The Director of the NCEE (division of the EPA) ordered a critical, if rushed, research report suppresed and the author has been told to “stop talking about it”. On June 27, 2009, Alan Carlin, the author of this hidden report made a copy available. A report which was initially requested by a department of the EPA (according to the title of the report) for the purpose of providing technical support and documentation analysing just how Greenhouse Gas Emissions endanger the atmosphere and how CO2 (from man made sources) promotes Global Warming

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The author(s) were only given 4 – 5 working days in which to prepare and submit the report, working long hours to prepare a thorough report and submit it on time, only to have the Director decide the day after it’s on-time submission, that it would not be forwarded. This decision effectively killed the report and ultimately killed any opportunity for the truths revealed in the report to ever see the “light of day”.

The report essentially tells the EPA that (Man Made) Anthropogenic Global Warming is being proven less and less likely by real science on an [almost] daily basis, and if they continue to recommend “solutions” to a non-existant crisis and legislation based on the erroneous data they have relied on to come to their faulty conclusions, that they are in grave danger of making egregious errors in those recommendations.

Translation: Global Warming (man made) is non-existant, CO2 is not a pollutant, and all the posturing, screaming “ENVIRONMENTAL CRISIS” and demading “solutions NOW” are fraudulent. The report was squashed because it reveals that there IS NO crisis which means there is no need for any “solutions” and certainly NO need whatsoever of the job-killing, economy destroying, corrupt Cap and Trade legislation.

But don’t take our word for it, read the report!

RightSideNews is making the entire document available, beginning with the authors June 27, 2009 comments, the Preface and the Executive Summary below, followed with a link to the rest of the document. In addition to our on-site publishing of the entire document, we are also including the original document site link, we are making it available in this manner because there have been instances of these sorts of documents being “scrubbed” from the internet. If the original site giving access to this document disappears, it will still be here on RightSideNews.

“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

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

PREFACE

I have become increasingly concerned that EPA has itself paid too little attention to the science of global warming. EPA and others have tended to accept the findings reached by outside groups, particularly the IPCC and the CCSP, as being correct without a careful and critical examination of their conclusions and documentation. If they should be found to be incorrect at a later date, however, and EPA is found not to have made a really careful independent review of them before reaching its decisions on endangerment, it appears likely that it is EPA rather than these other groups that may be blamed for any errors. Restricting the source of inputs into the process to these these two sources may make EPA’s current task easier but it may come with enormous costs later if they should result in policies that may not be scientifically supportable.

I do not maintain that I or anyone else have all the answers needed to take action now. Some of the conclusions reached in these comments may well be shown to be incorrect by future research. My conclusions do represent the best science in the sense of most closely corresponding to available observations that I currently know of, however, and are sufficiently at variance with those of the IPCC, CCSP, and the Draft TSD that I believe they support my increasing concern that EPA has not critically reviewed the findings by these other groups.

As discussed in these comments, I believe my 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 of endangerment from GHGs. I believe that this review should start immediately and be a continuing effort as long as there is a serious possibility that EPA may be called upon to implement regulations designed to reduce global warming. The science has and undoubtedly will continue to change and EPA must have the capability to keep abreast of these changes if it is to successfully discharge its responsibilities. The Draft TSD suggests to me that we do not yet have that capability or that we have not used what we have.

I would be happy to work with and assist anyone who might want to undertake such a serious review of the science and hope that these comments will at least illustrate the scope of what I believe is needed. I hope that the reader will excuse the many unintentional errors that are undoubtedly in these comments. My only excuse is that I had less than four days to draft these very lengthy and complex comments. It has not been possible to fully adhere to my usual very high standards of accuracy as a result. If there should be questions, I would be happy to try to correct any errors that anyone may find, however. It is of great importance that the Agency recognize the difference between an effort that has consumed tens of billions of dollars by the IPCC, the CCSP, and some additional European, particularly British, funding over a period of at least 15 years with what I have been able to pull together in less than a week. Obviously the number of peer reviewed papers that exist and the polish of the summary reports cannot be compared. What is actually noteworthy about this effort is not the relative apparent scientific shine of the two sides but rather the relative ease with which major holes have been found in the GHG/CO2/AGW argument. In many cases the most important arguments are based not on multi-million dollar research efforts but by simple observation of available data which has surprisingly received so little scrutiny. The best example of this is the MSU satellite data on global temperatures. Simple scrutiny of this data yields what to me are stunning observations. Yet this has received surprisingly little study or at least publicity. In the end it must be emphasized that the issue is not which side has spent the most money or published the most peer-reviewed papers, or been supported by more scientific organizations. The issue is rather whether the GHG/CO2/AGW hypothesis meets the ultimate scientific test-conformance with real world data. What these comments show is that it is this ultimate test that the hypothesis fails; this is why EPA needs to carefully reexamine the science behind global warming before proposing an endangerment finding. This will take more than four days but is the most important thing I can do right now and in the coming weeks and months and possibly even years.

