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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I strongly disagree with Leif Svalgaard.
This was an internal report that was shot down before it could work through normal editing cycles. As far as I know, we don’t know who leaked the report and I have to assume the authors weren’t ready to make the report public.
We have to take it as an incomplete report that was assembled quickly due to the constraints imposed by the EPA. You don’t know what this report would have looked like if the authors were given more time.
In the mind of most people, the entire climate science field is riding on a single theory, AGW. If that is false, then the field will implode. I give the field 10 years. Temperatures continue to rise, then the field is ok, if they drop, then the field implodes, and funding dries up.
I am just hoping if the climate science field implodes, it limits the damage to itself and not start an anti-science movement.
Jeff Id (14:59:03) :
I’m with you on that Jeff.
But then I just want results.
“Lucy Skywalker (14:50:34) :
Once again the material appearing here leaves me with the strong impression that the skeptics community needs and owes itself a skeptics climate science wiki, written and edited by all interested and proven skeptics/realists. This would be an immaculately sourced resource that Carlin could have simply copied wholesale.
I would like to see this happen also, but,
is there a safeguard in Wiki to protect such a entry from being butchered beyond recognition by William Connolley?
Just Want Results… (15:12:42) :
“Lucy Skywalker (14:50:34) : Once again the material appearing here leaves me with the strong impression that the skeptics community needs and owes itself a skeptics climate science wiki, written and edited by all interested and proven skeptics/realists. This would be an immaculately sourced resource that Carlin could have simply copied wholesale.
I would like to see this happen also, but, is there a safeguard in Wiki to protect such a entry from being butchered beyond recognition by William Connolley?
Of course this is the most important question. AFAIK all wiki formats can be configured as to who has rights to (a) contribute to the front page articles and (b) add comments on the comments pages. One idea: (a) start with a good “seed” material like the David Evans mentioned above (b) only allow editors of a capacity known and approved in the skeptics’ community (then we need to work out how to do that) (c) allow a wider selection of people to comment (as in the Wikipedia wiki setup) and from there, if they prove they are not little Connolleys, they can be promoted to editing rights.
Karl B. (15:08:51) :
This was an internal report that was shot down before it could work through normal editing cycles.
If this was an internal report, then it reflects badly on the internal expertise of EPA.
I decided to post to the “Bubkes” by gavin thread on RealClimate today, and it appears, for some reason, gavin thought it not worthy of space on RealClimate, as it didn’t make the “moderator”‘s cut.
Of course, Alan Carlin was denigrated about having no climate science credentials, so I posted (or tried to post) the following:
” 1. Greg Goodknight Says: Your comment is awaiting moderation.
28 June 2009 at 5:05 PM
R. Pachauri, Chair of the IPCC:
Indian Railways Institute of Mechanical and Electrical Engineering;
MS Industrial Engineering, Phd Industrial Engineering, PhD in Economics, North Carolina State University,
A. Carlin, BS Physics California Institute of Technology, PhD Econ, MIT.
North Carolina State engineering and econ, vs. CIT and MIT physics and econ. Which is the stronger science background?
It’s a shame Dr. Carlin had less than a week to crank out his draft report, but since the debate was over such things were mere formalities, and besides, it would have made his department look bad. Now the entire EPA is looking bad.”
It would have been #231…
I think that there is one very important point in this discussion. It doesn’t matter whether report has some errors in it. What important is that there is evidence that it was being suppressed. If it was evaluated on its merits and rejected on that basis EPA would have no problems whatsoever. It wasn’t and now they have.
It is not the crime itself, it’s a conspiracy to hide it that got Nixon and many, many others. That is where greatest potential in blowing this whole thing open lies. That is a chance to start real discussion regarding science. Lets hope that this will be a turning point.
I am very impressed with anyone who can assemble that much material and write the document in that short amount of time. And yes, there will be errors, typos, etc. But he captures every essential aspect for challenging CO2 being the cause of GW.
I do have one observation: In his document, on page 58 (73 of 100), in presenting data from Chapter 9 of IPCC’s Rev4 Report, the caption says the scale is “in degrees Celsius per decade”. In the IPCC report, http://ipcc-wg1.ucar.edu/wg1/Report/AR4WG1_Print_Ch09.pdf, Page 675, the caption states the units are “C/century”.
Would someone straighten out what are the units?
Tom Fuller,
I, too, found that the comment verification step on your site couldn’t be “obeyed,” since there was no image of letters/numbers that I would need to type to verify my status as a sentient being.
So, here’s what I would have said there:
This is your most important question: “How confident can the public be in the disinterested viewpoint normally expected from scientists?”
The answer appears to be: “The public should never believe the scientists trumpeting the greenhouse gas global warming hypothesis are disinterested; and should instead presume that they are not behaving in accordance with the scientific method at all.”
No one needs to be an expert in any science to recognize behavior that is analogous to that of religious zealots.
