On June 25th the Competitive Enterprise Institute (CEI) released a draft copy of the suppressed EPA report by EPA employee Alan Carlin critical of the EPA’s position on Carbon Dioxide saying:
The released report is a draft version, prepared under EPA’s unusually short internal review schedule, and thus may contain inaccuracies which were corrected in the final report.
While we hoped that EPA would release the final report, we’re tired of waiting for this agency to become transparent, even though its Administrator has been talking transparency since she took office. So we are releasing a draft version of the report ourselves, today,” said CEI General Counsel Sam Kazman.
CEI notes that: Internal EPA email messages, released by CEI earlier in the week, indicate that the report was kept under wraps and its author silenced because of pressure to support the Administration’s agenda of regulating carbon dioxide.
I’m pleased to say that we have the final report exclusively available here, courtesy of our verified contact at the EPA, who shall remain anonymous. For some background on this contact, developed with the help of Tom Fuller at the San Francisco Environmental Policy Examiner, please read the WUWT story below. The download link is also below.
Source inside EPA confirms claims of science being ignored, suppressed, by top EPA management
The title page of the final report from Alan Carlin of the EPA reads:
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
Alan prepared an update to this document which is on page 3, I’m reproducing it here for our readers:
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
UPDATE: Before downloading, please read the paragraph above from Alan Carlin to get some perspective. Certainly, this document is not perfect. How could it be? The EPA gave an internal comment period of 1 week on the most far reaching “finding” the agency has ever dealt with. This short window was unprecedented. So ask yourself, could you produce a paper like this, covering many disciplines outside of your own, that is “perfect” on 5 working days notice?
The EPA’s procedure here is the culprit.
Download the final report from Alan Carlin here, link: Endangerment comments v7b1 (PDF 4MB)
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Leif Svalgaard (00:15:46) :
The issue is that the time for comments internally was a week or less, not nearly enough time for a fully fact checked commentary, and this was apparently the only rebuttal. EPA ran turbo mode on this with no cares. Look at the bigger picture, not the details. – Anthony
If you don’t have time to get the details right, the proper thing is to omit the details.
Mike D. (01:30:00) :
PS to Leif: so you don’t concur on each and every point in the hastily written, suppressed report?
Haste is waste. Omitting the wrong details would have given the author a bit more time to concentrate on his central message.
REPLY: You’re assuming he knew it was wrong. As a solar physics expert, you know immediately what the status is of several datasets that you deal with. 99.99999% of the rest of the world does not. Haste makes waste. I agree with that, but Leif I strongly disagree with you here on your criticism because the EPA forced a comments window that was abnormally small for arguably the most far reaching “finding” they would ever deal with. The haste is the fault of the EPA and the unreasonable policy.
The EPA is the culprit here. – Anthony
Thank you Alan Carlin and Anthony for making this document public. It is not surprising that the EPA under Lisa Jackson chose to continue their findings that CO2 is a pollutant. With Chicago politics and now U.S. politics it is not about right or wrong but who is in charge.
Love this excerpt from “The Hill” article quoted above:
“Further, officials with the House GOP’s campaign arm, the National
Republican Congressional Committee, confirm that they will run with
paid media over recess in districts of conservative Dems who voted
for the bill. The official would not reveal details on the ad buys at
this time.”
The Republicans are going to hit hard on it. I think they smell blood.
Then this quote:
One Democrat was upset that his leaders would needlessly force
vulnerable Dems to vote for a bill that will come back to haunt
them. Mississippi Rep. Gene Taylor (D) voted against the measure
that he says will die in the Senate.
Smokey (04:40:30) :
17th amendment disconnected Senators from the entity of their home State. That essentially made them no different than a member of Congress and has allowed them to go hob nob for themselves with too limited repercussions from their home state voters as long as they deliver the pork and carbon allowances will be the new pork.
Because we have the 17th amendment we need to counter it with term limits on Senators.
