Comments On The EPA “Proposed Endangerment And Cause Or Contribute Findings For Greenhouse Gases Under The Clean Air Act”

I have generally supported most EPA actions which have been designed to support environmental improvement. These regulations have resulted in much cleaner water and air quality over the past several decades; e.g. see

National Research Council, 2003: Managing carbon monoxide pollution in meteorological and topographical problem areas. The National Academies Press, Washington, DC, 196 pp.

However, the EPA Endangerment Findings for CO2 as a climate forcing falls far outside of the boundary of the type of regulations that this agency should be seeking.

The EPA on April 17, 2009 released this finding in “Proposed Endangerment and Cause or Contribute Findings for Greenhouse Gases under the Clean Air Act”.  

This report is a clearly biased presentation of the science which continues to use the same reports (IPCC and CCSP) to promote a particular political viewpoint on climate (and energy) policy).

The text includes the statements

“The Administrator signed a proposal with two distinct findings regarding greenhouse gases under section 202(a) of the Clean Air Act:

Action

“The Administrator is proposing to find that the current and projected concentrations of the mix of six key greenhouse gases—carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6)—in the atmosphere threaten the public health and welfare of current and future generations. This is referred to as the endangerment finding.

The Administrator is further proposing to find that the combined emissions of CO2, CH4, N2O, and HFCs from new motor vehicles and motor vehicle engines contribute to the atmospheric concentrations of these key greenhouse gases and hence to the threat of climate change. This is referred to as the cause or contribute finding.”

As Climate Science has shown in the past; e.g. see

New Plans To Regulate CO2 As A Pollutant

Comments On The Plan To Declare Carbon Dioxide as a Dangerous Pollutant

A Carbon Tax For Animal Emissions – More Unintended Consequences Of Carbon Policy In The Guise Of Climate Policy

Will Climate Effects Trump Health Effects In Air Quality Regulations?

Supreme Court Rules That The EPA Can Regulate CO2 Emissions

Science Issues Related To The Lawsuit To The Supreme Court As To Whether CO2 is a Pollutant

the “cause” for their endangerment finding can cover any human caused climate forcing. For just one example, the paragraph above could be rewritten as

The Administrator is further proposing to find that the combined emissions of CO2 and CH4 from agriculture contribute to the atmospheric concentrations of these key greenhouse gases and hence to the threat of climate change. This is referred to as the cause or contribute finding.”

The EPA, by expanding its authority to be able to regulate for climate, will have enormous power to regulate all aspects of society. The seriousness of this grasp for power, using “science” as the tool, needs to be widely communicated and debated.

Further information is given at “Overview of EPA’s Proposed Endangerment and Cause or Contribute Findings for Greenhouse Gases under the Clean Air Act”, where it includes the information

 “After a thorough examination of the scientific evidence on the causes and impacts of current and future climate change, as well as other effects of greenhouse gases, the Administrator concludes that the science compellingly supports a positive endangerment finding for both public health and welfare. In her decision, the Administrator relied heavily upon the major findings and conclusions from recent assessments of the U.S. Climate Change Science Program and the Intergovernmental Panel on Climate Change.”

“The Administrator is proposing this endangerment finding after considering both observed and projected future effects of climate change, key uncertainties, and the full range of risks and impacts to public health and welfare occurring within the United States. The scientific evidence concerning risks and impacts occurring outside the United States, including risks and impacts that can affect people in the United States, provides further support for this proposed endangerment finding.”

What these statements tell us is that their finding includes results from multi-decadal climate predictions, which have never shown regional predictive skill, including any ability to predict past major weather events such as droughts!

Nevertheless, they make claims with respect to the climate risks as if these are certain, despite the absence of skill in predicting them for the 20th century. They claim that

 “The effects of climate change observed to date and projected to occur in the future include, but are not limited to, more frequent and intense heat waves, more severe wildfires, degraded air quality, more heavy downpours and flooding, increased drought, greater sea level rise, more intense storms, harm to water resources, harm to agriculture, and harm to wildlife and ecosystems. The Administrator considers these impacts to be effects on public health and welfare within the meaning of the Clean Air Act.”

In the document “Frequently Asked Questions on the Proposed Endangerment and Cause or Contribute Findings for Greenhouse Gases”, they have the Q&A

 “On what science was the proposed Endangerment Finding based?

“The Administrator relied heavily on existing, peer-reviewed scientific literature. In particular, she relied on reports and conclusions from the U.S. Climate Change Science Program, the National Research Council, and the Intergovernmental Panel on Climate Change because they represent the current state of knowledge on climate change science, vulnerabilities, and impacts. These studies are authored by leading scientific experts and underwent multiple layers of peer review, including, in many cases, review and acceptance by government agencies.”

As documented in

Pielke Sr., Roger A., 2008: A Broader View of the Role of Humans in the Climate System is Required In the Assessment of Costs and Benefits of Effective Climate Policy.Written Testimony for the Subcommittee on Energy and Air Quality of the Committee on Energy and Commerce Hearing “Climate Change: Costs of Inaction” – Honorable Rick Boucher, Chairman. June 26, 2008, Washington, DC., 52 pp.

Pielke Sr., Roger A., 2005: Public Comment on CCSP Report “Temperature Trends in the Lower Atmosphere: Steps for Understanding and Reconciling Differences“. 88 pp including appendices.

Protecting The IPCC Turf – There Are No Independent Climate Assessments Of The IPCC WG1 Report Funded And Sanctioned By The NSF, NASA Or The NRC.

the conflict of interest (with most of the same individuals leading the reports) is easy to see; i.e. the Federal (non-EPA) expert reviewers for the EPA Endangerment findings (see “Technical Support Document for the Proposed Findings”) are

Virginia Burkett, USGS; Phil DeCola; NASA (on detail to OSTP); William Emanuel, NASA; Anne Grambsch, EPA; Jerry Hatfield, USDA; Anthony Janetos; DOE Pacific Northwest National Laboratory; Linda Joyce, USDA Forest Service; Thomas Karl, NOAA; Michael McGeehin, CDC; Gavin Schmidt, NASA; Susan Solomon, NOAA; Thomas Wilbanks, DOE Oak Ridge National Laboratory.

In conclusion, the EPA Endangerment findings is the culmination of a several year effort for a small group of climate scientists and others to use their positions as lead authors on the IPCC, CCSP and NRC reports to promote a political agenda.

Now that their efforts have reached the federal policy decision level, Climate Science urges that there be an independent commission of climate scientists who can evaluate the assement process that led to the EPA findings as well as the climate science upon which it is constructed.

 

 

 

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Filed under Climate Change Regulations, Climate Science Misconceptions, RA Pielke Sr. Position Statements

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