The EPA apparently doesn’t care about any negative comment of their GHG Endangerment findings, even internally, so the exercise in Democracy we did yesterday apparently was for naught.
“The time for such discussion of fundamental issues has passed for this round. The administrator and the administration has 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.”
– Internal EPA email, March 17th, 2009
The Competitive Enterprise Institute (CEI) has caught EPA administration red-handed in concealment of internal dissent as well as apparently proceeding with plans in advance.
From this PDF circulated today by CEI, here are the points:
EI is submitting a set of four EPA emails, dated March 12-17, 2009, which indicate that a significant internal critique of EPA’s position on Endangerment was essentially put under wraps and concealed. The study was barred from being circulated within EPA, it was never disclosed to the public, and it was not placed in the docket of this proceeding. The emails further show that the study was treated in this manner not because of any problem with its quality, but for political reasons.
CEI hereby requests that EPA make this study public, place it into the docket, and either extend or reopen the comment period to allow public response to this new study. We also request that EPA publicly declare that it will engage in no reprisals against the author of the study, who has worked at EPA for over 35 years.
The emails, attached hereto, consist of the following:
1) a March 12 email from Al McGartland, Office Director of EPA’s National Center for Environmental Economics (NCEE), to Alan Carlin, Senior Operations Research Analyst at NCEE, forbidding him from speaking to anyone outside NCEE on endangerment issues;
2) a March 16 email from Mr. Carlin to another NCEE economist, with a cc to Mr. McGartland and two other NCEE staffers, requesting that his study be forwarded to EPA’s Office of Air and Radiation, which directs EPA’s climate change program. The email notes the quantity of peer-reviewed references in the study, and defends its inclusion of new research as well. It states Mr. Carlin’s view that “the critical attribute of good science is its correspondence to observable data rather than where it appears in
the technical literature.” It goes on to point out that the new studies “explain much of the observational data that have been collected which cannot be explained by the IPCC models.” (Emphases added);
3) a March 17 email from Mr. McGartland to Mr. Carlin, stating that he will not forward Mr. Carlin’s study. “The time for such discussion of fundamental issues has passed for this round. The administrator and the administration has 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.” (Emphasis added);
4) a second March 17 email from Mr. McGartland to Mr. Carlin, dated eight minutes later, stating “ I don’t want you to spend any additional EPA time on climate change.”
Mr. McGartland’s emails demonstrate that he was rejecting Mr. Carlin’s study because its conclusions ran counter to EPA’s proposed position. This raises several major issues.
A. Incompleteness of the Rulemaking Record: The end result of withholding Mr. Carlin’s study was to taint the Endangerment Proceeding by denying the public access to important agency information. Court rulings have made it abundantly clear that a rulemaking record should include both “the evidence relied upon [by the agency] and the evidence discarded.” Ethyl Corp. v. EPA, 541 F.2d 1, 36 (D.C. Cir. 1976), cert. denied, 426 U.S. 941 (1976).
B. Prejudgment of the Outcome of the Endangerment Proceeding: The emails also suggest that EPA has prejudged the outcome of this proceeding, to the point where it arguably cannot be trusted to fairly evaluate the record before it. Courts have recognized “the danger that an agency, having reached a particular result, may become so committed to that result as to resist engaging in any genuine reconsideration of the issues.” Food Marketing Institute v. ICC, 587 F.2d 1285, 1290 (D.C. Cir. 1978).
C. Violations of EPA’s Commitment to Transparency and Scientific Honesty: Finally, the emails suggest that EPA’s extensive pronouncements about transparency and scientific honesty may just be rhetoric. Shortly before assuming office, EPA Administrator Lisa Jackson declared: “As Administrator, I will ensure EPA’s efforts to address the environmental crises of today are rooted in three fundamental values: science-based policies and programs, adherence to the rule of law, and overwhelming transparency.” Jan. 23, 2009, link. See also Administrator Jackson’s April 23 Memo to EPA Employees, “Transparency in EPA’s Operations”. These follow the President’s own January 21 memo to agency heads on “Transparency and Open Government”. And in an April 27 speech to the National Academy of Sciences, the President declared that, “under my administration, the days of science taking a back seat to ideology are over.”
