The Trump Administration has been rolling out Executive orders on a daily basis to implement many of President Trump’s campaign promises. These include a number of orders related to environmental and energy policy. But possibly because Trump never made any promises related to revoking the USEPA Greenhouse Gas (GHG) Endangerment Finding (EF), there has been no public announcement of any proposed EPA action on this, the most critical step needed to bring sanity back to climate policy. Even if all of the climate-related EPA regulations promulgated by Obama are revoked or otherwise changed, more such regulations can be promulgated in the future as long as the GHG Endangerment Finding remains in effect.
So the thing to watch is whether EPA makes any move to revoke the Finding. Although the revocation of a number of the EPA climate regulations is a good first step, only if and when EF revocation occurs can the profound risks posed by climate alarmism be said to have passed in the US. As discussed previously, the risks arise not from the alleged climate change fears raised by the climate alarmists but rather from their ill-founded, useless, and horrendously expensive measures to reduce human carbon dioxide (CO2) emissions. This has always been the only serious risk and what must be avoided if the US and the developed world is to have a prosperous future that will allow humans to have access to the fossil fuel-generated energy needed for continued economic progress and improved human welfare and if plants are to not to lose partial access to one of their basic nutrients (assumming CO2 emissions reductions have any real effects on atmospheric CO2 levels) .
I have previously described one possible route to encouraging USEPA to undertake such an EF revocation that I have been involved in. But there are many others depending on the arguments used to invalidate the current EF. Although my name is included as one of the authors of the TSD for the present EF, apparently for historical reasons (explained here), there are many reasons why I believe it should be revoked as soon as possible. The reasons I used are explained in the letter I co-signed last fall, but many others can be found in my book, Environmentalism Gone Mad, as well as numerous previous posts on this blog.
EPA’s Three Lines of Evidence
The basis for the EPA’s GHG Endangerment Finding is their three lines of evidence, as found in the EPA EF Technical Support Document (page 47):
- The attribution of observed climate change to anthropogenic activities is based on multiple lines of evidence. The first line of evidence arises from the basic physical understanding of the effects of changing concentrations of GHGs, natural factors, and other human impacts on the climate system. The second line of evidence arises from indirect, historical estimates of past climate changes that suggest that the changes in global surface temperature over the last several decades are unusual (Karl et al, 2009). The third line of evidence arises from the use of computer-based climate models to simulate the likely patterns of response of the climate system to different forcing mechanisms (both natural and anthropogenic).
So citizens who pay electricity bills or are otherwise adversely affected by the EF and wish to encourage revocation can petition the USEPA to do so, preferably using evidence that EPA’s three lines of evidence are invalid. For detailed suggestions on preparing such a petition see my comments on a comment to this post at the end of the post.
It is my understanding that the endangerment finding was based on science that did not meet the EPA requirements in several respects. The supreme court ruling did not address the science except tangentially stating that if the EPA correctly found that CO2 was endangering the people of the US the EPA had to address it. But there was no follow through to check the analysis methods or conclusions of the endangerment finding. I think an internal review of the documents and analysis that led to the finding would conclude that it didn’t follow required protocol and should be revoked until it passes the correct review procedure.
Could you please address this thought Dr. Carlin?
Comments by Alan Carlin:
I agree. In my view, EPA should have followed the Office of Management and Budget (OMB) requirements for review of “highly significant scientific assessments.” This was the view of the EPA Inspector General’s Office as well, but EPA claimed that the Technical Support Document (TSD) for the Endangerment Finding (EF) was merely a summary of the findings of other groups, and chose not to follow the OMB “highly significant” requirements. Added details and references can be found in my book, Environmentalism Gone Mad, on pages 116-7. I believe that the EF should be revoked not just for failure to follow the required review procedures but permanently because EPA’s “three lines of evidence” presented in the TSD are all invalid. I pointed out some of this in my comments on the TSD, but a recent study confirms this for all three. Much of this science is also explained in the letters to EPA I signed last fall.
Please advise names/addresses (snail and email) of the persons who should be getting the petition. And I think our elected representatives and senators should be petitioned as well.
Thanks.
Comment by Alan Carlin:
I believe the best recipient is the EPA Administrator. The new one has not been confirmed as yet, so I would suggest the following recipient:
Ms. Catherine McCabe
Acting Administrator
U.S. Environmental Protection Agency (Mail code 1101A)
1200 Pennsylvania Avenue, N.W.
Washington, DC 20460
I would also suggest using postal mail rather then Email. Your letter should preferably be in the form of a petition to EPA rather than a normal letter since this is actually a legal document. And it would be good to mention the basis for your legal standing (probably paying electric bills). As I understand it, elected representatives are of little help in this case. It would be more reasonable for elected representatives to prohibit EPA use of the Clean Air Act to regulate greenhouse gases (thus overturning the Supreme Court decision in Massachusetts vs. EPA), but there may not be enough votes for this currently.
For many examples of the general petition to EPA format see here. The content would not be the same, but they are usually drafted by lawyers and show how it’s done. My earlier effort last fall was written by a lawyer and contains all the technical points, but was not in petition format.