EXECUTIVE SUMMARY

These comments are based on the draft Technical Support Document for Endangerment Analysis for Greenhouse Gas Emissions under the Clean Air Act (hereafter draft TSD) issued by the Climate Change Division of the Office of Atmospheric Programs on March 9, 2009. Unfortunately, because I was only given a few days to review this lengthy document these comments are of necessity much less comprehensive and polished than they would have been if more time had been allowed. I am prepared, however, to provide added information, more detailed comments on specific points raised, and any assistance in making changes if requested by OAR.

The principal comments are as follows:

As of the best information I currently have, the GHG/CO2 hypothesis as to the cause of global warming, which this Draft TSD supports, is currently an invalid hypothesis from a scientific viewpoint because it fails a number of critical comparisons with available observable data. Any one of these failings should be enough to invalidate the hypothesis; the breadth of these failings leaves no other possible conclusion based on current data. As Feynman (1975) has said failure to conform to real world data makes it necessary from a scientific viewpoint to revise the hypothesis or abandon it (see Section 2.1 for the exact quote). Unfortunately this has not happened in the global warming debate, but needs to if an accurate finding concerning endangerment is to be made. The failings are listed below in decreasing order of importance in my view:

1. Lack of observed upper tropospheric heating in the tropics (see Section 2.9 for a detailed discussion).

2. Lack of observed constant humidity levels, a very important assumption of all the IPCC models, as CO2levels have risen (see Section 1.7).

3. The most reliable sets of global temperature data we have, using satellite microwave sounding units, show no appreciable temperature increases during the critical period 1978-1997, just when the surface station data show a pronounced rise (see Section 2.4). Satellite data after 1998 is also inconsistent with the GHG/CO2/AGW hypothesis

4. The models used by the IPCC do not take into account or show the most important ocean oscillations which clearly do affect global temperatures, namely, the Pacific Decadal Oscillation, the Atlantic Multidecadal Oscillation, and the ENSO (Section 2.4). Leaving out any major potential causes for global warming from the analysis results in the likely misattribution of the effects of these oscillations to the GHGs/CO2 and hence is likely to overstate their importance as a cause for climate change.

5. The models and the IPCC ignored the possibility of indirect solar variability (Section 2.5), which if important would again be likely to have the effect of overstating the importance of GHGs/CO2.

6. The models and the IPCC ignored the possibility that there may be other significant natural effects on global temperatures that we do not yet understand (Section 2.4). This possibility invalidates their statements that one must assume anthropogenic sources in order to duplicate the temperature record. The 1998 spike in global temperatures is very difficult to explain in any other way (see Section 2.4).

7. Surface global temperature data may have been hopelessly corrupted by the urban heat island effect and other problems which may explain some portion of the warming that would otherwise be attributed to GHGs/CO2. In fact, the Draft TSD refers almost exclusively in Section 5 to surface rather than satellite data.

The current Draft TSD is based largely on the IPCC AR4 report, which is at best three years out of date in a rapidly changing field. There have been important developments in areas that deserve careful attention in this draft. The list includes the following six which are discussed in Section 1:

• Global temperatures have declined-extending the current downtrend to 11 years with a particularly rapid decline in 1907-8; in addition, the PDO went negative in September, 2007 and the AMO in January, 2009, respectively. At the same time atmospheric CO2 levels have continued to increase and CO2 emissions have accelerated.
• The consensus on past, present and future Atlantic hurricane behavior has changed. Initially, it tilted towards the idea that anthropogenic global warming is leading to (and will lead to) to more frequent and intense storms. Now the consensus is much more neutral, arguing that future Atlantic tropical cyclones will be little different that those of the past.
• The idea that warming temperatures will cause Greenland to rapidly shed its ice has been greatly diminished by new results indicating little evidence for the operation of such processes.