Because of ideology, however, it was this back seat to which Mr. Carlin’s study was relegated; more precisely, it was booted out of the car entirely.
For these reasons, we submit that EPA should immediately make Mr. Carlin’s study public by entering it into the Endangerment docket, and that it should either extend or reopen the comment period in this proceeding to allow public responses to that study. It should do so, moreover, while publicly pledging that Mr. Carlin will suffer no adverse repercussions from agency personnel. Mr. Carlin is guilty of no wrongdoing, but the tenor of the emails described above suggests he may well have reason to fear reprisals.
Read the EPA internal emails, including photographs of the originals here.
Call your congressional representative. This is legally wrong and makes a mockery of the public comment process.
Tell them here: 202-224-3121.
I tried to do my part today by calling my Congressman About the Waxman-Markey energy bill, but doubt it will slow down the steamroller. The people in our government are obviously lying to us about a number of issues, for political reasons. It’s too bad more evidence about this kind of chicanery is not revealed for the public to see. This is not the kind of “transparency” that the public thought they were buying. Even a technical society, the American Chemical Society’s publication, “Chemical & Engineering News” has come out with an editorial referring to us skeptics as “CCD’s”, meaning “climate change deniers” in a sarcastic attempt to link us with those who deny the Holocaust. I have always believed that truth will triumph eventually, but we may have to suffer a great deal before it does!
I have just called my congressman’s office. The intern I spoke with didn’t have a clue, said no one in the office is aware of any of the climate change issues, other than the congressman will be voting on Friday, (probably for the bill–he’s a Democrat), but he hasn’t read the bill and neither had anyone in the office.
They know nothing about the EPA rulemaking, either. I told him it was a criminal act to suppress pertinent information in the rulemaking. I just got another clueless answer.
All I can say is keep calling, keep pestering, make them pay some attention.
Call me a nutcase but I think most of these democrats (and some republicans) are working for global interests instead of national interests. I base this on many of the AGW documents I’ve read from various prestigious left wing think tanks and NGO’s and from various UN websites.
From what I’ve read, I get the strong impression that the end goals are “unprecedented” transfers of wealth to developing nations as well as technology that US taxpayers will paying for. The current phrase I’m coming across is “contraction and convergence” where the “contraction” is the lowering of CO2 emissions (and with it to a degree, the economy), and the “convergence” is the per-capita GDP and incomes of the worlds nations coming together (or equalizing). “Convergence” also refers to income coming together [i]within[/i] nations.
I think EPA is going to have some trouble over this. My recollection is that the EPA rulemaking is not based on its own research or evaluation of the scientifc literature, but instead is based only on the IPCC and CCSP reports. It doesn’t look like CEI got a hold of the actual document that Alan Carlin prepared, but based on the e-mails it probably contained a discussion of various scientific papers and studies that conflicted with the findings of those two reports, and that the author thought should be made a part of the record. It also seems to indicate that someone in the EPA wanted to independently form their own conclusions about the weight of the scientific literature as to endangerment, but that higher-management torpedoed that idea.
One of the issues the EPA invited comment on was whether or not it was appropriate for them to promulgate rules based exclusively on findings and research of other entities, e.g. the IPCC. The reason this e-mail exchange is so damaging is that it at least appears to show that EPA was made aware of scientific research that conflicted with those reports and which were either (1) not available to the IPCC and CCSP; (2) not considered by those report; or (3) both.
