GHGs, California, and the EPA: a golden braid of off-the-rails

30 July 2021

Pat Frank

I get emails from the EPA Office of Public Engagement. They came regularly, though not since I submitted testimony to them on June 21.

The short of it is that on April 26, I received an email from the EPA with the subject line, “EPA Reconsiders Previous Administration’s Withdrawal of California’s Waiver to Enforce Greenhouse Gas Standards for Cars and Light Trucks

California has applied for a waiver from the EPA’s SAFE-1 vehicle rule, which regulates so-called GHG emissions of cars and light trucks. These are the vehicles used by families and small business owners, primarily.

California wants to apply stricter emission standards than the EPA warrants — no surprise there — and so has asked for a waiver from the SAFE-1 Rule.

The EPA’s April 26 email noted the opportunity to remotely testify at public hearings about the waiver during June 2-June 6. So, I availed myself of it. Each speaker got three minutes. But written testimony was also accepted at the EPA Docket web portal.

My June 2nd three minutes included self-introduction and quick mention of 21 years attention to climate science, that climate models are unreliable, and the IPCC doesn’t know what it’s talking about. The EPA CO2 endangerment finding has no scientific basis, so the SAFE-1 rule is pointless.

If the SAFE-1 rule is pointless, well, then, so is a waiver from it. A rather condensed 3-minute message.

The panel noted that written testimony was accepted at their Docket web portal.

So, I uploaded the more detailed written testimony to the EPA on June 4. It presented the unreliability of the current CMIP6 climate models and reminded the EPA of their own stated commitment to make evidence-based decisions using only the best available science. Right.

The unskilled CMIP6 climate models undergird the soon-to-be-portentously-cried IPCC 6AR.

A PDF of the full testimony is available to anyone in California who wishes to send it to their state representative; or to the California Air Resources Board; or to Mr. Larry Elder’s campaign; or to any lawyer engaged in a class-action suit to recover injuries caused by false-precision-based climate legislation.

Here’s the testimony.


Written Comments on the US EPA SAFE 1 Adjudication Proposal

With Necessary Reference to the Science Underlying the CO2 Endangerment Finding

Docket ID No. EPA-HQ-OAR-2021-0257


Patrick Frank, Ph.D.

Oral testimony presented to the Environmental Protection Agency

2021 June 2

Summary Preface

The 31 March 2020 EPA SAFE Vehicles Rule finds its justification in the 7 December 2009 EPA CO2 Endangerment Finding.

General circulation climate models (GCMs) provide the sole foundation for both the 2009 Endangerment Finding and the SAFE Vehicle Rule because GCMs are the sole source for equating danger to CO2 emissions.

Until recently, the physical accuracy and reliability of GCM outputs had never been evaluated.

Propagation of Error and the Reliability of Global Air Temperature Projections, [1] published on 6 September 2019 following expert peer-review, presents the first critical evaluation of the physical accuracy and reliability of advanced GCMs, with direct bearing on the notion that CO2 emissions are dangerous.

Findings include:

  1. cloud fraction simulation error indicates a GCM lower limit of resolution that is about 800 times too coarse to detect a thermal signal, if any, from CO2 emissions.the uncertainty in centennial-scale GCM projections of air temperature is ±(12-17) C.
  2. GCMs are unable to detect, to attribute, or to project the effect, if any, of CO2 emissions upon global air temperature.
  3. They have no predictive value.

The unavoidable conclusions are that the SAFE Vehicle Rule serves no ameliorative purpose because the EPA CO2 endangerment finding is without any scientific merit.

As the SAFE Vehicle Rule serves no evident purpose, a SAFE waiver extended to California is senseless. The EPA is self-committed to adjudicate the California waiver accordingly.

Full Written Testimony

The EPA Office of Public Engagement Release of 10 February 2021 was, “EPA Takes Action to Protect Scientific Integrity.” Therein, Acting Science Advisor Dr. Jennifer Orme-Zavaleta noted that, “Science is the backbone of EPA.” Dr. Orme-Zavaleta further committed the EPA to, “making evidence-based decisions and developing policies and programs that are guided by the best available scientific data.

The testimony herein is presented with the confidence that the EPA will fulfill its commitment to scientific integrity and to guidance by the best science.

The EPA SAFE Vehicles Rule was activated on 31 March 2020. The SAFE protocol establishes fuel economy standards to service an imperative calling for a decrease in automotive tailpipe emissions of carbon dioxide (CO2). The present EPA concern is adjudicating the reintroduction of a waiver of SAFE allowing California to enforce its own greenhouse gas pollution standards for cars and trucks.

