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 wonder if there is a climate scientist out there worth his or her salt who would dare to begin a study with the null hypothesis and try every thing to prove that null hypothesis. One must therefore look for and study natural phenomena in order to then wonder at why the repeated and verified results show some unusual outliers. It seems to me that researchers these days skip that very vital first step, which is to prove that the normal distribution of the data is indeed normal. Could it be that we don’t yet know what is normal? Or rather, we refuse to consider what is normal and instead cherry pick our way to what becomes essentially a skewed distribution where all the data are outliers?
Many examples of “conclusions” based on biased, skewed, cherry picked bell curve distributions have led to tragic consequences. For example, the parents of children with autism were thought to be responsible for such a devastating illness, and in some cases, were accused of abuse where none existed, and thus lost custody of their children. In much the same way but on a much larger scale, humans are being charged with a disease that may be entirely part of the normal scheme of things (IE not caused by humans) and will experience the tragic consequences of misguided, enforced policies.
Which court?
Mark
“In general, we look for a new law by the following process. First, we guess it. Then we compute the consequences of the guess to see what would be implied if this law that we guessed is right. Then we compare the result of the computation to nature, with experiment or experience; compare it directly with observation to see if it works. If it disagrees with experiment it is wrong. It’s that simple statement that is the key to science. It does not make any difference how beautiful your guess is. It does not make any difference how smart you are, who made the guess, or what his name is — if it disagrees with experiment it is wrong.”
-Dr. Richard Feynman, “The Character of Natural Law,” The MIT Press, 1965, p. 156.
By this simple, yet brutally effective criterion, any competent and honest scientist would necessarily reject the AGW hypothesis (note – it never did qualify as an actual scientific theory).
1. The Vostok ice core data that was originally claimed to prove that atmospheric CO2 forces warming, at a closer look revealed that increases in CO2 lag temperature increases by 600 to 1,000 years. This means that warming causes more CO2, not vice versa. The data can be explained by well-established natural mechanisms, principally by the predictable release of CO2 from the oceans as they warm (the solubility of CO2 in water decreases with increasing water temperature).
2. If increases in “greenhouse gases” do increase global temperatures, a reasonably consistent positive correlation over a long period of time should be observed. Instead, it has been observed over the last century and a half that while atmospheric CO2 levels have gradually but consistently increased, global temperatures have sometimes increased and at other times have decreased, decreasing most notably in the three decades from the early 1940’s through the early 1970’s. The most accurate global temperature data has been from NASA and NOAA satellite measurements of lower atmosphere temperatures from 1979 to the present. Over that forty year interval there have been peak fluctuations up to +0.8, -0.5 degrees Centigrade, but currently the global temperature is just 0.04 deg C over the mean temperature from Jan. 1979 to Jan. 1989. If anthropogenic greenhouse gas emissions could possibly cause “runaway” global warming, some evidence to this effect would presumably be evident in the data by now, yet the measurements clearly do not support this hypothesis.
3. Whereas there is no significant correlation between greenhouse gases and global temperatures over the last century and a half, a very strong correlation has been established between solar activity and global temperature over the last four centuries, as explained in plain language in this video:
4. Three strikes and you’re out, AGW advocates.
“Climate Audit Submission to EPA”
http://www.climateaudit.org/?p=6354
PDF of Steve McIntyre’s submission to the EPA
Having just read Steve’s submission to EPA substantially questioning the “legality” of IPCC’s AR4 according to EPA’s own “Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility and Integrity of Information Disseminated by the Environmental Protection Agency,” and the OMB and EPA Peer Review Guidelines – I am impressed.
What is key here is that the lay person understand that EPA appears to have disregarded not only internal critical commentary (e.g. Alan Carlin) but, according to McIntyre’s submission, they overlooked their own rigorous standards of quality in accepting external (IPCC) reports.
Steve’s submission points specifically to his experience as an expert reviewer for IPCC AR4 and his attempts to access the underlying data used by papers he was reviewing. These attempts were imperiously rejected by IPCC’s Chair of Working Group I, with the statement that he was not entitled to such underlying data and materials. Yet the OMB/EPA Guidelines for Peer Review demand reviewers be given “sufficient background information, including access to key studies, data and models, to perform their role as peer reviewers.”
