There is a news article by George Russell of Fox News titled
EPA Ponders Expanded Regulatory Power In Name of ‘Sustainable Development’
which includes the text [highlight added]
“Environmental impact assessment tends to focus primarily on the projected environmental effects of a particular action and alternatives to that action,” the study says. Sustainability impact assessment examines “the probable effects of a particular project or proposal on the social, environmental, and economic pillars of sustainability”—a greatly expanded approach.
One outcome: “The culture change being proposed here will require EPA to conduct an expanding number of assessments.”
As a result, “The agency can become more anticipatory, making greater use of new science and of forecasting.”
The catch, the study recognizes, is that under the new approach the EPA becomes more involved than ever in predicting the future.”
In my post on May 15 2009
I wrote
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
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.
In my May 15 2009 post, I gave an example of how their finding could be rewritten to cover other human climate forcings. As another example, based on our paper
Pielke Sr., R.A., A. Pitman, D. Niyogi, R. Mahmood, C. McAlpine, F. Hossain, K. Goldewijk, U. Nair, R. Betts, S. Fall, M. Reichstein, P. Kabat, and N. de Noblet-Ducoudré, 2011: Land use/land cover changes and climate: Modeling analysis and observational evidence. WIREs Clim Change 2011. doi: 10.1002/wcc.144
the paragraph above for an EPA Action could be rewritten as
The Administrator is further proposing to find that certain land use changes result in a threat of climate change. This is referred to as the cause or contribute finding.”
The EPA. according to this news report, could be developing justification to move into areas of regulation that they have not been involved with in the past, including land management.
They also, as implied in the article, reply on multi-decadal climate predictions of societal and environmental impacts, which, as has been shown in our paper
Pielke Sr., R.A., R. Wilby, D. Niyogi, F. Hossain, K. Dairuku, J. Adegoke, G. Kallos, T. Seastedt, and K. Suding, 2011: Dealing with complexity and extreme events using a bottom-up, resource-based vulnerability perspective. AGU Monograph on Complexity and Extreme Events in Geosciences, in press
and weblog posts; e.g. see
have NO predictive skill. The EPA would be seeking broader regulatory ability to influence policy but without a sound scientific basis.
I have always been a strong supporter of clean air and water, as exemplified with my two terms on the Colorado Air Quality Commission during the administration of Governor Romer (D). I have published numerous papers and taught classes on air quality including the use of mesoscale and boundary layer models to develop improved proceedures to assess the risk of pollution from power plant plumes, vehicular emissions, and other sources of these contaniments. The EPA has been a leader in the effort to reduce human and environmental exposure to toxic and hazardous pollutants.
However, the broadening of the EPA into climate forcings based on model predictions, as reported in the Fox News article, is a significant concern.
I would be interested in a dialog with them, based on the bottom-up, resource-based vulnerabiltiy persepective presented in our paper
Pielke Sr., R.A., R. Wilby, D. Niyogi, F. Hossain, K. Dairuku, J. Adegoke, G. Kallos, T. Seastedt, and K. Suding, 2011: Dealing with complexity and extreme events using a bottom-up, resource-based vulnerability perspective. AGU Monograph on Complexity and Extreme Events in Geosciences, in press
to see what areas of risk should fit within their regulatory framework. As we wrote in that paper, the bottom-up, resource-based framework
“concept requires the determination of the major threats to local and regional water, food, energy, human health, and ecosystem function resources from extreme events including climate, but also from other social and environmental issues. After these threats are identified for each resource, then the relative risks can be compared with other risks in order to adopt optimal preferred mitigation/adaptation strategies.”
In my view, this is the way forward with respect to assessing “sustainability”, and discussions should be undertaken to ascertain if the EPA is the right venue to do this.
As reported in the Fox News article, however, the EPA is considering the broadening out of their regulatory authority, but without building on a sound scientific foundation. There is no evidence that their approach to sustainability uses the inclusive, bottom-up assessment approach, such as given in our 2011 paper.
If the EPA persists in using the top-down IPCC approach to develop impact assessments, they will inevitably develop seriously flawed policy responses.
Climate Science: Roger Pielke Sr. 