The imperative to decrease CO2 emissions rests upon the 7 December 2009 EPA CO2 endangerment finding. Therefore, the EPA SAFE Vehicles Rule, and waivers pertaining thereto, are driven entirely by the EPA CO2 endangerment finding.

This testimony evaluates whether the SAFE Vehicle Rule is based upon the best science. That evaluation will in turn determine whether the waiver for California has valid standing.

The full peer-reviewed scientific case supporting this testimony is available as an open access publication [1], and is included herein as an Addendum.

The entire case for a future catastrophe in air temperatures driven by CO2 emissions, rests upon the projections derived from general circulation climate models (GCMs). However, climate models through the CMIP5 generation have no predictive value (cf. below). [1] The prospect of a future extreme of air temperatures therefore has no scientific standing.

Explanatory Figure 1 presents evidence that a simple linear equation can successfully emulate the air temperature projections of the most advanced CMIP6 generation of climate models.

Figure 1: CMIP6 GCM air temperature projections can be fully replicated using a simple linear equation. Left panels: (blue points), the air temperature projections of the CMIP6 AWI-CM-1-1 GCM of the Alfred Wegener Institute, for four different shared socioeconomic pathway (SSP) forcing scenarios; (red lines), successful emulations of the projections using the “Climate Model Emulator” (cf. above, right)), using the identical SSP forcings.

Figure 1 shows that the same linear equation that successfully emulated the air temperature projections of CMIP5 and all prior generations of GCMs, [1] will faithfully emulate the air temperature projections of the current CMIP6 climate models. This work will be submitted for publication. [2]

Explanatory Figure 2 below conveys the CMIP6 error in simulated global cloud fraction.[1, 3, 4] Clouds control the amount of sun-derived thermal energy that resides in the troposphere (the atmosphere laying between the surface and the stratosphere).

Comparison of simulated cloud fraction against observed cloud fraction calibrates the accuracy of climate model output. Figure 2, left, shows that neither CMIP5 nor CMIP6 climate models are able to correctly simulate the global cloud cover fraction.

Simulation error in cloud cover produces an error in the simulated thermal energy flux (the heat content) of the troposphere. The thermal energy flux of the troposphere determines air temperature. ([5], cf. Figure 7.1)

Evaluation of 45 CMIP6 GCMs indicated an annual average error in simulated tropospheric thermal energy flux of ±2.9 W/m2. [2] By way of comparison, the annual average of thermal flux energy (forcing) that CO2 emissions contribute to the troposphere since 1979 is 0.035 W/m2.

Figure 2: (left), the CMIP6 error in simulated cloud cover, and; (right) the consequent error in tropospheric thermal energy flux.

The level of GCM simulation error defines their power to resolve detail. The relative sizes of GCM resolution of thermal energy flux and CO2 forcing is (±2.9 W/m2)/(0.035 W/m2) = 82.9.

That is, the smallest detail of tropospheric thermal energy flux (heat content) that can be resolved in a GCM simulation is 83 times larger than CO2 forcing. More simply, if a CMIP6 model were a lens, the effect of CO2 forcing would be 83 times too small to notice.

Typically, resolution power must be ten times signal intensity in order to obtain a reliable determination. In this metric, CMIP6 climate models must improve by 830-fold in order to reliably detect a forcing signal from CO2 emissions, if any.

Explanatory Figure 3 demonstrates the impact of CMIP6 error in simulated tropospheric thermal energy flux, on the reliability of CMIP6 air temperature projections. One notes here that the 23 June 1988 presentation before the Senate Committee on Energy and Natural Resources included no uncertainty bars. [6]

Uncertainty in a linear summation such as the projected air temperature of an advanced GCM, is the addition in quadrature of the error in each member of the sum.[1, 7, 8]

The uncertainty in the sum total is the magnitude of each entry propagated forward combined in quadrature. The result is an increasingly large envelope of uncertainty. [1]

From Figure 3, the uncertainty in the CMIP6 projected air temperature for the four shared socioeconomic pathways is, ±16.7 C (±30.1 F, ssp126), ±16 C (±28.8 F, ssp245), ±15.7 C (±28.3 F, ssp370), and ±12.1 C (±21.8 F, ssp585), after a centennial simulation.

These very large uncertainty envelopes reflect the 83-fold disparity between the error in simulated cloud fraction and the tiny perturbation from CO2 emissions.

