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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Luggo (15:37:21) :
If you are looking for flaws have you spent any time analyzing An Inconvenient Truth? You can find a supply of them there.
Have you investigated it?
Luggo (15:37:21) : It appears that Carlin may have a problem with attribution:
Back to that old standby “may” again.
Luggo (15:37:21) : 1. Not a “study”, but a critique based on the conclusions of others.
I think you are referring to An Inconvenient Truth, aren’t you?
Here’s some more hope.
Harry Reid supposedly said he is not even going to introduce this bill to the Senate.
If that’s true, he must not have the votes for passage, much less cloture.
Luggo (15:37:21) : “may”
Where would global warming be without words like ‘may’, ‘might’, ‘could’, ‘if’, etc.?
Luggo (15:37:21) : 1. Not a “study”, but a critique based on the conclusions of others.
I’m not sure what your point would be.
I would recommend that you don’t take up occupation of lawyer.
Luggo (15:37:21) : the Friends of Science
Yes, a wonderful group of people. The are concerned with science.
Tell me Luggo, who are you associated with? Are you a friend of politicians? A friend of environmental activism? Did I miss anyone?
What really ticks me off is that elected officials, by law in some cases, cannot respond to emails sent by non-constituents. Yet these same elected officials can receive lobby groups from some 3rd world country and even give them @ur momisugly#%& snacks and a drink. What kind of twisted logic is that? It seems that lobby groups have greater access to elected officials than a single individual from the state of Oregon wanting to email a representative from a neighboring district in the state of Oregon who’s decisions have the potential to affect everyone from that state and everyone from every other state in the US. But if your a lobbyist, here, have a cookie and we’ll talk.
Pamela: I wouldn’t bet my lunch money on it, either.
But it is not unreasonable to stipulate that a 3%/yr. CO2 increase will partially accumulate up to but not past the level of persistence, resulting in a 30% overall accumulated increase.
New data findings (on levels and/or persistence) may falsify that at any point, of course.
My greater point is, “So what?” CO2 is probably a considerable benefit to biomass and demonstrably has a minimal effect on temperature trends.
I think a good start would probably be the uncorrected world temperature series
Yes.
I would prefer a reliable TOBS adjustment, but I won’t trust TOBS adjustment until they start reading the actual figures off the actual forms.
Luggo (15:37:21) : 3. His conclusions on p. 64 – 66 render one incredulous.
Maybe it is you, and those like you, who are rendered thus. You could switch the word ‘one’ for the word ‘Luggo’, i.e. , “His conclusions on p. 64 – 66 render Luggo incredulous.”
evanmjones (16:20:02) : My greater point is, “So what?”
I agree and say too, so what.
Leif Svalgaard (13:18:42) :
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].
Gerry’s reply:
Let’s be clear about this. I’ve never said “Since it is not CO2 it must be the Sun.” But I do feel that those scientists who believe there is more evidence of the Sun being a climate driver than is CO2 are correct. I also understand that solar activity and galactic cosmic rays are not the only factors underlying cloud formation. One doesn’t have to be a meteorologist to realize that, but we certainly can all learn a great deal about climate from meteorologists, and I have a lot more respect for their knowledge than I do for the scientific knowledge of politicians.
Luggo (15:37:21) : 1. Not a “study”
You need to look things over more closely Luggo—no where is it claimed to be a study.
You’re shooting blanks dude.
Luggo (15:37:21) : 1. Not a “study”
You’re correct. It is not a study.
But it certainly was withheld! And it is a wonderful bit of news that it is now being investigated and revealed to the public!
As you look at longer and longer averaging windows the statistical significance decreases and eventually becomes zero.
Perhaps. But the cycles actually produce cooler/warmer SSTs and SATs. So there’s an actual measurable effect in evidence, not mere correlation.
Also, in the 1976 – 2001 interval we had the six most significant oceanic-atmospheric warm/cool cycles (PDO, SO, NAO, AMO, AO, AAO) go warm one after another.
That is an amazing lineup and given the variable lengths of these cycles, it is probably not repeated in pre-20th century iterations, so there will be less correlation.
Oh, and one more thing. Carlin never said that any of his points were proof-positive. He merely said that they deserve further consideration. If even one of them (and I read the whole draft) is correct or partially correct, it throws the whole EPA conclusion into a tizzy.
Luggo (15:37:21) :
I went to your link. All I can say is it’s so poorly written that it discredits itself.
Let’s not forget that the central tenet of the Carlin paper was simply to posit that the IPCC report was dated and that there was new information that cast doubt on many of those conclusions. Carlin cited a number of studies regarding feedbacks, hurricanes, etc. that were all more recent than the cut-off date of the IPCC, not to mention the temperature record of a statistically-level trend since 2000 or so.
EPA squelched this report, not because they were worried that they couldn’t refute it, but because they didn’t want to deal with the threshold matter of evaluating the scientific basis for CO2-driven global warming at all. From EPA’s persesctive, the IPCC had already made the necessary conclusions and all EPA thought they had to do was rubber stamp them. That’s why they thought a 1-week comment period was fine, and why Carlin’s report took them by surprise. You can’t weigh the IPCC’s conclusions against subsequently-discovered information without delving into the scientific basis that formed the basis for the IPCC conclusions in the first instance. EPA wanted to avoid making its own informed decision on the science at all costs, because that would have taken too much time.