Re: Comments on TSD – March 2009
Well. It may have been a rushed job to publish. And it took a couple of hours of my Sunday to read. But it was certainly worth the effort. And how frustrating to have it buried when it could do so much good.
Thanks for getting this out into the public arena.
TJ
Leif Svalgaard (07:24:24) :
Many of the criticisms are real, all that this rebuttal asked for was a further investigation. I think some space can be given for some of the details being inaccurate since the request is for greater accuracy.
This whole incident has just about turned me into an AGW denier. All the politics I’ve brought up over and over came right out in broad daylight with hardly a squeak from the scientific community. There is nothing but exaggerations and over-conclusions in this report.
The only thing preventing me from being a denier at this point is I don’t believe anyone knows the truth.
Leif Svalgaard (07:24:24) :
REPLY: You’re assuming he knew it was wrong. […]
The EPA is the culprit here. – Anthony
1st: I agree that the EPA is the culprit.
2nd: I’m not assuming he knew it was wrong. He almost certainly believes it is correct as he is a man of integrity.
3rd: The issue is a wider one. If I see some report or paper that makes, say, ten claims and, say, only one of them happens to be about something I know something about, the rest being completely outside. And if then the one I do know something about turns out to be wrong, that gives me a bad feeling about the rest. How do I know that they are right when the one I know about is wrong? Perhaps it is so that that wrong one was the only wrong one, but how is one to know?
4th: Although the window was very small, the author’s knowledge about the matter was presumably not acquired only during that window [if it was, I could rightfully dismiss it], but during a long period of time, so it is during that long period of time the wrong detail was acquired, so the short window is not an issue. The window would explain why there were two Figures with the same number 2.15, which is certainly excusable and understandable.
REPLY: Good points. I’ll add that it wasn’t until interaction with you that I learned that certain things that I thought I knew to be true (after months of looking at them) were not as I’d been led to believe by my own research. Unfortunately, almost every scientist that writes a study believes he/she to be “right”. The good ones leave a lot of room for correction.
Unfortunately it is tough to gauge what is correct and what is not solely by yourself, when you are a spectator to the discipline. Unfortunately in this hurried world, and the surreal hurried world of the EPA, time for determining the real merit of each piece of information you gather is short. – Anthony
The author makes a very important point concerning health. What are the observed negative health consequences of rising CO2? We’ve recorded generations of coincident CO2 rise and increasing world health. The IPCC needs to delete any content related to human health consequences unless they can explain the data.
Jeff Id (08:00:53) :
Many of the criticisms are real, all that this rebuttal asked for was a further investigation. I think some space can be given for some of the details being inaccurate since the request is for greater accuracy.
Perhaps everybody here misunderstand what I, perhaps too clumsily, was trying to say. So let me clarify: A document like this will be attacked. Wrong details are great attack points and serve as straw men that can be nitpicked over in order to gloss over the real message, so weaken the document. It is, of course, too late to do anything about it, but it may serve as a lesson to get the details right next time or in general when one is debating a strong ‘team’ or a powerful bureaucracy or administration. We need more such documents, but let’s get the details right EVERY TIME.
REPLY: Well said Leif, unfortunately all that can be done after the fact when imperfections are made into straw men is to point out that the EPA process itself created the imperfections by the unreasonably (and unheard of) short period for internal comments. By making it so short, many thorough scientists like yourself probably said to themselves “no way I can produce a quality document in that short space of time” so they didn’t try…which is the point. The EPA didn’t want well researched internal comments, they wanted to get the finding out the door.
This is why the flawed process calls for a “do-over”. – Anthony
Of course, a climate that stabilised at 6-7 degrees higher would be a catastrophe for most life until a few million years had gone by to allow it to adapt. Things would get very sticky for all of us in the meantime… – Nick Palmer
Helsinki Finland annual average temp 4.1°C
Shanghai China annual average temp 15.4°C
Seem there’s a lot of room for temperature variability without “catastrophe.”