The uncertainty after 100 years of projection exceeds any possible physical change in temperature. However, these large plus/minus uncertainties do not imply that the future climate may be, e.g., 30 F warmer or cooler than now.

The plus/minus uncertainty statistics do not at all indicate temperature. They indicate the region where complete ignorance reigns. This absolutely central point must be understood.

Figure 3: (left panels), the uncertainty envelopes around future air temperatures for four different shared socioeconomic pathway (SSP) forcing scenarios projected using the AWI-CM-1-1 CMIP6 GCM of the Alfred Wegener Institute (cf. Figure 1); (right panel), the emulation equation now including the ±2.9 W/m2 contribution of average annual CMIP6 tropospheric thermal energy flux error used to derive the uncertainty bounds.

The resolution of CMIP6 climate models is not up to the job of discerning or predicting the effect, if any, of CO2 emissions upon the climate. The large uncertainty envelopes indicate that future air temperatures are invisible to CMIP6 climate models.

Climate models cannot predict air temperatures 100 years out. Nor can they predict air temperatures one year out.

The strictly scientific interpretation of the uncertainty envelopes of Figure 3 is that the air temperature projections of CMIP6 climate models are physically meaningless. They impart no information whatever about future global air temperature.


Focus now returns to adjudication of the SAFE waiver for California.

The absence of any physical meaning in temperatures projected on the grounds of forcing from CO2 emissions means the SAFE Vehicle Rule is not grounded in science.

Indeed, the notion that vehicular CO2 emissions represent pollution at all is analytically vacated.

The unavoidable conclusions are that the SAFE Vehicle Rule serves no ameliorative purpose because the EPA CO2 endangerment finding has no scientific merit.

As the SAFE Vehicle Rule serves no evident purpose, the SAFE waiver extended to California is senseless and of no import.

The EPA has committed itself to adjudicate the California waiver accordingly.

In Added Note

The EPA Technical Support (TS) document of the endangerment finding is not a critical analysis. It is instead a catalogue recrudescing the IPCC Assessment Reports.

For example, the TS document ignores the known systematic temperature measurement errors of field meteorological stations. These errors completely obscure the rate and the magnitude of climate warming since 1900. [9, 10]

Further, The TS document uncritically accepts proxy air-temperature reconstructions despite that they have no distinct physical meaning. [11]

Critical analysis fully removes the notion that the EPA CO2 endangerment finding has any scientific standing. Neither, then, does the 2020 SAFE Vehicle Rule. A vitiation waiver for California is senseless.


[1]        Frank, P., Propagation of Error and the Reliability of Global Air Temperature Projections. Frontiers in Earth Science: Atmospheric Sciences, 2019. 7(223)

[2]        Frank, P., Are CMIP6 Air Temperature Projections Reliable? in preparation, 2021

[3]        Vignesh, P.P., et al., Assessment of CMIP6 Cloud Fraction and Comparison with Satellite Observations. Earth and Space Science, 2020. 7(2): p. e2019EA000975

[4]        Wild, M., The global energy balance as represented in CMIP6 climate models. Climate Dynamics, 2020. 55(3): p. 553-577

[5]        IPCC, Climate Change 2013: The Physical Science Basis. Contribution of Working Group 1 to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change, T.F. Stocker, et al., Editors. 2013, Cambridge University Press: Cambridge, United Kingdom and New York, NY, USA. p. 1535.

[6]        Hansen, J. Statement of Dr. James Hansen, Director, NASA Goddard Institute for Space Studies.  1988 [Last accessed:  4 June 2021; Testimony before the US Senate Committee on Energy and Natural Resources: The Greenhouse Effect: Impacts on Current Global Temperature and Regional Heat Waves]. Available from:

[7]        Bevington, P.R. and D.K. Robinson, Data Reduction and Error Analysis for the Physical Sciences. 3rd ed. 2003, Boston: McGraw-Hill.

[8]        Taylor, B.N. and C.E. Kuyatt., Guidelines for Evaluating and Expressing the Uncertainty of NIST Measurement Results. 1994, National Institute of Standards and Technology: Washington, DC. p. 20.

[9]        Frank, P., Uncertainty in the Global Average Surface Air Temperature Index: A Representative Lower Limit. Energy & Environment, 2010. 21(8): p. 969-989

[10]      Frank, P., Systematic Error in Climate Measurements: the global air temperature record, in The Role of Science in the Third Millennium, R. Ragaini ed, 2016,  World Scientific: Singapore, pp. 337-351.

