly cited, and the drop-out of a large number of rural stations in the 1970s. The urban heat island effects arise because urban areas retain heat much more than non-urban areas and many urban areas in the US and elsewhere expanded rapidly in the late 20th Century. This may have been accentuated by the decision to drop many rural sites. So prior to 1997 the upward bias in the ground-based temperatures may represent little more than the results of these three effects.

In addition, there are many reports that the ground data has been subjected to substantial and often repeated adjustments for various factors. In the case of the crucial HadCRUT ground-based data developed in Great Britain, and the source most often used by the United Nations, the custodian has refused to release the data and their manipulations of it and recently said that they have not even retained the original observations. So it now appears to be impossible to reconstruct exactly what the custodian may have done with the data despite the fact that this is the data most often relied upon by AGW supporters to make their case. Finally, the heavily smoothed ground-based annual data appears to hide rather than illuminate what has actually happened.

For more information on the problems with the ground-based data see here and more recently here.

So what should we make of this seemingly perplexing but very important battle of the global temperature charts? A reasonable interpretation is that the AGW charts cleverly hide the ENSO cycle through use of annual data, heavy smoothing, and questionable data and show a gradual increase in temperatures starting in the mid-1970s due to an upward bias in the data. But If monthly data are used, no smoothing is carried out, and the increasing ground-based temperature data during 1978-96 is assumed to be replaced with the flat trend line shown in the satellite data, the two data sources would actually appear to be quite consistent except that the ground-based data is generally higher than the satellite data. This difference may also be due to biased ground-based data. But if this substitution is made, the same major features would appear in both cases.

I believe it is incumbent on AGW supporters to show why the monthly satellite data without smoothing should not be used since it avoids using the suspect ground-based data and provides a more accurate picture of what actually happened. It is they, after all, that are asking the world to spend astronomical amounts on the basis of their hypothesis. If this is done, their “hockey stick” disappears and along with it the familiar AGW arguments for their hypothesis. This is not proof of biased 1978-96 ground data but appears to be the most reasonable explanation of the remaining differences between the two data sources.

The satellite data may have its own problems, of course, but there is reason to believe that it may be far more reliable than the ground-based data. There are also two independent data services which have delivered very similar data. A much more detailed analysis of what the satellite data can tell us can be downloaded from here, which is also the immediate source of the charts above.

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Why the UN GHG Hypothesis Should Be Rejected on Scientific Grounds

Alan Carlin | August 9, 2009

(Updated August 11, 2010 to include added sources)

In a previous post I explained why I believe that the United Nations GHG hypothesis that significant global warming will occur as a result of increasing greenhouse gas (such as CO2) levels is implausible.  In this post I will explain why I believe that the best available evidence indicates that the hypothesis is not just implausible but rather should and can be rejected on scientific grounds.

For a broader view of how science progresses see here. Clearly I am in the Popper camp in this regard. Kuhn’s view may more accurately describe how science has unfortunately sometimes been historically conducted, but certainly not how it should be.

Before going further, it is important to explain that the important word in the definition of the UN GHG hypothesis is “significant.” There is little doubt that higher levels of greenhouse gases are likely to lead to slightly higher global temperatures since that is why they are called greenhouse gases. The United Nations, however, claims that increases in the levels of these gases in the atmosphere are the predominant influence on global temperatures. Hence the qualification “significant” in order to include the UN claims while excluding the minor warming that has probably been caused by increasing levels of greenhouse gases in the atmosphere.

As explained in my Comments, the models relied on so heavily by the UN do not prove anything scientifically one way or the other.  They simply show what the model builders believe would happen if the hypothesis and all their other assumptions were correct. The model results are interesting, perhaps even useful, but irrelevant in deciding whether their AGW hypothesis should be accepted or rejected. This is because they do not compare the implications of the hypothesis with real world data other than past temperature data which the models have been modified to emulate. 

The Critical Role Played by the Scientific Method

According to the scientific method, a scientific hypothesis must be tested by comparing real world data with the implications of the hypothesis.  This is how Albert Einstein was able to persuade the world that his ideas on relativity had merit.  Scientists kept proposing real world tests of his hypothesis but each test confirmed its validity. After a number of these tests, the opposition conceded that his hypothesis was valid. (For a description of this extended process see, for example, Jeffrey Crelinsten’s Einstein’s Jury: The Race to Test Relativity). A similar process resulted in the acceptance of Newtonian mechanics and other hypotheses which gradually assumed the status of theories.

If the comparison with real world data does not confirm the hypothesis, the hypothesis should be rejected. There are only two alternatives from a scientific viewpoint when this happens: Discard or at least modify the hypothesis or discover an error in the data used to reject it.  From a scientific viewpoint, it is totally irrelevant how many public officials or scientific organizations–or how prominent they may be–support a particular hypothesis.  A hypothesis has scientific validity only by comparison with real world data. Joanne Nova has expressed this very well in her Handbook downloaded here.

