Here is a version of my EPA testimony that contains links to the 2009 publication Global Climate Change Impacts in the United States, published by the U.S. Global Change Research Program (USGCRP). As shown in my comments, this document played a principal role in their Endangerment Finding of December 7, 2009.
Also linked is a draft document, ADDENDUM: Global Climate Change Impacts in the United States, by the Center for the Study of Public Science and Public Policy at the Cato Institute. This document is analogous to the USGCRP report in form and content, but details the voluminous science that the USGCRP either ignored or slanted. It is a fact that there are almost twice as many references and endnotes in the Addendum than there are in the original report. Note that this is a draft version that contains various minor errors and will undergo some slight changes before the final version is released later this year.
Readers should enjoy looking at the USGCRP document and the Addendum side-by-side. (see below).
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Docket No. EPA‐HQ‐OAR‐2011‐0660
Standards of Performance for Greenhouse Gas Emissions for New Stationary Sources: Electric Utility Generating Units
Public Comments by:
Dr. Patrick J. Michaels
June 22, 2012
Chapter 3 of EPA’s the Regulatory Impact Analysis (RIA) for the Proposed Standards of Performance for Greenhouse Gas Emissions for New Stationary Sources: Electric Utility Generating Units is concerned with “The climate change problem and rationale for rulemaking.” The Chapter “summarizes the adverse effects on public health and public welfare detailed in the 2009 Endangerment Finding” and has this to say regarding the source of the scientific opinions underlying the Endangerment Finding:
The major assessments by the U.S. Global Change Research Program (USGCRP), the Intergovernmental Panel on Climate Change (IPCC), and the National Research Council (NRC) served as the primary scientific basis for these effects.
In fact, the USGCRP 2009 report, Global Climate Change Impacts in the United States is the only one of these documents that relates directly and purposefully to climate change in the U.S. It is therefore of much more import than the other two.
The EPA’s proposed rule states that “There is no reason to revisit the 2009 Endangerment Finding given recent scientific findings that strengthen the scientific conclusion that GHG air pollution endangers human health and welfare.”
That is not the case. Through careful consideration and involved effort, I conclusively demonstrate in the attached report that the 2009 USGCRP report Global Climate Change Impacts in the United States—itself a summary of 21 Synthesis and Assessment Reports produced by the USGCRP (formerly the Climate Change Science Program) over the past several years prior to 2009—is unrepresentative of the larger body of scientific research on the topic of anthropogenic climate change and its potential impacts in the United States. It is wholly inappropriate for the EPA to rely on a set of documents that is clearly slanted towards negative impacts from climate change when there is a large body of scientific evidence, much of it not included in the USGCRP assessment products, that argues for the contrary. The EPA, contrary to its assertion, must revisit the Endangerment Finding.
I submitted an extensive public comment when Global Climate Change Impacts in the United States was in draft form, in which I stated, with some dismay, that:
Of all of the “consensus” government or intergovernmental documents of this genre that I have reviewed in my 30+ years in this profession, there is no doubt that this is absolutely the worst of all. Virtually every sentence can be contested or does not represent a complete survey of a relevant literature…
Not only did the 2009 USGCRP report re-appear in near its draft form, but, what’s worse, it served as the foundation document pertaining to climate impacts in the U.S. for EPA’s Endangerment Finding, and, subsequently, the EPA’s Proposed Standards of Performance for Greenhouse Gas Emissions for New Stationary Sources: Electric Utility Generating Units.
The USGCRP report is scientifically misleading and unfortunately it has served to mislead the EPA. However, my initial review of the draft report, while extensive, was limited by the brevity of the Comment Period.
To complete my review, I began to work on a separate document, an “Addendum” to the 2009 USGCRP report, extensively detailing, in the same format as that report, the “missing” science. It is noteworthy that the number of citations and endnotes in the Addendum substantially exceeds—932 versus 569—the number in the 2009 USGCRP report. Some of these papers were available to the authors of the report. Many additional new and influential scientific findings have been published subsequent to the 2009 USGCRP report. Consequently, my Addendum draws upon a considerably more comprehensive body of scientific research. Noteworthy is that many of the papers cited in the Addendum that were published after the 2009 USGCRP report indicate the probability of extreme climate change is much lower than the USGCRP assumed.
This directly challenges EPA’s glib assertion that recent science reinforces “the scientific conclusion that GHG air pollution endangers human health and welfare,” and with regard to science published concurrently or previous to the USGCRP report, is prima facie evidence that there was a voluminous refereed literature that the USGCRP chose to ignore, and, by the reference standard, a volume that was larger than the science it did consider.
A team of well-qualified scientists and experts produced the “Addendum”, which represents a complementary and extensive assessment of the “missing” scientific literature. While this report is not in its absolute final form, I include the fourth-order draft as the central part of my public comments on the New Stationary Source proposal. It is imperative that the EPA closely examine and compare this Addendum to the original USGCRP document. Such an examination will be eye-opening and should convincingly demonstrate that the EPA must reassess the science of climate change and therefore reconsider their Endangerment Finding, which, of course, is the rationale for the New Stationary Source proposal. The proposed regulation should be withdrawn until such time as a thorough review of the most current science can be conducted and submitted for public comment.
As an example of differences between the two reports, I include below a comparison between the “Key Findings” in each of the two reports—the original 2009 USGCRP Global Climate Change Impacts in the United States and my Addendum to that report. The side-by-side comparison clearly shows that the whole of the scientific literature tells a much different story than only those parts selected for inclusion by the USGCRP.
Original USGCRP Report
In addition to my complete Addendum which is included below, I am providing two links that will aid EPA and interested parties in comparing the original USGCRP document and the Addendum.
The original USGCRP document can be found at:
and the Addendum is located at:
I submit the full Addendum report as part of my comments on the EPA’s Proposed Standards of Performance for Greenhouse Gas Emissions for New Stationary Sources: Electric Utility Generating Units. I ask that the EPA complete a thorough review of this Addendum in order to better expose them to the full scope of the science of anthropogenic climate change—a scope that was not provided by the USGCRP. As a result, the Endangerment Finding may be sufficiently compromised so that it cannot serve as the basis for any proposed regulation.
Further, no static report can provide long-term guidance as to the nature of climate change and its impacts as this field is constantly evolving under the weight of new scientific findings. Consequently, it is imperative EPA reassess the current scientific understanding on an annual basis, if not continuously. If the EPA were to do have done that with the regulations being proposed here (consideration of my comments and Addendum would have been an appropriate place to start) it is quite likely that their original Endangerment Finding would have to be revised and potentially overturned.
Relying on dated and incomplete science in a rapidly evolving environment will almost certainly lead to poor regulations. In the name of science and in the spirit of responsible government, the EPA must revisit the Endangerment Finding before adopting sweeping regulations with potentially enormous economic and social implications.