The EPA began this exercise on the assumption that the IPCC essentially did all their work for them, and that they could use someone else’s conclusions as a rational basis for an endangerment finding, without going through the time-consuming process of conducting its own review of the credibility of the scientific literature. Even setting aside the question of pre-judgment, which the CEI is stressing, the fact that the EPA shunted this document aside highlights the fact that the EPA has in essence abdicated to other agencies (one of which isn’t even a US agency) its own responsibility to determine the factual issue of endangerment. What it wants is not only to rely upon the compilation of scientific data from the IPCC but also rely upon the conclusions of the IPCC (e.g. 98% confidence that most of the temperature increase in recent decades is from CO2) so that EPA doesn’t have to go through and evaluate all the scientific literature referenced by the IPCC report, which would take years.
In my opinion, even were the EPA to do what the CEI asks, e.g. extend the public comment and add the document to the administrative record, they nonetheless have handed a stockpile of ammo to anyone who wants to challenge the finding in court on the basis that the EPA cannot avoid its own responsibility to both collect its own scientific record and make its own independent judgments as to the weight of that record. In other words, the conclusions the IPCC drew from its own review of the scientific literature is not a factaal basis from which the EPA can support an endangerment finding.
And here’s another thought. Maybe the reason the Obama Administration has been low-key in its support of Waxman-Markey is that they knew they had this EPA process waiting in the wings. They’d let Congressional Dems muck it all up, then spring EPA’s ruling and before we know it we’ll have Enron II and Al Gore rolling in the dough.
“I tried to do my part today by calling my Congressman About the Waxman-Markey energy bill, but doubt it will slow down the steamroller. ” – Retired BChe.
“I don’t believe in the no-win scenario.” – James T. Kirk, Admiral Star Fleet United Federation of Planets.
Retired BChe (14:49:15) :
I noticed the same editorial. Of course the staff of CE&N and ACS in general are so “inside the beltway” that they’ve completely lost touch with most of their non-academic clientele. Add to that the fact that most of the CE&N never got over not getting that dream job with the Washington Post, and we’ve got just a classic case of people opining using other people’s money.
But I did think of sending a letter refering to “anthropogenic global warming alarmists (AGWAs)”, but it turned out the idea had already been taken.
http://antigreen.blogspot.com/2008/01/global-warming-skeptics-compared-to.html
Pity, there’s a perfect picture of an AGWA here.
http://tl.pandapedia.com/wiki/Agwas
Another example of how the EPA does not represent sound scientific achievement or the good of mankind. Our progress cannot continue if science is suppressed in favor of Big Oil interests to defraud the consumer. See altfuels.us for other expamples of EPA tactics.
Tom Fuller (14:33:32) : “Anthony, I contacted EPA and received a very quick and (I think) fairly open response. Apparently CEI may have exaggerated hugely. EPA emailed this statement to me:”
What reason do you have for believing the “mouthpiece” of an agency that is accused of being up to dirty tricks? This person was just passing on a canned response. See comments above by imapopulist (13:48:35) :
Ummm… Carlin is an economist with EPA, not a scientist.
His CV lists exactly zero publications in meteorology, atmospheric physics… or any scientific field whatsoever.
While he is certainly qualified to comment on things like costs vs benefits of regulating CO2, he has absolutely no qualifications to be commenting on the underlying science (which is what he appears to have done).
KW (14:45:44) :
“I do wonder…are the comments only for the sake of humoring people’s opinions?”
Acting like as if they care!!!
It is coming clear that we will neverdo away with CO2 output. Output from farm equipment and automotive will be bad and output from pets and democrats will be good. CO2 out put will be graded regarding it’s source. CO2 produced in building rail is clean but for building a nuclear plant is dirty. 572 pounds of paper for my annual NYT subscription is good. 572 lbs of firewood for my cabin is dirty.
Before we get too excited re this apparent “suppression” of Mr. Carlin’s paper, be advised that Mr. Carlin is STRONGLY in the AGW camp. His 2007 paper “Risky Gamble” talks about the difficulties of adopting a single approach to reducing GHG and strongly encourages looking at Geoengineering to effect Solar Radiation Management. [ ERD=Exclusive Regulatory DeCarbonization or Cap and Trade]:
“Risky Gamble
Reducing emissions of greenhouse gases may be well intentioned and even
helpful. But as the sole strategy for climate change control it is nevertheless
inflexible, expensive, risky, and politically unrealistic, according to this government economist. Such a strategy could even make matters worse.
