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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Humans are responsible for all, or essentially all, of the 100ppm increase in the past 100 years
Please cite the references for this since no one can be certain of that. Where did you read this?
Did you take in to account co2 from oceans? Volcanoes? All natural sources?
You will have a precarious time proving that all the co2 increase over the last 100 years was manmade.
Just Want Results… says:
This comes from multiple lines of evidence. First of all, we have good estimates of the amount of fossil fuels burned and the amount of CO2 thus produced and thus how much CO2 levels would have gone up had all of this CO2 liberated from long-buried sources of carbon had not been so liberated. Hence, the oceans + lithosphere + biosphere must be a net sink. (There is also direct evidence of the change in pH in the oceans associated with their net uptake of CO2.)
Second of all, we have the strong circumstantial evidence from ice cores that CO2 levels have oscillated between about 180 and 300ppm over the last 750,000 years and have only shot up to their current levels of ~385ppm very recently…with the rise well-timed with the industrial revolution. (And, in fact, the more detailed measurement available since the 1950s show the CO2 levels consistently rising about half as fast as they would have had all of our emissions remained in the atmosphere. (When I say “consistently”, I mean once you average over several years; there is year-to-year variability in this associated with the ENSO oscillations / global temperatures, among other things.)
Third of all, there is the isotopic evidence that shows the increase in CO2 in the atmosphere is coming from the carbon in fossil fuels.
There are other lines of evidence, including the lag between the CO2 levels in the Northern Hemisphere (where most of the fossil fuel burning occurs) and the Southern Hemisphere.
I think my use of the word “circumstantial” is poorly expressed in my last post. What I say the ice cores show is not circumstantial. What is circumstantial is to use this history to say that therefore the current rise must be due to man. However, as circumstantial arguments go, it is a strong one because it is exceeding unlikely in a statistical sense that such a rise in CO2 over, say, any century would occur coincidentally with the time that we have been significantly burning of fossil fuels for unrelated natural reasons.
And, of course, the other lines of evidence further bury this “exceedingly unlikely coincidence” hypothesis!
Joel Shore said: “…it is exceeding unlikely in a statistical sense that such a rise in CO2 over, say, any century would occur coincidentally with the time that we have been significantly burning of fossil fuels for unrelated natural reasons.”
What does that mean, exactly? I have charts showing an amazing correlation between global warming and the number of pirates, and correlation between the rise in postage rates and the rise in CO2. So some folks have their pirates or postage rate hikes charted and use them to predict the future… and you’ve got your CO2=AGW hypothesis. Same-same.
REPLY: I can correlate temperature with a worldwide increase in carbonated beverage consumption. In fact, accronding to this graph, the steady increase in CO2 during the last century may be entirely correlated to soft drinks.
http://joemaller.com/wordpress/wp-content/uploads/2007/07/soft-drinks_vs_candy.gif
– Anthony
His main point was that EPA should not rely on IPCC AR4 because it was out of date. He cited work published since the AR4 cutoff date and indicated reasons why these studies should have been taken into acount but weren’t. If he’s “wrong” on something arising from a particular study that doesn’t mean he is “wrong” that it should have been considered (and maybe rejected).
Coverage of the passing of the bill in the house in Australia.
http://news.smh.com.au/breaking-news-world/obama-against-penalties-on-polluters-20090629-d1yn.html
I think China and India won’t care a hoot about the demise of US businesses.
I can correlate temperature with a worldwide increase in carbonated beverage consumption. In fact, according to this graph, the steady increase in CO2 during the last century may be entirely correlated to soft drinks.
Oddly the chart exactly matches my consumption of candy bars. Starting about 1987 I got hooked on the mars bar and have noted significant temperature rises since then. Likely due in part to these sinful ingredients: Creamy Nougat, Heavenly Carmel, Covered in Chocolate…
http://www.mars.com/global/Global+Brands/Snackfood/Mars.htm
This has been an interesting thread. However, unless I’ve missed something, it would appear that it is violating “Godwin’s Law of Nazi Analogies”. I was considering remedying that by talking about Jeffrey Immelt’s ambitions, but I couldn’t decide whether the better analogy was Albert Speer or Gustav Krupp. 🙂
Deep Climate wrote:
“Patagon,
“Did you read the actual abstract? It doesn’t support your conclusion: that Greenland “is accumulating mass, rather than melting”. That’s not how global warming works. Rather, snow accumulates at the centre and the ice pack melts at the edges.
“The surface mass balance trend over the full 1958–2007 period reveals the classic pattern expected in a warming climate, with increased snowfall in the interior and enhanced runoff from the marginal ablation zone. In the period 1990–2007, total runoff increased significantly, 3% per year. The absolute increase in runoff is especially pronounced in the southeast, where several outlet glaciers have recently accelerated.”
First, the bottom line is that there won’t be rising sea levels, because the increased snowfall will offset the increased runoff. Rising sea levels are the most worrisome outcome of global warming.
Second, the temperature rise in Greenland may not be indicative of global warming, but only local warming. Dr. Syun-Ichi Akasofu has claimed that during the period of claimed global warming, which the IPCC’s climate models predicted would result in temperature increases throughout the arctic, the temperature of Greenland declined. It’s only recently that it’s risen. Here is a link to his paper, 52-page PDF, “The Recovery from the Little Ice Age”:
http://people.iarc.uaf.edu/~sakasofu/pdf/recovery_little_ice_age.pdf
Pat (20:21:52) : I think China and India won’t care a hoot about the demise of US businesses.