Carlin’s report may well have included some inaccuracies. I remember when I read it that I had problems with the portion where he brought up correlation coefficients between temperature and presumed drivers like CO2, PDO, etc. The problem with this analysis was that the correlation between temperatures and PDO were so strong that the negative phase of the PDO would mask any correlation to CO2 during that phase. If you look at the graphs, you see that when PDO is positive, temperatures really go up, while in the negative phase they go down, but not by as sharp a rate as the uptick in the positive phase, leading to an overall upward trend. Trying to correlate CO2 rise to a temperature rise during the negative phase of the PDO is foolishness, even if CO2 does have a positive influence on temperatures.
On the other hand, however, what made the correlation to PDO so damned persuasive was the correlation to both increasing and decreasing temperatures. This eliminated any doubts I may have had about the temperature changes just happening to coincide with the PDO. The shifts happened in tandem like clockwork. CO2, on the other hand, could be entirely a coincidental correlation. CO2 is rising no matter what, and if the temperature just happens to be going up at the same time, e.g. as a recovery from the little ice age, then it’s a false positive.
Anyway, back to the original point, Carlin’s paper was impressive from the standpoint that it persuasively collated a lot of information, in the brief time he was permitted, that highlighted the many weaknesses in the IPCC report. Irrespective of whether you agree with everything in Carlin’s paper, I don’t think that any objective person could read the whole thing and think that there aren’t things that EPA needs to mull over before it just adopts the IPCC conclusions, in toto, without its own scientific review.
This latter point is the REAL ISSUE. Setting aside cap-and-trade on the assumption that if it passes any endangerment finding under the Clean Air Act gets mooted, the question is not whether EPA is supressing one side of a scientific inquiry, the issue is the threshold one of whether this country is going to hold its own official scientific inquiry at all. EPA sure doesn’t want one. The IPCC report has a number of procedural defects that won’t fly here in the US – look at Steve McIntyre’s commemts to the EPA regarding those. If EPA has to evaluate first hand the science behind global warming, then there really will be an opportunity to look at the data behind temperature reconstructions, model assumptions, etc.
But if your a lobbyist, here, have a cookie and we’ll talk.
You’ll have to make it a Dove bar.
Luggo (15:37:21) : 1. Not a “study”
It was never required to be a study to carry weight in it’s intended purpose.
Again Luggo, I wouldn’t recommend you become a lawyer.
Our local country radio station has a Morning Show that is live. The one doing news (Rob Lowery) picked up on the censored EPA-Carlin story and reported on it and the fact that he thought AGW was a scam. I expect he will get some negative feedback, although on a “country station” maybe not too much. I sent the following note.
kxle@elltel.net
Morning Show – Rob Lowery
While in the car this morning (Monday) I heard your comments regarding being a climate warming skeptic. You will probably get a few negative comments because of this. I, however, am in agreement and wrote a letter to the Ellensburg newspaper earlier this year saying why. Thanks for expressing your view on KXLE.
The following two sites are useful places for information:
http://wattsupwiththat.com/ Mostly not too technical, some silliness.
Owner/moderator is a degreed weather meteorologist.
http://www.climateaudit.org/ Often technical as the owner/moderator is a data analyst specialist. Both sarcastic and humorous at times.
The Morning Show is very entertaining – thanks for that too!
John F. Hultquist
Rural Kittitas County
Gerry (16:22:55) :
But I do feel that those scientists who believe there is more evidence of the Sun being a climate driver than is CO2 are correct.
There are many that believe it is mixture of the two, rather than an either/or thing. Throw in volcanoes and internal cycles of a complex system [ignoring external long-period orbital changes] and you have enough variables to fit just about anything. The important question is what the relative proportions of these different drivers are. And that is unknown. Unfortunately, Joe Sixpack and his elected officials can only comprehend one of the many causes [has a Hrair-limit of 1], so we have these meaningless vitriolic debates about whether it is this or that, rather than about how much of this, and of that, and that, and that, and …
Just Want Results… (14:45:53) :
let’s get with it and inform news agencies, like Drudge, about it.
And Drudge has it…
Leif Svalgaard (18:57:54) :
I just saw, thanks!
Landmark. Fox News reports Inhofe’s call:
http://www.foxnews.com/politics/2009/06/29/gop-senator-calls-inquiry-supressed-climate-change-report/
Ain’t MSM but significant NTL.
Luggo is correct. Carlin cribbed the premise and key sections of his report from PR disinformation spinmeister Pat Michaels’ World Climate Report, but appropriated it as his own.
See the latest:
http://deepclimate.org/2009/06/30/suppressed-carlin-report-based-on-pat-michaels-attack-on-epa/
Also:
http://deepclimate.org/2009/06/28/epas-alan-carlin-channels-pat-michaels-and-the-friends-of-science/