[11]      Frank, P., Negligence, Non-Science, and Consensus Climatology. Energy & Environment, 2015. 26(3): p. 391-416

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Steve Case
August 1, 2021 10:14 pm

So how many speakers were there? Only a few? Then maybe you will get some consideration. But if there are 20 or so other speakers and they’re all communists then you will be thoroughly ignored.

Pat Frank
Reply to  Steve Case
August 2, 2021 8:01 am

At 3 minutes each, Steve, there were 20 per hour. After me there came a young girl (maybe 12 from her voice), who spoke with confidence in approval. That’s when I logged off.

The moderator’s voice communicated endurance in the face of boredom. But he was paying attention, and recommended the Docket upload.

Comments were open for four days. I’d suppose upwards of 200 commenters. Not much fun for the panel.

Kevin kilty
Reply to  Pat Frank
August 2, 2021 9:28 am

I had the same experience in a recent hearing in which I was alotted three minutes also. Three minutes goes by fast. A large proportion of people in favor of the project were junior high and high school students who added nothing of value to the discussion except fatigue of the committee. All they did was repeat pro forma commentary that they’d received in school. There were also some young people against the project who added crazy testimony. Very little testimony was fact-based, lots of emotion.

I jumped at the opening of public comment and spoke first hoping I might have a bit more impact, but I doubt I actually had any more than the young people.

Rick C
Reply to  Pat Frank
August 2, 2021 11:59 am

Having been through several EPA NSPS rule making exercises I predict EPA will dismiss your comment and all others opposing granting the waiver. Of course, they are required to issue a detailed response to comments which will appear months (or perhaps years) after the fact. It will probably be hundreds of pages and be written in indecipherable bureaucratic language. I would not be at all surprised to see EPA cite the comments made by those alarmists who have dismissed your paper because they don’t understand the difference between “uncertainty” and “error”. Sadly under EPA rule making procedures there is no avenue to challenge their ultimate determination short of filing a law suit.

Geoff Sherrington
August 1, 2021 11:20 pm

Your essay is a timely return to proper science, thank you.
If its treatment follows some past patterns, we might expect those in EPA who read it to seek to dismiss it on grounds that a body like Real Climate has found it lacking, so all that is needed is a note back to you saying thank you for the submission, which will be given attention,
Is there no way in which, legally, you can require EPA to halt public action pending their study and scientific response to your submission?
I wish that more people had your knowledge and drive. There must be some me scientists in EPA who can perceive how correct you are. It then becomes an ethical matter if they fail to speak.
Geoff S

Pat Frank
Reply to  Geoff Sherrington
August 2, 2021 8:06 am

Thanks, Geoff.

If past is prologue, the only way to get action would very likely be by lawsuit as Thomas Gasloli suggests below.

I did my best to hold the EPA’s best available science feet to the fire, but don’t hold much hope that it will cause a thoughtful pause.

Reply to  Pat Frank
August 2, 2021 8:34 am

Pat, they intend to apply “the best available science THEY ALREADY PAID TO HAVE PRODUCED”.

Joel O'Bryan
August 1, 2021 11:21 pm

Well the World-famous, teenage high school drop-out, Swedish Climate Expert has a concise
rebuttal to Dr Frank…

Reply to  Joel O'Bryan
August 2, 2021 12:32 am

She’s calling her time off high school ‘a gap year ‘. So it seems she’s back in class, or did covid spike her international travels?

August 1, 2021 11:54 pm

No, don’t let them have a waiver.
Let them feel the effect of the results of their beliefs.
It might push some sense into their heads.

Doc Chuck
August 1, 2021 11:58 pm

Nicely concise presentation, Pat, that confronts a corner of practical mensuration that bureaucrats have never even begun to grasp. The (un-)scientific consensus that drives so much public policy with accompanying copious ‘virtuous’ expenditure from city to state/province to nation to international governance levels is clearly based upon politically appealing notions of effective human climate control thoroughly anchored in an abiding quicksand of assessed attribution to oxidized carbon that is indeed beyond our current reckoning powers and so any quantitative prediction capability from first principles in our water planet’s complex yet remarkably stable solar/atmospheric system.

Otherwise we are confidently entrained into heading off a phantom crisis that is the very inverse of its actually documented beneficial moderation in cold night-time temperatures in northern subarctic latitudes while daily high temperatures are to date notably without much overall trend even in the tropics. We are no doubt VERY PROUD of ourselves!

Reply to  Doc Chuck
August 2, 2021 2:36 am

Nicely written but the second last sentence implies tropics should be most likely to change; specifically:

notably without much overall trend even in the tropics.