Rely on your own eyes, ears, and knowledge of the ways of the world.
The comments you elicited from the “RC” blog readers are from people who have the same dogmatic approach to the issues as the “AGW” “scientists”.
So, don’t shut up, no matter how indignantly they attempt to discourage you. Their zealous dogmatism is enough to turn a Bible thumping, snake handling, Appalachian fundamentalist green with envy. They won’t change, and you should not.
Mr. Fuller and your talking points:
There are two sides. Not only may AGW be wrong, but if they aren’t then there is also the the fact that an increase in temperature may well have considerable benefits to mankind in terms of better harvests, etc…. and gee, if we warmed the climate up for a few centuries, we could burn less fuel!! I had a terrible fuel bill up here in Ottawa for the last couple of years. I would hate to have to pay $200 BOE because of a tax and have colder winters to go with it. I don’t have any ready links but google “benefits of a warmer climate” – there is lots out there.
Lucy Skywalker (15:33:25) :
I think I’d feel safer if any edit that someone would want to do would have to be sent to a selected few people who run the page. Then the edit, if approved, would be added in by one of those few who control the page. That way no one but those few would ever have access to it.
Just Want Results… (14:55:36) :
I want results too.
Greg Goodknight (15:43:12) :
Gavin who?
[post excerpt plus link] ~ charles the moderator
The Imposter Maurice Garoutte (10:54:16) :
Your web site may be all about fun but I am not amused.
To Tom, that bit of snark at the end of the 10:54:16 comment was an imposter, not my thoughts.
To Anthony, You have an imposter on your site using my (formerly) good name. I don’t need any help looking opinionated.
REPLY: I’ll have a look. – Anthony
Ed Long (16:01:31) :
And yes, there will be errors, typos, etc. But he captures every essential aspect for challenging CO2 being the cause of GW.
Flawed data are not essential aspects for a successful challenge of AGW unless we play as dirty as they do.
D. Johnson (13:57:44:)
I was addressing the errors of the 1998 ‘n all that argument in the report. Its wildly unsuitable in a science setting. And, there isn’t even any cooling.
Myself, I’m content with the warmest month rankings. April was fifth; May was fourth.
Tamino may have been more adversarial because he was addressing the originator of the 1998 cherry-pick: Bob Carter.
These near flat-lined temperatures are obviously short of the model predictions. Natural fluctuations?…weather is not climate?…or…
“…we should expect the observations to catch-up somewhat with models because El Nino is due…” (Lucia)
Leif Svalgaard (17:22:09) :
Flawed data and flawed logic just before the deadline does little to advance the cause. However perfect data and perfect logic after the submission deadline does absolutely nothing to advance the cause. The administrators at the EPA know that, and that is why the review period was compressed.
We don’t have to play as dirty as the “end justifies the means” crowd in the administration but we do have to play within their rules. As long as the rules are controlled by Lisa Jackson, data and logic will have little to do with how the process plays out. Please keep your powder dry for the future court cases where the process can be challenged and the scientific process can (possibility) mean something.
Squidly says:
No. The current human emissions from burning fossil fuels are in fact enough to raise CO2 by about 3ppm or so EVERY YEAR. The actual rate of increase in CO2 levels in the atmosphere is about half that because the oceans and, to a lesser degree, the land biosphere, have been taking up about half of this excess. Humans are responsible for all, or essentially all, of the 100ppm increase in the past 100 years…and in fact the levels would have gone up about twice as much if these sinks did not absorb about half of what we have liberated into the atmosphere.
Francis (17:36:32) :
‘These near flat-lined temperatures are obviously short of the model predictions. Natural fluctuations?…weather is not climate?…or…
“…we should expect the observations to catch-up somewhat with models because El Nino is due…” (Lucia)’
Fine, but you left out the very significant possibity that the models are simply over-predicting the extent of warming. Isn’t this a significant omission?
Molon Labe says:
Sorry…I misformatted my last comment but the 2nd paragraph (the most indented one) are my words.
D Johnson (18:34:12) :
Francis (17:36:32) :
The models are non linear… if they are wrong at all, the errors will compound. It shows them to be less than useless at the present stage…
And something that has always irked me about the climate models and the AGW crowd is the whole weather is not climate… this statement taken on face value is true obviously, climate is a measure of the average of the weather… But, and its a big but, to model the earths climate WOULD require you too accurately predict the weather at every location around the globe at all times, because its non linear, and each event effects the next. So errors will compound. We’re not talking about a basic black body model after all. There are a lot more factors than albedo and the radiative properties of green house gases to be taken in to account.
“The current human emissions from burning fossil fuels are in fact enough to raise CO2 by about 3ppm or so EVERY YEAR.
Co2 does not control climate.
Haven’t you studied the science?
Is the document which requested comments public yet? Somehow the request for comments reached these fellows. Was it a memo sent to all employees, was it a task assigned to individual people?