There are numerous inconsistencies between the UN CO2 hypothesis and observed data.  Gregory explicitly compares the explanatory power of the UN hypothesis with the competing Svensmark hypothesis and finds the UN hypothesis wanting.  Idso and Singer provide extensive scientific evidence against the UN hypothesis.

But perhaps the most fundamental comparisons are between the major physical effects of the UN hypothesis and available real world data.  There are four particularly telling physically-based basic comparisons in this regard.  According to the scientific method an inconsistency even in one of these comparisons means that the hypothesis should be rejected from a scientific viewpoint.  It is important to deal with the uncertainty introduced by the word “significant,” however. This uncertainty increases the likelihood that a few of the comparisons may prove positive. Hence it increases the strength of any negative finding. In fact, if a number of tests should prove negative it makes the tests very powerful evidence against the hypothesis.

Four Critical Comparisons with Real World Data

Acceptance of the hypothesis requires that each of the following four observations are present:

  1. There is a hot spot in the upper troposphere in the tropics as predicted by the UN. If greenhouse gases are significantly warming the Earth the first signs of it are supposed to appear about 10 kilometers above the tropics. The lack of such a hotspot is discussed in my Comments in Section 2.9 as well as by Joanne Nova downloaded here. She discusses the major objections that have been raised to this comparison and why she believes they are not credible. For a further update see here. For more detailed information see here.
  2. There is heating of the oceans.  The added heat generated by increasing greenhouse gas levels in the atmosphere must be stored somewhere. It has not been showing up in the atmosphere in the last decade, so if the hypothesis is valid it must be going into the oceans. But in the last few years this has not been the case. An extensive discussion of the evidence can be found here. The bottom line is that the AGW hypothesis fails this test as well.
  3. The observed outgoing radiation fluxes from the Earth decrease with increases in sea surface temperatures. Satellite data, however, shows an increase, which is inconsistent with the high climate sensitivities to increases in CO2 and positive feedback so crucial to the UN’s case. A new peer reviewed paper accepted for publication on this subject can be found here. For a video of Christopher Monckton’s presentation on this study on the Glenn Beck program see here. For a more up-to-date but considerably more technical presentation, see starting at slide 28 here or in the corresponding Richard Lidzen video found here.
  4. The atmospheric response times for volcanic sequences would be longer than they would be without the UN hypothesis. If climate sensitivity is as high as the UN claims, it should show up in the atmosphere’s response time from volcanic eruptions. The reason for this is that climate sensitivity is also a measure of how tightly air and sea temperatures are coupled. High sensitivity is associated with weak coupling, allowing the establishment of significant disequilibration of the sea surface temperature. A discussion of this can be found in a 1997 report from the National Academy of Sciences here.  The discussion may be a little technical, but the conclusion that the data “is consistent with low [climate] sensitivity,” which is inconsistent with one of the UN’s crucial conclusions, is clear.

The conclusions are the same in each of these four cases: The UN hypothesis is not supported or even partially supported by these comparisons with real world data.  As Professor Richard Lindzen of MIT has recently observed with regard to his findings on comparison 3 above, “In a normal field, these results would pretty much wrap things up, but global warming/climate change has developed so much momentum that it has a life of its own – quite removed from science.”

The data are far from perfect, of course, perhaps in part because of a lack of effort to gather it.  But they all tell the same story.  This means that the hypothesis should be rejected scientifically based on current information. Future testing could lead to other conclusions, of course, but for now rejection is the rational course of action.

Implications

Accordingly, using this hypothesis has no scientific basis based on current knowledge concerning these four comparisons.  Attempts to argue that it is anything more than a religious or superstitious belief must show that the data used in each and every one of these tests (as well as others that may be proposed in the future) is wrong.

Accordingly, using the UN hypothesis as a basis for formulating policy is not useful or relevant from a scientific viewpoint.  Attempts to do so are likely to lead to scientifically unsound policy. Given that the current proposed “solution”–radically reducing CO2 emissions–would cost many tens of trillions of dollars, it is particularly incumbent on those advocating this very large expenditure (for which there are many other uses if it should actually become available) to show that their solution should not also be rejected since it is based on a hypothesis that should be rejected.

The UN reports issued to date do not show that the data used in these four important comparisons is incorrect, and therefore the reports should not be used as a basis for policy in my view. Reports substantially based on the UN reports, such as the draft EPA Endangerment Technical Support Document reviewed in my Comments, should also not be used for policy purposes for the same reason in my view.

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Global Temperature Charts Suggest Implausibility of UN CO2 Hypothesis

Alan Carlin | July 25, 2009

Alan Carlin on Glenn Beck program
On June 30 I appeared on the Glenn Beck show, where I showed two charts from my Comments on the proposed EPA endangerment finding report. Although these two graphs do not prove or disprove the existence of significant global warming as a result of increasing levels of carbon dioxide in the atmosphere (the principal UN hypothesis), they are readily understandable and suggest that substantial such warming from this cause is implausible.