The tropical oceans are temperature limited and least likely to reflect real climate changes. They are limited to 30C on average and brief excursion to 32C as the limiting process kicks in. So the SST in tropics is remarkably stable. The Nino34 region, spanning the equatorial Pacific, has no trend over 40 years – per chart. Unlike the climate models that claim to present reality.

The only response of climate modellers to such absurdities is that their particular model is similar to all the other models. Reality takes a back seat in model world. Reasonably so as well because the modellers have close ties to the weather monitoring groups responsible for weather forecasts and they have become adept at changing history. The Australian BoM are up to version 2.1 of their ACORN surface temperature homogenisation program. The Nino34 region is important internationally and less likely to suffer historical down-trending than national datasets.

Honiara, near the equator provides a good example of the stability of the upper limit:

Peta of Newark
Reply to  RickWill
August 2, 2021 4:21 am

Inside one of the ‘Massive Online Open Courses’ I did on the subject of Climate, it was actually admitted that if a Climate scientist/researcher/modeller:
“Didn’t like the look of the output” (of any particular run of The Model)
..They simply binned it and ran the model again.

And so on ad-infinitum until they got something they ‘liked the look of‘ – patently meaning something akin what everyone elseliked the look of‘ or “seemed about right

Hence what you say about all model outputs looking similar..

There aren’t the words to describe…… it’s got everything and everything about it, the science, the people and politics is WRONG

Reply to  Peta of Newark
August 2, 2021 5:46 am

It sounds like the farmers who wanted me to repeat their silage analyses until they got a result that said the feed value was OK.
They weren’t generally very good farmers..

Dave Fair
Reply to  Peta of Newark
August 2, 2021 10:31 am

IIRC, at least one UN IPCC CliSciFi modeler stated they adjusted parameters until they got an “ECS that looked about right.”

Devils Tower
Reply to  Doc Chuck
August 2, 2021 2:55 am

As for a manufactured crisis. The feather river has been at flood stage all summer while lake Oroville is being drained.

The people of California need to clean house. The reason behind this at another time.

Alan Tomalty
August 2, 2021 1:41 am

Pat, did your discussion with Patrick Brown about base state errors with the cloud forcing end with an agreement to disagree? 

Pat Frank
Reply to  Alan Tomalty
August 2, 2021 7:55 am

More like it ended at an impasse, Alan.

Patrick Brown showed zero understanding of physical error analysis or of the impact of error. He made the standard climate modeler’s mistake of seeing ±T uncertainty and assigning physical T meaning.

Like all of them, he assumes that whatever errors there are in the zeroth simulation (the base-state) all subtract away when taking differences.

Alan Tomalty
Reply to  Alan Tomalty
August 3, 2021 8:29 am

Pat could you also show how the 0.35 W/m^2 number was calculated(the annual forcing since 1979)?

Alan Tomalty
Reply to  Alan Tomalty
August 3, 2021 8:30 am

Sorry my mistake It is 0.035 W/m^2.

Pat Frank
Reply to  Alan Tomalty
August 3, 2021 10:15 am

Hi Alan, I just added up all the forcing anomalies starting in 1979, and then divided by the number of years. As simple as that. The average annual increase I got is 0.035 W/m^2.

You can check that here at the RF Wiki page. They give a chart of forcings, conveniently from 1979-2019. The annual average increase in GHG forcing is 0.036 W/m^2.

Pat Frank
Reply to  Pat Frank
August 3, 2021 10:35 am

Sorry, 0.035 W/m^2.

August 2, 2021 2:06 am

There is climate change – the only constant in climate is change.

The unphysical claptrap embodied in climate models is diverting resources from productive endeavour to unbounded waste.

The oceans of the Northern Hemisphere have had an increasing trend in sunshine since 1585 while the oceans of the Southern Hemisphere have sunshine trending down. These changes are real and significant. Not some fanciful consequence of increasing CO2.

There are real changes in climate associated with the changes in sunlight over oceans with corresponding changes in the timing and variation in sunlight intensity over the oceans. The climate models are so inept that they do not even assess the consequence of real changes.

The modern demonising of CO2 is as absurd as virgin sacrifices in dated religions. It is perverse, in fact criminal negligence, to foster a false belief under the guise of “the science” that the molecule responsible for all life on Earth is causing climate – warming, change, wierding or emergency while not assessing the real changes that are occurring and will eventually need mitigating action.

AGW is Not Science
Reply to  RickWill
August 2, 2021 7:14 am

will eventually need mitigating action require adaptation.