With China aggressively building economic infrastructure maybe their plan is world domination through economics.
How funny it is that the USA—or I should say the current President—is doing everything it can to shut down economic progress.
—-
But not to worry, America can never fall behind China….sark off now.
we have good estimates
Ok, then provide them. I had already said cite your sources.
the strong circumstantial evidence
You evidence is inaccurate.
Provide sources please.
the isotopic evidence
Provide the source of your statement here please. This is what I asked in the first place.
What I am saying is provide the data.
What is circumstantial is to use this history to say that therefore the current rise must be due to man.
This is only opinion. You have not and cannot provide evidence for that. You cannot conclude it is due to man. You remind me very much of someone I debated for months at YouTube who would constantly give his view of things and never provide data. He would talk like he was so certain about things but when put on the spot to give the science for what he said was never able to produce any. He would only go on and on about what he “believed” was true–he literally would say “I believe”, not “the data shows”.
I could more accurately say that the recent rise in co2 level (which has now ended) is due primarily to increased solar activity (which also has now ended). And I will provide evidence.
This five part YouTube series about the suns influence on the earths warming and cooling, which includes warming and cooling of ocean water that is directly related to co2 level in the atmosphere.
I am very interested. I have everything ready, and would very much appreciate it.
the amount of fossil fuels burned and the amount of CO2
The level of manmade co2 is rising faster than was predicted it would. Yet worldwide the level of co2 is falling and so are temperatures.
You hypothesis wrong. The scientific method therefore says you must discard it.
The Scientific Method-Richard Feynman :
REPLY: I can correlate temperature with a worldwide increase in carbonated beverage consumption. In fact, accronding to this graph, the steady increase in CO2 during the last century may be entirely correlated to soft drinks.
LOL!!
President Obama has already this weekend started working on Senators to get them to pass Waxman-Markey
“Obama, hoping to build momentum in the Senate after the narrow victory in the House, delayed the start of a Sunday golf game to speak to a small group of reporters in the Oval Office…”
http://www.breitbart.com/article.php?id=CNG.e85bfc186c27a0ad174305d3021bd251.201&show_article=1&catnum=7
I’ve emailed Tom Fuller inviting him to dinner with me and moshpit.
REPLY: and I get to eat crackers while talking on a cell phone from up north. – Anthony
Reply 2: Did you want to join us? It would probably complicate scheduling if he agrees but anything for you sweetums. ~ charles the moderator aka jeez
REPLY3: sure, if the option is there. Make your plans and if I can come, I will – Anthony
Yes, check out McIntyre’s clearly written 20pg. submission to EPA. Among his other very important points regarding the EPA’s rules involved in its making of findings – peer review requirements and standards, transparency, methods and data availability, foi problems with the ipcc, etc., McIntyre notes that the very ipcc-basis for EPA’s “The Supporting Documents” might not have been actually “submitted” to the EPA in the first place, as required.
Just Want Results… (22:20:58) : The level of manmade co2 is rising faster than was predicted it would. Yet worldwide the level of co2 is falling and so are temperatures.
JWR you know I support you. Therefore I ask you to get your words correct, here. AFAIK the level of CO2 is not falling, it’s the rate of increase that’s falling. However, I seriously believe the levels should start falling some time… is anyone doing measurements comparable to MLO but independently (and not close to landmass forests / industries)?
Joel Shore (18:36:29) :
‘It is an approximate result that comes out of the models given their physics and assumptions about convective transport of water vapor, etc. And, this result has been now been well-verified by satellite observations.’
So Joel, where are all those high level, heat trapping clouds?
I found the Alan Carlin document very informative and a great summary of the arguments (in one place). Wondered about the inaccuracies but, then it’s always hard to know if someone is giving you a sales pitch. Thanks for the reminder on that.
Lucy, since the CO2 sinks are entirely modeled, and the decadel oscillations not even considered in the models, the CO2 source pump at Mauna Loa cannot be used as any kind of proxy for an accurate observed well mixed measure of atmospheric CO2 over decadel time scales. In fact, there are no “media active” monitors where CO2 is not (except maybe antarctica). I believe that the only way to know how much CO2 is in the air at any one time, and to show where it is and how it got there, without dubious modeling, it is to take actual measures of ground and atmospheric CO2 at a satellite level over time and plot it (much like oceanic temperatures at different depths are done and demonstrated). My hunch is that level, amount, and transportation of CO2 will demonstrate that industrial countries do not contribute significant amounts of anthropogenic CO2 world wide. It is more likely that natural and agricultural flora and fauna as well as oceanic sources are much more powerful sources of CO2, and not the internal combustion engine. However, the herds of animals on the Earth before agricultural sources came along may have been even greater. We are a pretty poor substitute, for example, for the vast buffalo herds that once roamed the midwest. This would lead us to propose that the Amazon jungle should be provided the opportunity to involve itself in the cap and trade scheme. And possibly King Triton.
One thing is completely clear to me from reading the public comment on the endangerment finding. There is no way that finding can survive a court challenge. The comments clearly show that the finding is illegal by both agency charter and executive orders still in force.