I have previously discussed how important it is for the US Environmental Protection Agency to revisit and revoke the EPA Endangerment Finding for Greenhouse Gases issued in 2009. To date the USEPA has not decided to do so. I have suggested how anyone who pays electric bills can petition the USEPA to do this. What follows is a press release by one group that recently sent a supplement of an earlier petition. This supplement reflected primarily new 2017 research and provides the necessary new research results that justify a revisit and revocation. I do not know for sure whether others have submitted such petitions with a somewhat similar basis other than one from the Competitive Enterprise Institute and the Science and Environmental Policy Project on February 17 (as updated February 23), which was previously published by Inside EPA. In addition, the Texas Public Policy Foundation has recently submitted a Petition to EPA based on a different basis.
Key Points of New Press Release:
1. Just released, with even more definitive research findings that make it even more certain that CO2 is not a pollutant but rather a beneficial gas that should not be regulated.
2. If the Endangerment Finding is not vacated, whether the current administration likes it or not, it is certain that electric utility, automotive and many other industries will face ongoing EPA CO2 regulation.
3. This scientifically illiterate regulation will raise energy prices thereby reducing U.S. economic growth and jobs.
Press Release
The Concerned Household Electricity Consumers Council announces that on May 8, 2017 it filed with EPA a Supplement to the Council’s January 20, 2017 Petition asking the Agency to reconsider the scientifically invalid Endangerment Finding on which all Obama-era greenhouse gas regulations are based. The Supplement may be found here.
The Council’s original Petition demonstrated that the Endangerment Finding is nothing more than assumptions that have each been disproved by the most relevant empirical evidence from the real world. The original Petition was substantially based on a major peer-reviewed 2016 scientific paper by James Wallace, John Christy and Joseph D’Aleo (Wallace 2016) that analyzed the best available temperature data sets and “failed to find that the steadily rising atmospheric CO2 concentrations have had a statistically significant impact on any of the 13 critically important tropical and global temperature time series data sets analyzed.” The full text of Wallace 2016 may be found here.
The Supplement to the Petition now brings to the attention of EPA new developments, since the date of the Petition, that render the invalidation of the Endangerment Finding yet more definitive. First among the new developments is a new extensively peer reviewed April 2017 Research Report, also from Wallace, Christy and D’Aleo (Wallace 2017). Wallace 2017 can be found here.
Wallace 2017 takes a totally different analytical approach than Wallace 2016, and specifically estimates the impacts of the key natural factors, including solar, volcanic and oceanic/ENSO activity, on tropical and global temperatures. It concludes that once these natural factor impacts on temperature data are accounted for, there is no “natural factor adjusted” warming remaining to be attributed to rising atmospheric CO2 levels. That is, these natural factor impacts fully explain the trends in all relevant temperature data sets over the last 50 or more years. This research, like Wallace (2016) found that rising atmospheric CO2 concentrations did not have a statistically significant impact on any of the (14) temperature data sets that were analyzed. At this point, there is no statistically valid proof that past increases in atmospheric CO2 concentrations have caused what have been officially reported as rising, or even record setting, temperatures.
The Supplement to the Petition also demonstrates the improper use of Climate Models relied upon by EPA in the attribution of warming to human–related CO2 emissions. Court records make it very clear that the premise of using climate models in attribution is that such models are properly validated, provide reliable forecasts, and are unable to reproduce observed warming without the additional forcing from anthropogenic Green House Gases (GHGs). Wallace (2016) and Wallace (2017) both independently demonstrate that this premise is false. Both reports show that natural factors alone explain all the warming. Conversely, climate models show a pattern of warming in the tropical troposphere that simply does not exist in nature-–the Missing Tropical Hot Spot. Thus, the climate models have been invalidated and cannot be relied upon by EPA for attribution analysis in its Endangerment Finding. Therefore, simple but insistent logic precludes the use of invalidated climate models to attribute warming to human emissions of GHGs, and requires reconsideration of the Endangerment Finding.
The Supplement to the Petition also puts in the record before EPA information from the March 29, 2017 testimony of John Christy before Congress which also dealt with the Missing Tropical Hot Spot issue. Dr. Christy’s Congressional testimony showed that the temperature trend, projected by climate models on which EPA relies, differs from the actual trend of observations at the 99% confidence level. Thus, the models used by EPA to conclude that greenhouse gases pose a “danger” to human health and welfare have failed a simple “scientific method” test. They have been invalidated.