Fixed it for you. We can’t “do” anything about the climate, except adapt to the changes, which will occur whether we like it or not.

Ron Long
August 2, 2021 3:25 am

Good report and nice effort by Pat Frank. However, Kalifornia is dysfunctional and proud of it, so they don’t like these sort of “but the King has no clothes” type presentations. Press on, and good luck to the effort.

Frank from NoVA
August 2, 2021 4:25 am

Bravo Pat. Your excellent work strikes at the heart of the GCM’s that are the only ‘predictive’ basis of ‘support’ for the EPA’s Endangerment Finding and CAGW. There are only two outcomes from here: either the world sees scientific reason and pulls back from the brink of alarmism, or it lunges into an abyss of economic tyranny and collapse.

David Dibbell
August 2, 2021 4:47 am

Pat Frank, your continuing efforts to expose and explain the unreliability of GCM simulations relating to CO2 are greatly appreciated. Please keep on.

Andy Pattullo
August 2, 2021 6:12 am

In a fair and open boxing match you would have scored an immediate knock-out evident to all who watched. In the world of policy-driven “science” you will likely be disqualified for muddying the waters with facts.

Jim Gorman
August 2, 2021 6:25 am

Pat, excellent work. I wish more scientists involved with the physical measurement of the world would speak up about the uncertainty an iterative, linear process generates. There are surely certified surveyors who can address cumulative uncertainty when using past measuring equipment with large uncertainty in each individual measurement.

Carpenters, surveyors, master machinists, chemists, and quality control people who deal with real world measurements and must understand this in order to properly do their work. I simply don’t understand why climate scientists get away with not even knowing the fundamentals of uncertainty in measurements.

AGW is Not Science
Reply to  Jim Gorman
August 2, 2021 7:23 am

I simply don’t understand why climate scientists get away with not even knowing the fundamentals of uncertainty in measurements.

Well, when the “goose that lays the golden eggs” (of “grant funding”) is birthed by cooking up an imaginary, and, of course, human induced, “crisis,” uncertainty is an inconvenience that must be swept under the rug. Otherwise people won’t believe the bullshit they’re peddling, because once the uncertainty is known, the fact that so-called “climate science” is nothing but agitprop will be revealed and “belief” will quickly evaporate. Kind of like what happens when the man behind the curtain is discovered in OZ.

Doc Chuck
Reply to  AGW is Not Science
August 2, 2021 10:14 pm

Yeah but, this way ‘Fake Science’ can join its big brother ‘Fake News’ in brazenly joy riding at the expense of their merely honest working class fellow countrymen whilst garnering accolades traditionally well-earned by those who’ve done notable careful inquiries that actually deserved their garnered recognition. It’s apparently as irresistible as stealing candy from an inattentive baby.

Thomas Gasloli
August 2, 2021 7:13 am

They will respond to it the same way they responded to all the evidence refuting the proposed Greenhouse Gas Finding of Endangerment; they will say, “The Agency disagrees.”

As someone with nearly 40 years of experience in environmental protection, who has prepared comments on proposed regulations, and responses to public comment, the public comment system is a joke. The agency has total power, the agency can simply respond as stated above. The only alternative is a lawsuit before a judge that who will more than likely side with the agency’s interpretation of the “science”

The only real solution is to dramatically reduce government power, and go back to legislatures legislating instead of delegating total authority to agencies to do whatever they want.

August 2, 2021 7:17 am

Pat, you’re right of course.
But what you are saying is a threat to the very basis of their career planning, which involves having future employees reporting to them and large corporations cowtowing to them for planning approvals. So it will be ignored by anyone with a salary in the EPA and labelled heresy….

Pat Frank
August 2, 2021 7:38 am

My thanks yet again to Anthony and Charles for hosting my work, and for all they do.

Smart Rock
August 2, 2021 8:05 am

Pat: Nice work. If there is a politician who can get past the first page without their eyes glazing over, I would be very, very surprised. Mostly, they would go straight to your conclusions, and decide that you’re “just another denialist”

It’s not about science. It’s never been about science. More precisely, it’s not about science as we know it.

As soon as the big money is looking for a certain result, science becomes “science”. It may look like science, sound like science, feel like science, but science it is not. Ego can play a role in transforming science into “science” (Mann is a prime example) but money, taxpayers’ money by the boatload, is the big corrupter. If you want to see it in action elsewhere, just look at the pharmaceutical industry.