• One of the worst economic recessions since World War II has greatly decreased GHG emissions compared to the assumptions made by the IPCC. To the extent that ambient GHG levels are relevant for future global temperatures, 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 nor those that are likely to occur in the future as a result of the recession. In fact, the topic is not even discussed to my knowledge.
• A new 2009 paper finds that the crucial assumption in the GCM models used by the IPCC concerning strongly positive feedback from water vapor is not supported by empirical evidence and that the feedback is actually negative.
• A new 2009 paper by Scafetta and Wilson suggests that the IPCC used faulty solar data in dismissing the direct effect of solar variability on global temperatures. Other research by Scafetta and others suggests that solar variability could account for up to 68% of the increase in Earth’s global temperatures.

These six developments alone should greatly influence any assessment of “vulnerability, risk, and impacts” of climate change within the U.S., but are not discussed in the Draft TSD to my knowledge. But these are just a few of the new developments since 2006. Therefore, the extensive portions of the EPA’s Endangerment TSD which are based upon science from the IPPC AR4 report are no longer appropriate and need to be revised before a TSD is issued for comments.

Not only is some of the science of the TSD out-of-date but there needs to be an explicit, in-depth analysis of the likely causes of global warming in my view. Despite the complexity of the climate system the following conclusions in this regard appear to be well supported by the available data (see Section 2 below):

A. By far the best single explanation for global temperature fluctuations appears to be variations in the PDO/AMO/ENSO. ENSO appears to operate in a 3-5 year cycle. PDO/AMO appear to operate in about a 60-year cycle. This is not really explained in the draft TSD but needs to be, or, at the very least, there needs to be an explanation as to why OAR believes that these evident cycles do not exist or why they are so unimportant as not to receive in-depth analysis.

B. There appears to be a strong association between solar sunspots/irradiance and global temperature fluctuations. It is unclear exactly how this operates, but it may be through indirect solar variability on cloud formation. This topic is not really explored in the Draft TSD but needs to be since otherwise the effects of solar variations may be misattributed to the effects of changes in GHG levels.

C. Changes in GHG concentrations appear to have so little effect that it is difficult to find any effect in the satellite temperature record, which started in 1978.

D. The surface measurements (such as HADCRUT) are more ambiguous than the satellite measurements in that the increasing temperatures shown since the mid-1970s could either be due to the rapid growth of urbanization and the heat island effect or by the increase in GHG levels. However, since no such increase is shown in the satellite record it appears more likely that urbanization and the UHI effect and/or other measurement problems are the most likely cause. If so, the increases may have little to do with GHGs and everything to do with the rapid urbanization during the period. Given the discrepancy between surface temperature records in the 1940-75 and 1998-2008 and the increases in GHG levels during these periods it appears even more unlikely that GHGs have as much of an effect on measured surface temperatures as claimed. These points need to be very carefully and fully discussed in the draft TSD if it is be scientifically credible.

E. Hence it is not reasonable to conclude that there is any endangerment from changes in GHG levels based on the satellite record, since almost all the fluctuations appear to be due to natural causes and not human-caused pollution as defined by the Clean Air Act. The surface record is more equivocal but needs to be carefully discussed, which would require substantial revision of the Draft TSD.

F. There is a significant possibility that there are some other natural causes of global temperature fluctuations that we do not yet really understand and which may account for the very noticeable 1998 temperature peak which appears on both the satellite and surface temperature records. This possibility needs to be fully explained and discussed in the Draft TSD. Until and unless these and many other inconsistencies referenced in these comments are adequately explained it would appear premature to attribute all or even most of what warming has occurred to changes in GHG/CO2 atmospheric levels.

These inconsistencies between the TSD analysis and scientific observations are so important and sufficiently abstruse that in my view EPA needs to make an independent analysis of the science of global warming rather than adopting the conclusions of the IPCC and CCSP without much more careful and independent EPA staff review than is evidenced by the Draft TSP. Adopting the scientific conclusions of an outside group such as the IPCC or CCSP without thorough review by EPA is not in the EPA tradition anyway, and there seems to be little reason to change the tradition in this case. If their conclusions should be incorrect and EPA acts on them, it is EPA that will be blamed for inadequate research and understanding and reaching a possibly inaccurate determination of endangerment. Given the downward trend in temperatures since 1998 (which some think will continue until about 2030 given the 60 year cycle described in Section 2) there is no particular reason to rush into decisions based on a scientific hypothesis that does not appear to explain much of the available data.

Finally, there is an obvious logical problem posed by steadily increasing US health and welfare measures and the alleged endangerment of health and welfare discussed in this draft TSD during a period of rapid rise in at least CO2 ambient levels. This discontinuity either needs to be carefully explained in the draft TSD or the conclusions changed.