All this points to the likelihood that EPA’s Endangerment finding is fraught with legal and scientific weakness. How could it not be? To the lay person the Environmental Protection Agency has declared the bubbles in your soda pop a “pollutant.” Step back for one short moment and contemplate the abject ridiculae of such a finding!
That such a finding is in fact the basis for massive taxation of industrial nations without benefit of representation – is the hidden agenda. Thanks Steve for laying the groundwork for a plausible legal challenge to EPA’s endangerment finding and the subsequent Waxman Markey tax bill.
Gerry (09:40:40) :
3. Whereas there is no significant correlation between greenhouse gases and global temperatures over the last century and a half, a very strong correlation has been established between solar activity and global temperature over the last four centuries
The video is as slick as “An Inconvenient Truth (AIT)” and as wrong in its details. One of the most irritating errors is the notion that the Sun’s magnetic field ‘keeps the cosmic rays at bay’. This is incorrect, the Sun modulates the cosmic ray flux by a few percent, so the video should have shown 100 cosmic rays bombarding the Earth, then putting in the Sun and shown that 97 cosmic rays still bombarding the Earth. One could go over the rest and find many more errors, not unlike when a British Court found eleven errors in AIT, but we have gone over this ground often enough. What is a bit sad is that we apparently choose to combat AGW with ‘science’ just as bad. I take it that for the solar enthusiasts, that ‘science’ is settled, too.
I believe the video linked by Gerry (09:40:40) was a snippet from The Great Global Warming Swindle, which was wrong on a number of details but nonetheless named a number of scientists who have done good research.
Anyone watching GGWS had plenty of information to start googling the published research and find the likes of Friis-Christensen, Svensmark, Shaviv, Veizer and others free of the editorializing of folks who studied communications rather than physics or chemistry.
Similarly, the video snippet posted by Just Want Results… (22:03:06) appears to be the documentary Klimamysteriet (The Cloud Mystery), which keeps getting taken down from servers due to copyright issues. It seems there will be a release of a newer cut than this one from Danish TV this coming September:
http://klimamysteriet.dk/
Leif Svalgaard (10:29:53) :
Gerry (09:40:40) :
The video is as slick as “An Inconvenient Truth (AIT)” and as wrong in its details. One of the most irritating errors is the notion that the Sun’s magnetic field ‘keeps the cosmic rays at bay’. This is incorrect, the Sun modulates the cosmic ray flux by a few percent, so the video should have shown 100 cosmic rays bombarding the Earth, then putting in the Sun and shown that 97 cosmic rays still bombarding the Earth. One could go over the rest and find many more errors, not unlike when a British Court found eleven errors in AIT, but we have gone over this ground often enough. What is a bit sad is that we apparently choose to combat AGW with ’science’ just as bad. I take it that for the solar enthusiasts, that ’science’ is settled, too.
Reply from Gerry:
Leif,
Yes, the video is slick, but not fearmongering-slick, as is “An Inconvenient Truth.” I happen to like the video, even though I have nothing to do with its creation. We scientists are rightly concerned about getting the details right. Unfortunately, while we are unearthing the devil in the details, legislators pass laws that don’t make any sense.
True, the Sun’s magnetic field does not directly modulate galactic cosmic radiation appreciably. It does, as you well know, modulate the solar wind, which is currently in a relatively collapsed state. Also, those few highly energetic GCRs produce very impressive amounts of secondary radiation (nucleons and muons), as they enter Earth’s atmospere. These are the actual cloud-seeding particles in Henrik Svensmark’s hypothesis. Here is Shir Naviv’s succinct explanation of the successful SKY experiment:
http://www.sciencebits.com/SkyResults.
A CERN experiment is in the works, but not in time to stop any foolish climate legislation from possibly being voted in by the Senate.
Of course the science is not settled! But IMHO we can already rule out the notion that CO2 emissions are causing, or will in the next century cause, runaway global warming. I’ve looked at the alleged evidence behind this claim and none of the details, when examined closely, hold up scientifically. But if you know of any that you think do, I will certainly re-examine them.
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.
I agree that the ~3% rise in CO2 contributed by man has caused a ~30% rise in CO2 levels over the past several decades. About half is absorbed by other sinks, the other half accumulates. Even this will level off depending on the persistence factor (currently in huge dispute) and the fact that CO2 input will not increase forever.
