CEI Releases Suppressed EPA Report
The Competitive Enterprise Institute made public an internal study on climate science which was suppressed by the Environmental Protection Agency. 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 passing the "Cap and Trade" bill regulating and taxing carbon dioxide emmissions.
The following are extracts from the Executive Summary of the draft EPA Report, Proposed NCEE Comments on Draft Technical Support Document for Endangerment Analysis for Greenhouse Gas Emissions Under the Clean Air Act, which the Obama Administration has been hiding from the public for months because the findings run counter to its prevailing metanarrative.
The current Draft TSD is based on the IPCC AR4 report, which is at best three years out of date in a rapidly changing field. There have been important developments in areas that deserve careful attention in this draft. The list includes the following five:
• Global temperatures have declined--extending the current downtrend to eleven years, with a particularly rapid decline in 2007-8; in addition, the PDO went negative in September 2007 and the AMO in January 2009 respectively. At the same time, atmospheric CO2 levels have continued to increase and CO2 emissions have accelerated.
• The consensus on past, present and future Atlantic hurricane behavior has changed. Initially, it tilted towards the idea that anthropogenic global warming is leading to (and will lead to) more frequent and intense storms. Now the consensus is much more neutral, arguing that future Atlantic tropical cyclones will be little different from those of the past.
• The idea that warming temperatures will cause Greenland to rapidly shed its ice has been greatly diminished by new results indicating little evidence for the operation of such processes.
• One of the worst economic recessions since World War II has greatly reduced GHG [Greenhouse Gas] emissions compared to assumptions made by the IPCC. To the extent that ambient GHG levels are relevant for future global temperatures, these emissions reductions should greatly influence the adverse effects of these emissions on public health and welfare. The current draft TSD does not reflect the changes that have already occurred nor those that are likely to occur in the future as the result of the recession. In fact, the topic is not even discussed to our knowledge.
• A new 2009 paper finds the crucial assumptions in the GCM models used by the IPCC concerning strongly negative feedback from water vapor is not supported by empirical evidence, and that the feedback is actually negative.
• A new 2009 paper by Scafetta and West suggests that the IPCC used faulty solar data in dismissing the direct effects of solar variability on global temperatures. Their research suggests that solar variability could account for up to 68% of the increase in the world's global temperature.These six developments alone should greatly influence any assessment of "vulnerability, risk and impacts" of climate change within the U.S. But these are just a few of the new developments since 2006. Therefore, extensive portions of the EPA's endangerment TSD which were based upon the old science are not longer appropriate and need to be revised before a new TSD is issued for comments.
Not only is the science of the TSD out of date, but there are a number of other disturbing inconsistencies between the temperature and other scientific data, and the GHG/CO2 hypothesis that need to be carefully explored and explained if the draft TSD is to be credible. Despite the complexity of the climate system, the following conclusions appear to be well supported by the available data:
A. By far the best single explanation for global temperature fluctuations is variation in the PDO/ENSO. ENSO appears to operate in a 3-5 year cycle. PDO/AMO appear to operate in about a 60-year cycle. This is not really explained in the draft TSD, but needs to be, or, at the very least, there needs to be an explanation of why OAR believes that these evidence cycles do not exist, or why they are much more unimportant than we believe them to be.
B. There appears to be a strong association between solar sunspots/irradiance and global temperature fluctuations. It is unclear how this operates, but it may be through indirect solar variability on cloud formation. This topic is not really explored in the draft TSD but needs to be, since otherwise the effects of solar variations may be misattributed to effects of changes in GHG levels.
C. Changes in GHG concentrations seem to have so little effect that it is difficult to find any effect in the satellite temperature record, which started in 1978.
D. The surface measurements (HADCRUT) are more ambiguous than the satellite measurements in that the increasing temperatures shown since the mid-1970s could either be due to the rabid growth of urbanization and the heat island effect, or by the increase in GHG levels. However, since no such increase is shown in the satellite record, it appears more likely that urbanization and the UHI effect are the most likely cause. If so, the increases may have little to do with GHGs and everything to do with the rapid urbanization during the period. Given the discrepancy between surface temperature records in 1940-75, and 1998-2008 and the increases in GHG levels during these periods, it appears even more unlikely that GHGs have much effect on measured surface temperatures either. These points need to be very carefully and fully discussed in the draft TSD if it is to be scientifically credible.
E. Hence, it is not reasonable to conclude that there is any endangerment from changes in GHG levels based on the satellite record, since almost all fluctuations appear to be due to natural causes and not human-caused pollution as defined by the Clean Air Act. The surface record is more equivocal but needs to be carefully discussed, which would require careful revision of the draft TSD.
F. There is a strong possibility that there are some other natural causes of global temperature fluctuations that we do not yet fully understand, and which may account for the 1998 temperature peak which appears on both the satellite and surface temperature records. This possibility needs to be fully explained and discussed in the draft TSD. Until and unless these and many other inconsistencies referenced in these comments are adequately explained it would appear to be premature to attribute all or even any of what warming has occurred to changes in the GHG/CO2 atmospheric levels.
These inconsistencies are so important sufficiently abstruse that in our view EPA needs to make an independent analysis of the science of global warming, rather than adopting the conclusions of the IPCC and CCSP without much more careful and independent EPA staff review than is evidenced by the draft TSP. Adopting the scientific conclusions of an outside group such as the IPCC or CCSP without thorough review by EPA is not in the EPA tradition, anyway, and there seems to be little reason to change the tradition in this case. If there conclusions should be incorrect and EPA acts on them, EPA will be blamed for inadequate research and understanding, and reaching a possibly inaccurate determination of endangerment. Given the downward trend in temperatures since 1998 (which some think will continue until at least 2030), there is no particular reason to rush into decisions based on a scientific hypothesis that does not appear to explain most of the available data.
Finally, there is an obvious logical problem posed by steadily increasing U.S. health and welfare measurements and the alleged endangerment of health and welfare discussed in this draft TSD during a period of rapid rise in at least CO2 ambient levels. This discontinuity either needs to be carefully explained in the draft TSD or the conclusions changed.