Fortunately, there is a better solution.
ALAN CARLIN
{Here it is }
“…Fortunately, there is an alternative to relying on ERD, although it is almost never mentioned by environmentalists and not widely known, much less understood, by the public — solar radiation management, sometimes called stratospheric geoengineering or engineered climate selection. An extensive review of management strategies and currently available alternative technologies for global climate control gives the inescapable conclusion that SRM is the most effective and efficient first step toward solving most of the problems that ERD supporters are concerned about, quickly and easily………
So it is likely that his contribution may include a paper on SRM which does not fit the current thrust of the Gore/Obama/Goldman Sachs coalition.
[The above title and quote are taken from the Carlin website:
http://carlineconomics.googlepages.com/
Chris V. (15:17:13) : It’s very easy to be considered a legitimate scientist among the global warming crowd. No education or diploma required. All one has to do is to proclaim that CO2 is causing the earth to warm and unless the people surrender all their money and freedom to the government, everyone will die. Voila! You are now considered a legitimate scientist worthy of quotation in every media outlet worldwide.
That did not take too long for someone to write an article to try to debunk the emails and memo… http://www.grist.org/article/2009-06-24-scant-evidence-of-suppression/
Looks like the story is being burried in the Google News search. Just an hour ago you could find it by only putting in EPA… but now you have to be much more specific to find it.
NOTE: This could be a repost… the original did not appear!
That did not take too long for someone to write an article to try to debunk the emails and memo… http://www.grist.org/article/2009-06-24-scant-evidence-of-suppression/
Looks like the story is being burried in the Google News search. Just an hour ago you could find it by only putting in EPA… but now you have to be much more specific to find it.
The true revolutionary will never waiver. If the evidence disagrees with the movement, they will change the evidence, not the policy.
NOAA, IPCC and now EPA – it is a sign of our times that I trust Vince, the Sham Wow guy, more than I trust the preeminent scientists who guard our truth.
This is Ruckelshaus and DDT re-visited: to hell with science, facts, and the recommendations of one’s staff.
For all the good it will do I did contact my representative who is about as far left as it is possible to be.
Those above who have noted that this is just one more example of the demise of our republic are correct.
I wish I could feign surprise at this news. I live in the UK though, so I just can’t. One hope for those of you in the US is that you get to have a say in the first place and that eventually this story could end up decided in a public Court.
Over here (UK) we have had to watch this same corrupt process from the side lines, no voice, no recourse and no rules of engagement. Ministers here spout the party line and quietly hand out the Carbon Candy. They hand it to friends on the Carbon “advisory” board and “donors” from the “Carbon Market”. Only when people eventually see the scam for what it is will there be a reaction.
How exactly did we get from six tenths of a degree “statistical discrepancy” over one hundred years to creating a “fresh air market” worth several Trillion dollars a year worldwide to those in the loop? I’m not one for “tinfoil hats” but I am certainly recommending “aluminium hair nets” to anybody that wants one.
What exactly do the people involving themselves in this scam, without actually profiting, think is going to happen when the general population wake up both to the scale of the robbery and the real statistics relating to hypothermia deaths in the North?
UHI statistical tenths of a degree combined with Hansen Amplifying Pivot Mathematics, 2D energy transfer equations in a theoretical environment, Mannomatic hockey stick climate history re-writes, GC models that fail every test, no place on Earth left for warming to hide and the ever changing goal posts – AGW has been dead in the SST ocean for some time now.
In the US you have boiling Tar and Feathers. Here in the UK we have scaffold erected in front of The Banqueting House. I have said it before and I mean it – I will throw Guardian readers on the fire before I freeze to death quietly in my old age. I would ask all those that tow the “we might as well go with the flow” line to think long and hard about what they are getting themselves involved in.