Yet CO2 rise and actual temperature rise correlate rather poorly. Multidecadal oceanic-atmospheric cycles correlate rather well.
Gerry (12:56:22) :
But IMHO we can already rule out the notion that CO2 emissions are causing, or will in the next century cause, runaway global warming. I’ve looked at the alleged evidence behind this claim and none of the details, when examined closely, hold up scientifically. But if you know of any that you think do, I will certainly re-examine them.
The way one looks at the evidence of a solar/climate connection should not be biased by one’s opinion on the CO2 issue. Sadly, that happens a lot. Since it is not CO2 [so goes the mantra] it must be the Sun [‘what else can it be’ brays the enthusiasts].
evanmjones (13:00:19) :
Yet CO2 rise and actual temperature rise correlate rather poorly. Multidecadal oceanic-atmospheric cycles correlate rather well.
The more you average the higher a correlation gets, average all the way down to two data points [1st half and 2nd half of the data] and the correlation coefficient has magnitude 1. As you look at longer and longer averaging windows the statistical significance decreases and eventually becomes zero.
I seem to be in the habit of spelling people’s names wrong! I thought I had typed “Nir Shaviv” in my last post, but apparently got a little dyslexic again and must not have reread this part before sending. My abject apologies, Nir!
This is certainly not the way to befriend fellow scientists.
evanmjones, we don’t have observed total atmospheric CO2 oscillations yet. We have partly modeled and partly local measurements, and this over less than one oceanic oscillation in many areas. Much of the land-based modeled flora calculations we have on CO2 absorption is extrapolated from enclosed greenhouse experiments, not in situ measurements. Oceanic CO2 levels are another thing all together with proxies as well as direct measures here and there, yet only one calculation is used for the whole oceanic shebang as if the oceans were a static stable entity. I would not bet my lunch money on current CO2 estimates.
Joel Shore (19:45:06) :
“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.”
My understanding is that the isotopic data proves that the increase in co2 is organic in origin.. Not necessarily proof of it coming from fossil fuels as such. That would be an assumption, that seems to be portrayed as a fact.
End of the day we contribute approximately 3% of annual emissions of co2, and thus 3% of the rise could be directly attributed to fossil fuels talking literally.
The thing is, as youve rightly pointed out, co2 levels are the highest theyve been in 750,000 years… but temperatures have been higher at every other interglacial than the present temperatures… and even warmer earlier than present climate at earlier times during this interglacial… in spite of considerably lower atmospheric co2 levels…
And for that matter their have been vastly more dramatic shifts in climate(100x present) previously during Holocene period during times of low atmospheric co2… Which certainly points a finger at other mechanisms having a greater influence on climate than atmospheric co2.
Leif, I agree about averaging in that the data noise is as important (if not more?) as the average in weather pattern variation science. This desire to average out the bumps in order to find a tiny signal is not well thought out. Why? Because I don’t believe the weather data noise is random. It is responding to drivers that the resultant averaged signal cannot distinguish between.
This reminds me of trying to get elicited auditory brainstem response (ABR) signals (which are deep and synaptically regular) to appear out of cortical random noise (which are nearer the surface, and in quiet, can be quite random). The electrodes placed on roughened clean skin on the head pick up a cacophony of brainwave signals. What we are looking for is a signal we are driving. The first experiment found only random noise with no evidence of the clicking noise going through the ear phones. But now we know why. The cortical impulses which are overwhelming stronger than the brainstem signals, must be made to be random, which is why ABR signals are best collected under a very nondistracting and quiet ambient atmosphere. In fact, it is made easier when the patient is asleep. Why do we need cortical brainwaves to be random? So that we can average them out (to near zero) of the total signals we are getting from the surface of the skin on the head so that we can see a signal we are actually driving. We know how the auditory nerve works. Any elicited response from that nerve using clicks or pips will show electrical synaptic regularity though at least wave 5, and in some folks with quiet brains, all the way to wave 7. Any non-elicited random response detected by the electrodes on the skin can be averaged out to zero because there is nothing eliciting it in any regular way. In quiet, these non-elicited brainwaves go up as much as they go down because nothing is driving them with regularity. With ABR signals, we know how loud the signals are, what frequency band they are, and how fast we are delivering them. We can then calculate where we would see the synaptic signals from the onset of the brainwaves we are picking up through the skin. And sure enough, after “washing” the data from the electrodes in a mathematical averaging bath, so to speak, we are left with a 5 to 7 waves that cannot be averaged out nearly as easily and are where we predicted they would be.