CBS News picked up the story, in their political hotsheet blog:
http://www.cbsnews.com/blogs/2009/06/26/politics/politicalhotsheet/entry5117890.shtml
I’ve been having a lot of fun over there in the comments section…
Still only 31 articles listed by Google News, CBS & NYT are the only majors.
http://news.google.com/news?ned=us&hl=en&q=epa+suppressed+report
Jeff Id (08:00:53) :
” The only thing preventing me from being a denier at this point is I don’t believe anyone knows the truth.”
Exactly that is the point. “Skeptic” are in search of the Truth AGW believers are dead set on accepting one errant explanation = CO2 man made. I think they have a compelling theory, but for some reason it does not stand up to empiracal Scientific testing (unless you count models as ‘Emprical’ Science. Computer models are helpful, but not all/100% inclusive of all natural processes. So that leaves me with a big ? = Skeptic. This site just so happens to feed my desire to know more. AGW sites (the ones I have visited) only tell me I have to do this and do that because it is real and I am at fault. I will only do something if I want to do it not because somebody tells me to do it. That is why I am against this Cap and Tax bill, as well as the National Healthcare bill. I have also urged my State to not accept the stimulus payments, they did it any way, because we (the people) would owe the Federal Government with interest. The Fed’s have gotten to big and powerful to even care about what it’s citizens want.
Sorry I got off topic, but that is the way I feel.
Nick Palmer:
“It wasn’t so good for ocean life because of the increased acidification, but that’s another matter.”
Do you have any references for that? It certainly isn’t the way I read the fossil record.
This deal where the GCMs *assume* that RH is constant with temperature. It seems ridiculous to me. Why even bother running a GCM? The radiative warming attributable to CO2 is instantly magnified by an *assumed* constituitive relation that exponentially increases water vapor in the stratosphere? Are you effing kidding me?
From an e-mail I’m sending on global warming (no doubt fruitlessly) to an Obama administration official:
With its view that “the science is settled” the administration risks appearing less informed than a fairly intelligent and curious individual who can browse the Internet. Certainly other countries with whom we will be dealing on this issue will not be ideologically blinkered in what evidence they will consider in forming policy.
The Obama administration is a step away from holding a position reminiscent of Lysenkoism on anthropogenic global warming. (Lysenko, as you know, was the Soviet “biologist” under Stalin whose views on the inheritance of acquired characteristics achieved state sponsorship and set back Soviet biology and agriculture for a generation). The administration is clinging to its position in the face of increasing scientific evidence to the contrary which it won’t consider and despite evidence from their own senses that temperatures have been steady/dropping over the past decade.
The process is corrupt. – Anthony
————————————
Anthony, a concise description of the administrative and legislative Federal government of the United States of America.
smallz79 (08:24:10) :
Exactly that is the point. “Skeptic” are in search of the Truth
“A philosophical skeptic does not claim that truth is impossible (which would be a truth claim). The label is commonly used to describe other philosophies which appear similar to philosophical skepticism, such as “academic” skepticism, an ancient variant of Platonism that claimed knowledge of truth was impossible.”
So a skeptic believes that one cannot know the truth. In more ordinary usage skepticism is the doctrine that true knowledge or knowledge in a particular area is uncertain. So there is not much to search for. Perhaps the word ‘skeptic’ is not good for characterizing your position. It looks to me more like a label for disbelieving somebody else’s opinion or theory.
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As noted above by Michael D. Smith, CBS News has now picked up the story. Following the link in Michael’s post and reading the whole thing highly recommended.
And even if CBS + NYT are the only majors SO FAR, the fact that 2 majors have started to cover it; together with the cover-up being mentioned on the floor during debate on 2454; AND with the outstanding work to get the story out by WUWT:
Makes me hopeful that critical mass may have been reached, and the EPA will not be able to sweep this story under the rug (as they already appear desperately trying to do). If nothing else what has come out should weigh heavily in what I expect will be an inevitable court challenge to this absurd endangerment finding.