Using documented facts, logic and science-based arguments against the climate-change juggernaut is like trying to fend off a hungry tiger with a fly-swatter. Face it, they have won and we have lost. So far. Doesn’t mean that we stop trying, though. Now that those far-off target dates for CO2 emission reduction are suddenly getting very close, the pain is going to start for the general public, and folk will maybe start to listen.

Keep up the good work, Dr. Frank, and try not to lose heart.

Dave Fair
Reply to  Smart Rock
August 2, 2021 10:40 am

I call “science” CliSciFi. I agree that the average taxpayer will revolt once the now-hidden costs are revealed. Yellow Vest forever.

August 2, 2021 8:17 am

Valiant attempt but facts and reason stand no chance against the array of vested interests on the other side including: Tesla (both EV and Solar City), Silicon Valley VCs investing in green tech, existing green tech startups and companies, wind and solar PV manufacturers, etc etc.

Richard M
August 2, 2021 8:26 am

The biggest reason the models are crap is they handle CO2 incorrectly. This data from long ago shows what really happens in the atmosphere.
comment image

Essentially, the troposphere is opaque to CO2 absorption/emission. CO2 does it’s thing above the clouds. That means that it is essentially working with IR from water vapor and clouds. It does not participate in what is usually referred to as the greenhouse effect.

That means understanding clouds is essentially to understanding what changes in CO2 will do to the climate. Pat’s paper is even more important under the proper view of atmospheric physics.

Dave Fair
Reply to  Richard M
August 2, 2021 10:45 am

A grad student has upended the “blanket” description of the CO2 effect. His paper “proves” that CO2 only affects aerosols and clouds, din ‘cha know?

Steve Z
August 2, 2021 8:38 am

That’s quite a revelation that the global climate models have an error of +/- 2.9 W/m2 on the heat-trapping or sunlight-reflecting effect of clouds, which overwhelms any effect of CO2. Do any of the writers of the global climate models know that there is this much uncertainty in their models, or are they just trying to hide it? The climate models don’t seem to be any more accurate than throwing darts at a thermometer blindfolded!

Pat Frank
Reply to  Steve Z
August 2, 2021 10:02 am

They know it’s there, Steve. They just assume off-setting errors make everything physically correct, and/or assume the errors subtract away when taking anomalies.

The field is full of self-serving assumptions like that, which allow the modelers to make their grand conclusions without having to do any of the really gritty hard work of science.

Tom Abbott
August 2, 2021 8:51 am

From the article: “or to Mr. Larry Elder’s campaign”

Wouldn’t you just love it if Larry Elder won the California governorship!

Elder would make one heck of a good governor. Or anything else he applied himself to.

August 2, 2021 9:09 am

Oh, well, you can not model clouds, if you have not slightest clue what role they play in climate. And the fascinating fact is, “climate science” totally messed up this part. The CRElw (cloud radiative effect, long wave side) has a magnitude of about 80W/m2. That is 30W/m2 only clouds and 50W/m2 clouds overlapped with GHGs.

Climate science has been ignoring this overlapped part for decades and only (erroneously) allocates it to GHGs. Thereby it hugely underestimates the GHE due clouds, and equally overestimates that of GHGs. Also, correcting for this mistake, we find that clouds are NET WARMING the planet!

In reality the GHE looks something this..

Carlo, Monte
August 2, 2021 9:25 am

Pat: is it correct to assume that there are other errors built into these models that are not quantified which can only make the iterative uncertainties larger?

Pat Frank
Reply to  Carlo, Monte
August 2, 2021 9:59 am

Yes, you’re exactly correct to conclude that, Carlo.

The most recent discussion of model systematic errors of which I’m aware is D. Zanchettin, et al., (2017) Structural decomposition of decadal climate prediction errors: A Bayesian approach Scientific Reports 7(1) 12862.

W. Soon, S. Baliunas, S. B. Idso, K. Y. Kondratyev and E. S. Posmentier Modeling climatic effects of anthropogenic carbon dioxide emissions: unknowns and uncertainties is perhaps more accessible.

They discuss the many 10s of Watts of error that arise in different parts of a model simulation.

The paper is pretty much as relevant now as it was 20 years ago, because climate physical theory has not advanced much since then. Mostly because the modelers have driven all the physicists out of the field.

It remains true as well, that the ocean model in AOGCMs still does not converge. But that’s OK to modelers because ‘it looks reasonable (hand-waving communicated).’

If all those iteration-transmitted simulation errors were propagated into the final projection, the plotted uncertainty envelope would be about the size of North America, i.e., gernormous.