I apply this to climate trend analysis in noisy weather data. The mistake made is the assumption that out of weather noise, we can find the signal of an elicited driver, such as emitted CO2. But we cannot take weather noise out of the total signal because it is also elicited. It is not random noise. Therefore the rise, fall, or stable averaged statistic is nothing more than the weather. You cannot say anything else about it because you cannot average out weather pattern variation drivers any more or less than you could average out a Michael Jackson tune from brainwaves so that you could find the response to clicks or pips. Yet, climate modelers do exactly that. They assume that the non-random magical trend line is something else than the assumed random weather noise. They are wrong on both assumptions. They jump to a conclusion about the trend being something else than statistically averaged weather noise, and they jump to a conclusion that weather noise is random. It is therefore inappropriate, based on the weather temperature data, to use the statistical linear data as well as the modeled data to make these conclusions. The proof must be made elsewhere in order for AGW to be more than just hypothesized.
Search “Joe Barton, EPA suppression.”
Rep. Joe Barton, Texas is asking the questions…
The scientific purists here should bear in mind that the quality or accuracy of Dr. Carlin’s comments is irrelevant. The burden of proof is solely with the EPA to demonstrate that all such comments have been fairly considered.
Gerry (12:56:22) :
It is true the science is not settled. I have not heard that Henrik Svensmark or Nir Shaviv say that it is. But the aerosols are produced. I am glad that the CERN CLOUD work is being done. It will help define what Svensmark has found.
All new discoveries run in to resistance. After Einstein published General Relativity there were scientists who held conferences to denounce it. One scientists literally said Einstein should be killed for giving such an odd concept to the public.
p.s., The documentary, The Cloud Mystery, is wonderful. It is unjust to compare it to An Inconvenient Truth.
———————————–
CERN CLOUD :
http://public.web.cern.ch/public/en/spotlight/SpotlightCloud-en.html
Lucy Skywalker (01:32:25) :
Thanks for the friendly words Lucy. 🙂
Gerry (12:56:22) : A CERN experiment is in the works, but not in time to stop any foolish climate legislation from possibly being voted in by the Senate.
Enough science has already been presented to the Senate to convince them about this issue. If CERN CLOUD was already completed and its case laid before the Senate I don’t think they would listen to it either.
It looks like it’s going to come down to which Democratic Senators are worried about re-election in November 2010 and not about the science on if Waxman-Markey passes or not.
1. Not a “study”, but a critique based on the conclusions of others.
2. Carlin is part of “Global Cooling” cadre.
3. His conclusions on p. 64 – 66 render one incredulous.
It appears that Carlin may have a problem with attribution:
“EPA’s Alan Carlin channels Pat Michaels and the Friends of Science”
June 28, 2009
http://deepclimate.org/2009/06/28/epas-alan-carlin-channels-pat-michaels-and-the-friends-of-science/
“It was reassigning you or losing my job, and I didn’t want to lose my job,” Carlin said, paraphrasing what he claimed were McGartland’s comments to him. “My inference (was) that he was receiving some sort of higher-level pressure.”
http://www.foxnews.com/politics/2009/06/29/gop-senator-calls-inquiry-supressed-climate-change-report/
Greg Goodknight (12:37:10) : …The Great Global Warming Swindle, which was wrong on a number of details…
I was unaware of these. Would you enumerate them?
Pamela Gray (09:00:00) :
I wonder if there is a climate scientist out there worth his or her salt who would dare to begin a study with the null hypothesis and try every thing to prove that null hypothesis.
I think a good start would probably be the uncorrected world temperature series
DaveE.
evanmjones (15:38:13) :
Sen. James Inhofe… told FOX News, saying he’s ordered an investigation. “We’re going to expose it.”
This is good news! This is the first flash of hope I have that Waxman-Markey can be defeated in Senate.
evan,
last Friday I was pretty pessimistic about what was going to happen when it was voted on in Senate. Thanks for posting this!!
p.s Anthony is fortunate to have the final report exclusive!!
Good onya Anthony!!
Luggo (15:37:21) : 2. Carlin is part of “Global Cooling” cadre.
Provide evidence for this talking point please.