AGW induced climate catastrophe has long been a religious fantasy not a scientific hypothesis, profit from it at your peril. You cannot steal the lives of a huge number of people together with trillions of dollars in “tax” without there being a day of reckoning.
Jim Papsdorf (15:28:35) :
it seems that Sam Kazman, the Competitive Enterprise Institute’s general counsel, said Carlin’s work cites research showing global warming has been caused by ocean and solar cycles, not by human-caused emissions. Kazman refused to share the document.
see: http://www.grist.org/article/2009-06-24-scant-evidence-of-suppression/
The sad thing is that I expected this from the people who surround Obama; however, I did not expect them to get caught like this. But it’s not just him either of course. There is blame enough for all in the government who cannot resist, or who can find a way to justify, grabbing power over ordinary Americans’ lives in the name of public safety. He is just a mouth piece and that’s it.
But I’m just waiting for the government to come up with this:
http://en.wikipedia.org/wiki/Committee_of_Public_Safety
The link to The Examiner article points to the EPA countering by saying it was open and previously published and etcetera. Spin at full revs; but the headline is out there; that will be difficult to erase.
Also, it doesn’t address the most damning part, the actual content of the e-mails which clearly indicate that the ruling on endangerment had already been decided months ago and that his input was “not helping”, therefore it had been canned. Now, go work on something else, stupid. Clearly, also, the puiblic input would be ignored for the previously decided outcome.
“Chris V. (15:17:13) :
Ummm… Carlin is an economist with EPA, not a scientist.
His CV lists exactly zero publications in meteorology, atmospheric physics… or any scientific field whatsoever.
While he is certainly qualified to comment on things like costs vs benefits of regulating CO2, he has absolutely no qualifications to be commenting on the underlying science (which is what he appears to have done).”
Be careful about this. First, for all we know, he was submitting research on the economic projections that computer models use to project future emissions, hence future climate. Economic studies were also used in the IPCC report to assess damage caused by climate change. Many of the lead authors of the IPCC report are mathemeticians or modelers as opposed to scientists, yet their word is treated as gospel.
Economists can be very intelligent people. I’d hesitate before claiming that an econmist isn’t qualified to understand research papers involving matehmatical models, or even qualified to understand or comment on say, radiative transfer.
More importantly, the e-mail exchange seems to indicate that whatever he was proposing to submit with respect to the endangerment finding could have been forwarded on, but wasn’t because a decision had been made to go forward, even though the deadline hadn’t yet passed. I’m assuming that this deadline was for the EPA’s preliminary finding of endangerment which in turn triggered the public comment period.
One very interesting part of the e-mail exchange was at the end when Carlin was told that the endangerment finding was not a “criteria document” and hence his comments weren’t relevant at that stage of the process. This refers to “criteria pollutants” for which the EPA sets concentration limits for air pollution, e.g. ozone, particulates, etc. As part of the Clean Air Act requirements, EPA must periodically assess the current state of scientific data on what concentrations of criteria pollutants are hazardous. I take this exchange as indicating that the EPA is basing its endangerment findings solely on the conclusions of the IPCC and other selective reports of other agencies (see my post above), but this guy Carlin has presented data that was more recent than the respective cut-off dates for scientific papers to be sumbitted prior to writing those reports. The e-mails seem to suggest that the EPA is taking the position that they are under no obligation to consider current scientific data before making an endangerment finding based on the IPCC report.
Just as a follow-up to my last post, apparently Carlin has a degree in Physics and a Masters in Economics. By education, anyway, he appears at least as qualified as mant who write the IPCC report.
When Hansen claimed to have been “muzzled” by the Bush administration, all the news media trumpeted the allegation and most treated it as true. Will Alan Carlin’s obvious “muzzling” be noticed in any of the major news media? The left is already claiming there is nothing to it:
http://www.grist.org/article/2009-06-24-scant-evidence-of-suppression/
That’s the only “hit” by Google news for “Alan Carlin EPA” right now.
kurt (15:06:00) :
It also indicates that at least one person in the EPA is not on The Team.
I am sure the internal witch hunt is on!