The scientific invalidity of the Endangerment Finding becomes more blindingly obvious and undeniable with each day’s accumulation of empirical data. It is time for an honest and rigorous scientific re-evaluation of this Obama-era political document. The Nation has been taken down a tragically foolish path of pointless regulations and wasteful mal-investments to “solve” a problem which does not actually exist. Our leaders must summon the courage to acknowledge the truth and act accordingly.
The Council brought its Petition because the Obama-era greenhouse gas regulations threaten, as President Obama himself conceded, to make the price of electricity “skyrocket.” All Americans will benefit from a new era where the cheapest sources of energy can also compete and prevail in the marketplace.
[…] Council Calls on Trump to Revoke the Scientifically Invalid CO2 Endangerment Finding […]
[…] Council Calls on Trump to Revoke the Scientifically Invalid CO2 Endangerment Finding […]
The clean air specifically addresses “toxic” pollutants and produces a list of some 600? toxic chemicals that end up in the air. These chemicals and their reaction products in the atmosphere caused by light and ozone all have established toxic levels that can be measured and toxic effects in the atmosphere. The classic London Smog and the Donora PA smog clearly made many people sick and directly killed people in large numbers.
CO2 does not have any of the characteristics of a toxin. It causes no lasting health effects even at levels that are hazardous. People can recover from an overdose with no long term effects. It doesn’t accumulate in the body. And it is a required nutrient for all green plants on earth. Current levels are only somewhat more than twice the level where green plants start to die and geology indicates that in the past CO2 levels have been 3-10 times current levels while supporting huge quantities of life.
Another comment asks,
“Should Pruitt thoroughly review the endangerment finding or should he just change on [sic] variable, like the discount rate, that makes the cost of carbon negative? There would be less to argue with if he just changes one variable to a more reasonable value.”
Wrong. The lie must be removed. CO2 is not a pollutant – the false claim it is must not stay in place.
Just beau,
Interesting way to look at the issue. I am not sure it’s a good idea to leave the EF in place as it has taken 30 years for it to get entangled into the political environment in CA.
Scott Adams’s recent blog post (1) could be a prelude to a post on “Policy Integrity (2)” as I am sure that a lot of CA residents are having a hard time reconciling this policy statement (..”policies are reducing not only GHG emissions, but also energy costs for consumers.”):
“B. Foster Resilient Economic Growth (pg 27)-
……..”Through AB 32 and related policies, California has implemented a suite of policies that is reducing emissions by both reducing energy demand and cleaning up energy supply. Taken together, our efficiency and clean energy policies are reducing not only GHG emissions, but also energy costs for consumers. For example, while the State moves toward 33 percent renewable energy in its electricity supply mix, it continues to outpace the rest of the country on energy efficiency.” (3)
with their ACTUAL costs to accomplish activities.
Scott earlier noted that it’s the economic models that are being used to define what should be done and when in regards to the risks of the climate change. Scott has likely already talked to folks at the LADWP about their concerns in regards to the assumptions in economic models(4)-
ristvan comment last year on the CIC’s real goals seems spot on to me (5).
Nationally the EF has to go as we have the interstate clause that has to be dealt with……
1) http://blog.dilbert.com/post/160989114746/the-time-i-nudged-climate-scientists-into
2) “Policy Integrity regularly conducts economic and legal analysis on the appropriate use of the social cost of carbon, among other environmental and economic topics.” https://www.arb.ca.gov/lists/com-attach/160-scopingplan2030-USEHblY7BT9XMlcu.pdf
3) http://www.arb.ca.gov/cc/scopingplan/2013_update/first_update_climate_change_scoping_plan.pdf pg 27
4) https://www.arb.ca.gov/lists/com-attach/156-scopingplan2030-BmoGYVw5VHBWIAdY.pdf pg 13
5) ristvan | March 28, 2016 at 5:38 pm- https://judithcurry.com/2016/03/28/paris-agreement-a-risk-regulation-perspective/#comment-775344
Could someone, anyone explain why Congress does not simply issue an amendment to the CAA that for the purposes of the Act CO2 can not be considered “a pollutant”.
Wouldn’t that solve the problem?
Should Pruitt thoroughly review the endangerment finding or should he just change on variable, like the discount rate, that makes the cost of carbon negative? There would be less to argue with if he just changes one variable to a more reasonable value.
Climate change was an epic lunacy and cynically self interested political narrative.
There is no good reason not to rebut and repudiate the endangerment finding in due course.
Keep up the pressure, Doc!
There may be political rationales for keeping endangerment around. It may be needed for republicans to compete in purple districts.
Keeping endangerment keeps democrats in places like California impaled on allegiance to climate change. Climate change does a lot of damage to democrats and they may fare better when they are rid of the burden of championing it and instead compete on grounds of improving the economy.