Posted by: Matt Dempsey Matt_Dempsey@epw.senate.gov (202)224-9797
In a memo released on April 23, EPA Administrator Lisa Jackson, to great fanfare, established new guidelines to govern Agency decision-making. As she wrote, “In all its programs, EPA will provide for the fullest possible public participation in decision-making.” What’s more, she stated, “This requires not only that EPA remain open and accessible to those representing all points of view, but also that EPA offices responsible for decisions take affirmative steps to solicit the views of those who will be affected by these decisions [emphasis added].” This is a policy deserving of high praise, no doubt. Yet according to news reports, EPA has failed to meet Administrator Jacksons’s standard.
Consider the case of Dr. Alan Carlin, a PhD economist in EPA’s Office of Policy, Economics, and Innovation. In a compelling analysis, Carlin questioned, in fine detail, the science underlying the agency’s proposed endangerment finding. According to Carlin, a 38-year veteran of EPA, and a fellow agency employee, “We have become increasingly concerned that EPA and many other agencies and countries have paid too little attention to the science of global warming…We believe our concerns and reservations are sufficiently important to warrant a serious review of the science by EPA before any attempt is made to reach conclusions on the subject.”
One would think an agency dedicated to transparency and openness would have allowed such a review. But Carlin’s request was unceremoniously denied. In a series of emails, Al McGartland, Carlin’s boss, forbade him from having “any direct communication” with anyone outside of his office concerning his study. On March 16, Carlin tried again, but McGartland made clear what his superiors thought of the report: “The time for such discussion of fundamental issues has passed for this round. The administrator and the [Obama] administration have decided to move forward on endangerment, and your comments do not help the legal or policy case for this decision… I can only see one impact of your comments given where we are in the process, and that would be a very negative impact on our office.”
But that’s not all. McGartland also wrote to Carlin: “With the endangerment finding nearly final, you need to move on to other issues and subjects. I don’t want you to spend any additional EPA time on climate change. No papers, no research etc, at least until we see what EPA is going to do with Climate.” One wonders if this passes Jackson’s test to “remain open and accessible to all points of view.”
So just what did Carlin say in his report? The following is Carlin’s take on recent developments in the scientific literature, none of which received serious treatment in EPA’s proposed endangerment finding:
-“The draft endangerment TSD [Technical Support Document] is largely a dated document which relies heavily on the Fourth Assessment Report (AR4) of the U.N.’s Intergovernmental Panel on Climate Change (IPCC). A lot has happened in those intervening three years since then. The IPCC’s AR4 was published in the spring of 2007, but to meet the deadline for inclusion in the AR4, scientific papers had to be published by late 2005/early 2006. So, in the rapidly evolving field of climate change, by grounding its TSD in the IPCC AR4 the EPA is largely relying on scientific findings that are, by early 2009, largely 3 years or more out of date.”
-“Global temperatures have declined—extending the current run of time with a statistically robust lack of global temperature rise to eight years, with some people arguing that it can be traced back for 12 years.”
-“The consensus on past, present, and future Atlantic hurricane behavior has changed in our view. Initially, it tilted towards the idea that anthropogenic global warming is leading to (and will lead to) more frequent and intense storms. Now the consensus is much more neutral, arguing that future Atlantic tropical cyclones will be little different than those of the past.”
-“Trying to identify a statistically significant and robust human signal in the observed history of Atlantic basin tropical cyclones, whether over the past 100+ years, or in recent decades, is probably untenable. This conclusion is based on increases in hurricane activity in recent decades far exceeds that generally projected by climate models run with observed changes in anthropogenic emissions, and there is ample (and growing) evidence that the Atlantic hurricane record is characterized by multi-decadal oscillations that are tied to multi-decadal oscillations in ocean circulation, atmospheric circulations, and patters of sea surface temperature variability.”
-“The idea that warming temperatures will cause Greenland to rapidly shed its ice has been cast into doubt by new results indicating little evidence for the operation of such processes (e.g., van de Wal et al. 2008; Joughin et al. 2008).”
-“One of the worst economic recessions since World War II has greatly decreased GHG emissions compared to the assumptions made by the IPCC several years ago. To the extent that ambient GHG levels are relevant for future global temperatures and to the extent that this may be much more than a minor, short recession, these emissions reductions should greatly influence the adverse effects of these emissions on public health and welfare. The current draft TSP does not reflect the changes that have already occurred or those that are likely to occur in the future as a result of the recession, but it needs to. In fact, the topic is not even discussed to our knowledge.”
-“What all of this argues is that there is considerable doubt as to the validity of the IPCC GCM models because they do not correspond with observational data in a very important aspect. Since these models are the principal underpinning for the IPCC conclusions and therefore the Draft TSD it is vital that these doubts and uncertainties be carefully explained in the TSD so that readers understand these issues which directly affect the proposed finding of endangerment.”
-“The possibility that IPCC (2007) has erred in its attribution of most of the relatively recent global warming to GHG increased with the publication of Scafetta and Wilson (2009). This paper concludes that reconstruction of the [Total Solar Irradiance] used by the IPCC appears to have been seriously flawed. If this peer-reviewed analysis is correct, then the sun ‘could account for as much as 69% of the increase in the Earth’s average temperature, depending on the TSI reconstruction used’.”
-“Failure to consider these other [views] makes the draft TSD one-side and unscientific in its discussion since it basically pre-supposes the answer and the answer does not explain the observed fluctuations in global temperatures. Until the causes are clearly understood most any effort [to regulate greenhouse gases] is likely doomed to failure.”
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