Kevin kilty
August 2, 2021 9:36 am


Your explanation of uncertainty is even more effective in this EPA testimony than in your earlier contributions here at WUWT. For some reason the point that this is not a projection of temperatures, but an indication of what is not known came through far clearer. Thanks for taking the time, and the risk of being simply trashed, to make this testimony. I hate doing things like this.

Pat Frank
Reply to  Kevin kilty
August 2, 2021 2:16 pm

Thanks, Kevin. You know this stuff down to the bedrock. Your agreement is very welcome.

michael hart
August 2, 2021 11:38 am

 “EPA Reconsiders Previous Administration’s Withdrawal of California’s Waiver to Enforce Greenhouse Gas Standards for Cars and Light Trucks

I’m slightly confused. Does this, and following sentences, mean that California wanted permission to impose higher standards than the EPA, the Trump Administration granted it, and the EPA has now changed its mind?

Pat Frank
Reply to  michael hart
August 2, 2021 2:17 pm

As I understand it, the EPA is re-imposing a standard the Trump administration had set aside. California wants a waiver from the EPA standard in order to apply its own stricter one.

Jeff Reppun
August 2, 2021 11:52 am

What is needed is an organized and funded effort to challenge all the federal agencies that publish information with the obvious objective of giving support to a massive and poorly understood alteration of the country’s energy systems based on unsupportable scientific claims, including support of IPCC messaging.
Here is an excerpt from the EPA’s “Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity, of Information Disseminated by the Environmental Protection Agency”
OMB Guidelines In Section 515(a) of the Treasury and General Government Appropriations Act for Fiscal Year 2001 (Public Law 106-554; H.R. 5658), Congress directed OMB to issue government-wide guidelines that “provide policy and procedural guidance to Federal agencies for ensuring and maximizing the quality, objectivity, utility, and integrity of information (including statistical information) disseminated by Federal agencies….” The OMB guidelines direct agencies subject to the Paperwork Reduction Act (44 U.S.C. 3502(1)) to:

  1. Issue their own information quality guidelines to ensure and maximize the quality, objectivity, utility, and integrity of information, including statistical information, by no later than one year after the date of issuance of the OMB guidelines;
  2. Establish administrative mechanisms allowing affected persons to seek and obtain correction of information maintained and disseminated by the agency that does not comply with the OMB or agency guidelines; and
  3. Report to the Director of OMB the number and nature of complaints received by the agency regarding agency compliance with OMB guidelines concerning the quality, objectivity, utility, and integrity of information and how such complaints were resolved. 

The US legal system puts preference on US government agencies scientist in establishing who is scientifically correct. Sooner or later the attribution lawsuits will get one of our agencies to give support to their attribution claims.
If there is not an effort to force agencies to abide by congressionally mandated quality standards, the battle will be totally lost.

Pat Frank
August 5, 2021 1:56 pm

In a revelatory follow-up. I received the email below from the EPA Office of Public Engagement today. The inadvertent irony is bitter rather than funny.

EPA to Overhaul Pollution Standards for Passenger Vehicles and Heavy-Duty Trucks, Paving Way for Zero-Emission Future.”

Here’s a bit of selected text: “Washington, DC (August 5, 2021) – Today, the Environmental Protection Agency (EPA) is proposing to set robust federal greenhouse gas (GHG) emissions standards for passenger cars and light trucks to secure pollution reductions through Model Year (MY) 2026.

CO2 as pollution. I wonder if they polled the the florasphere.

“Today, EPA takes a major step forward in delivering on President Biden’s ambitious agenda to address the climate crisis and create good paying, union jobs,” said EPA Administrator Michael S. Regan. “These robust standards are underpinned by sound science and technical expertise, (my emphasis) t

The juxtaposition of climate crisis and sound science is especially rich. Note the sop to workers with false promises of good jobs (subsidy paychecks) and union support with promises of membership.

“EPA estimates that this proposal would result in 2.2 billion tons of avoided CO2 emissions through 2050. … Those avoided emissions would provide between $86 and $140 billion in net benefits for Americans.

Models all the way down.

All of this will “[pave] paving the way for deploying rapidly developing trends toward zero-emission technologies and the substantial improvements in air quality they will make possible.”

Right. Third-world strip mines for rare metals. Blighted landscapes dedicated to wind farms and PV solar. An impoverished citizenry (subjects, really, not citizens). Unreliable intermittent power. Blackouts. No AC on very hot days or heat on very cold days. Food scarcity. And an enormous pollution problem of overage and failed wind generators and heavy metal PV panels.

This is your EPA at work, deploying evidence-based decisions using only the best available science. Right again.

All for the children.

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