Friday, June 26, 2009

"the administration has decided to move forward..."

The Competitive Enterprise Institute has been watching this story play out...


The National Council on Environmental Economics has examined the Environmental Protection Agency's Draft Technical Support Document for Endangerment Analysis for Greenhouse Gas Emissions under the Clean Air Act. (As we all remember, the Supreme Court decided that the EPA should regulate carbon dioxide as a pollutant, and the EPA promptly decided to regulate carbon dioxide and methane.) So the EPA is preparing an "endangerment" analysis on how Americans are "endangered" by carbon dioxide and methane, and getting ready to propose new regulations.

Of course, you can't do things like that without some analysis of the impact, of the costs and the benefits. so the NCEE has reviewed the draft proposal, and has some comments. But they aren't being released - the EPA is trying to suppress the analysis. Why is that? Well, as the Director of the National Center for Environmental Economics Al McGartland wrote to Alan Carlin, the NCEE scientist who prepared the review:
The time for such discussion of fundamental issues has passed for this round. The administrator and the administration has [sic] decided to move forward on endangerment, and your comments do not help the legal or policy case for this decision...I can only see one impact of your comment given where we are in the process, and that would be a very negative impact on our office.


And the comments that would have such a negative impact?
The current Draft TSB is based largely on the IPCC AR4 report, which is at best three years out of date in a rapidly changing field...
- Global temperatures have declined - extending the current downtrend to 11 years...at the same time atmospheric CO2 levels have continued to increase and CO2 emissions have accelerated...
- 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...
- A new 2009 paper finds that the cruial assumption in the GCM models used by the IPCC concerning strongly positive feedback from water vapor is not supported by empirical evidence and the feedback is actually negative...
- A new 2009 paper...suggests that solar variability could account for up to 68% of the increase in Earth's global temperatures...
...these are just a few of the new developments since 2006...the extensive portions of the EPA's Endangerment TSD which are based upon the old science are no longer appropriate and need to be revised...

But the science doesn't really matter - "the administration has decided to move forward on endangerment..."

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