UN Temperature Projections Compared with Measured Global Temperatures


Comparison of UN Projections with Temperatures
Comparison of UN Projections with Temperatures (click to enlarge)

The first graph compares some of the United Nations IPCC model projections (in red, orange, and brown) and actual global temperature surface (green) and satellite (blue) measurements. There is also a yellow line representing the UN’s projection of future temperatures if there were no further human caused carbon dioxide (CO2) emissions. The vertical scale shows temperatures and the horizontal scale calendar years.

It is quite evident that there appears to be an increasing divergence between the UN projections and the global temperature measurements. The obvious question is how this could be if the UN projections are correct. We cannot rule out a brief divergence between projections and temperatures, of course, based on other random and unexplained factors.

But the other seemingly more likely possibility is that the UN projections are substantially inaccurate and exaggerate the projected temperature increase on the high side. Subsequent temperature measurements (not shown here) do not resolve this discrepancy.  If the projections are substantially too high, perhaps they do not deserve to be taken as seriously as many people now do.

Decreasing Measured Temperatures and Increasing CO2 Levels


Comparison of Decreasing Temeratures to Increasing CO2
Comparison of Decreasing Temeratures to Increasing CO2 (click to enlarge)

The second graph also shows global temperatures by calendar year for the period 2002 until mid-2008, but superimposes on this chart yearly atmospheric CO2 levels (shown in green) by year. Since there are two principal sources of global temperature data, surface (shown in black) and satellite (shown in red) measurements, both are shown along with trend lines for each. Inspection of the data shows that while temperature data were trending down over this period, CO2 levels were steadily increasing.

This again suggests that either there was a brief, random, divergence from what would be expected if the UN hypothesis concerning the effects of increasing CO2 levels on temperatures are correct, or that the UN models and hypothesis are simply incorrect.   The brief divergence possibility appears implausible because very similar divergences have appeared previously during the periods 1880 to 1910 and 1940 to the mid-1970s. In fact, the changes in global temperatures appear to be cyclical and to be very similar to the pattern of the Pacific Decadal Oscillation (PDO) which has roughly a 60 year cycle (with 30 up years followed by 30 down years). This leaves the other possibility–that something may be wrong with the UN’s basic hypothesis that CO2 levels are the major determinant of global temperatures since the UN models do not show any such cycles and do not explain the down years from 1940 to the mid-1970s or since 1998.

And if their hypothesis is incorrect, their proposed solution, decreasing CO2 emissions into the atmosphere, would not be effective in preventing increases in global temperatures. At the very least there would appear to be other important factors influencing global temperatures besides CO2 levels that the UN has not considered.  It is important that we understand what these other factors might be before committing ourselves to trying to reduce CO2 emissions at the cost of many trillions of dollars.  To proceed now with reducing CO2 emissions would not only be very expensive but possibly largely futile as well.

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How Skepticism Concerning the UN Hypothesis Fits with Interest in Geoengineering

Alan Carlin | July 22, 2009

Some may have wondered how I reconcile my skepticism about the United Nations hypothesis that emissions of CO2 and other greenhouse gases have an important effect on global temperatures fits with my interest in stratospheric geoengineering as an attractive alternative to reductions in CO2 emissions? This interest is shown in four of my previous publications in climate science under publications. If there is no real risk of a significant global temperature rise due to CO2, we may not need geoengineering after all. My view is that we still have much to learn about Earth’s climate and that the history of interglacial periods suggest that we could be faced with global cooling within a few thousand years. It would therefore appear prudent to be prepared for the eventuality that significant global warming or cooling could occur.

For reasons explained in my geoengineering papers, CO2 emissions control is unlikely to be effective in controlling global warming and useless for global cooling. For a comparatively modest cost, however, we could acquire the capability to carry out stratospheric geoengineering. Chances are very good that it would not be advisable to actually use it, but acquiring the capability would appear to be a wise precaution. It might also reassure those who believe in the UN hypothesis that possible potential warming could be stopped if there should ever be agreement that something needed to be done.

So in summary, I believe that significant global warming is unlikely this century, particularly as a result of increasing CO2 levels, but if it should start to occur it might be useful to be prepared to deal with such warming or the slightly more likely global cooling if necessary through stratospheric geoengineering. One other advantage of being prepared to use effective geoengineering techniques is that we would no longer have any need to undertake extremely expensive efforts to reduce CO2 emissions on the chance that there might be damaging global temperature increases or other adverse effects until the effects actually started to occur.

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Comments on Proposed EPA Endangerment Technical Support Document

Alan Carlin | July 9, 2009

Comments on Draft Technical Support Document for Endangerment Analysis for Greenhouse Gas Emissions under the Clean Air ActOn 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:

    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

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