Curiousgeorge (06:12:21) :
The EPA/Carlin story also appeared on CNET yesterday: http://news.cnet.com/8301-13578_3-10274412-38.html , so it is getting around.
Recognition should be made of the few MSM reporters who are running with this story. The CNET article is from CBSnews.com Chief Political Correspondent Declan McCullagh. CBS so far is the only major network organization that has carried this story – though the NY Times’ Greenwire, Robin Bravender wrote the “Two EPA Staffers Question Science Behind Climate ‘Endangerment’ Proposal” story on Thursday 26, June.
You can thank Declan at delcan@cbsnews.com, and Greenwire Editor, Kevin Braun at kbraun@eenews.com, or Robin at rbravender@eenews.com
It’s helpful to let these writers know that their work is being read and appreciated by this dedicated community. Writing the whole truth about these issues has its rewards for MSM – massive new readership.
Tom Fuller,
Your San Francisco Examiner out-did itself by publishing your investigation. I was not alone in being surprised by your candor. Great work!
Your questions are on the right track, but deserve the benefit of broader inquiry. I suggest that you attempt to acquire Ian Plimer’s new book: Heaven+Earth, Global Warming: the missing science. It’s new, already in its 6th printing. It’s published in Australia by ConnorCourt Publishing. It’s 493 pages with 2311 footnotes. That said, you only have to read the 29 page introduction (33 footnotes) to understand the breadth and nature of the inquiry you seek.
He notes that there is no single scientific discipline that defines climate. Here are some relevant quotes:
“Studies of the earth’s atmosphere tell us nothing about future climate. An understanding of climate requires an amalgamation of astronomy, solar physics, geology, geochronology, geochemistry, sedimentology, tectonics, paleontology, paleoecology, glaciology, climatology, meteorology, oceanography, ecology, archaeology and history. This is what is attempted in this book.”
He also notes…”Data collection in science is derived from observation, measurement and experiment, not from modeling.” This is a direct reference to the sole reliance of IPCC on modeling. “Observations in nature differ markedly from the results generated by nearly two dozen climate models. These climate models exaggerate the effects of human CO2 emissions into the atmosphere because few of the natural variables are considered.”
You get the drift. It’s an enjoyable and informative read.
Keep asking questions.
The EPA didn’t want well researched internal comments, they wanted to get the finding out the door.
And they covered up internal dissent to get it done. Same procedure as RC and Open Mind.
My favorite quote from Mythbusters- Adam
“I reject your reality and substitute my own.”
Tom Fuller (23:45:22) :
Thanks for your courageous coverage of what I’m sure has been an eye-opening experience. I can imagine the discourse at RC must have left you drained.
From your point 3, it’s obvious you’ve looked at some recent info. There’s and interesting post over at Jennifer Marohasy’s site, a guest post from Michael Hammer. If you haven’t seen it, it’s worth the look. Bottom line: the NOAA “adjustments” account almost entirely for the reported temperature rise over the last several decades. In addition to eliminating a UHI adjustment, he points out that siting changes from urban to non-urban locations in effect builds in a positive UHI positive forever!
http://jennifermarohasy.com/blog/2009/06/how-the-us-temperature-record-is-adjusted/
On your comments on sensitivity, you write “The IPCC calculation of 1.5 to 4.5 with a ‘preference’ (help with phrasing?) of 3.5 may be too high”. I’d suggest inserting the word sensitivity for clarity.
Great work! It’s great having someone in the media asking tough questions. My experience is that you don’t really get answers, only circular arguments, dismissal, hostility, appeals to authority or all of the above.
Jack Green, wasting money is now seen as a patriotic duty 🙂
This story and WUWT is also mentioned in Investor’s Business Daily. http://www.ibdeditorials.com/IBDArticles.aspx?id=330911757213432