Scott Pruitt is Dead Right: EPA Never Seriously Considered the Science Used in Its 2009 GHG/CO2 Endangerment Finding

Last week I reported on a petition signed by over 60 climate experts (others can still do so) asking EPA Administrator Scott Pruitt to reopen EPA’s GHG Endangerment Finding (EF). Late in the week it was reported that he had stated that:

“This is the first time in history that this ever occurred. This Agency took work product of the UN International Panel on Climate Change and adopted it, and transferred it to this Agency, and used it as the basis, underpinnings, of the Endangerment Finding. That had never happened. It happened in months, by the way. This Agency doesn’t build a record in months with respect to these kinds of issues.

“So it really draws down into [this] question: Did this Agency engage in a robust, meaningful discussion, with respect to the Endangerment that CO₂ poses to this Country? And I think by any definition about process they didn’t.” —Scott Pruitt in interview with Justin Worland of Time Magazine, as reported on October 20, 2017 and transcribed here.

Based on my experience as a Senior Analyst at EPA actively involved in understanding climate alarmism and reviewing the basis for the Endangerment Finding at the time the EF was adopted, Administrator Pruitt is correct. EPA never engaged in a robust, meaningful discussion. Rather, there was a pro forma review after a decision had already been made which met many but not all of the legal requirements. Deadlines were always set a few days ahead at each step in the process and there was a strong presumption in favor of climate alarmism rather than an impartial, science-oriented discussion appropriate to the Agency’s responsibilities under the Clean Air Act. This was all too evident in the Agency’s treatment of my critical scientific comments, which were never seriously considered. The proposed Endangerment Finding was never referred to the EPA Science Advisory Board. The clear intent was to push it through without regard to its scientific merits.

Here are six crucial scientific issues that EPA did not actively discuss despite my best efforts to bring a few of them to their attention in early 2009:

1. Bottom Up GCMs Used by Alarmists Prove Nothing. The principal justification offered by climate alarmists for their beliefs is that by using bottom up general circulation models (GCMs) they believe they can predict how the climate as a whole will operate by considering how they believe it operated in a large number of individual geographic grid cells. They claim that the models show that global temperatures are primarily determined by atmospheric CO₂ levels. These GCMs are modified weather models, which generally are not valid and therefore not useful much beyond two weeks because of the chaotic nature of climate. But the alarmist model builders claim that they can usefully run these models over periods of decades or even centuries and get valid results.

But even the UN IPCC admits that climate is a coupled, non-linear chaotic system which cannot be usefully modeled beyond a few weeks’ time. To make matters worse, their models are primarily based on the conclusions they are trying to justify–that human-caused CO₂ emissions will result in catastrophic global warming. The models are useless for the justification purposes for which they were built and prove nothing except that some “scientists” are more than willing to waste other people’s money on very expensive and irrelevant models proving nothing. In recent years the GCMs have proved much too “hot” in their forecasts of future temperatures, as pointed out by John Christy and others and even by a recent paper by the climate alarmists themselves. I am not alone in my conclusions; one skeptic, Pat Frank, using different but related reasoning reached these conclusions a few years ago:

Climate modelers are not scientists. They are not doing science. Their climate model projections have no physical meaning. Their climate model projections have never had any physical meaning.

Unfortunately, many people are impressed by big computer models and those that write them; they do not understand them and take this approach seriously, which only proves that garbage fed into a large computer model yields garbage out.

2. The Few Available Top Down Studies Conclude that Observed Climate Change since 1960 Can Be Explained by Natural Factors. The bottom up computer modeling could never produce valid results and has always been a waste of time and effort despite the expenditure of billions of dollars by various national governments and the UN. In very recent years a very different, top down approach has been tried by a few researchers; so far the results have been exactly the opposite of the alarmist models–that CO₂ levels have no significant effects on global temperatures; changes in global temperatures since about 1960 can be fully explained by known natural factors. Unlike the bottom up approach, there is no inherent reason that these results are not valid, and they appear to explain the observed behavior of the climate system using robust statistical tests. But this top down approach appears to have never been used by climate alarmists. The findings of (2) further rule out (1) as a justification for climate alarmism. The study and its predecessors disprove the basic three lines of evidence used as the basis for the Endangerment Finding.

3. Earth Has a Very Extensive Natural Temperature Control System which Rules Out the Alarmists’ Predicted Catastrophic Temperature Increases. There is substantial evidence that Earth has a very effective natural temperature control system that continuously and automatically keeps down temperatures, particularly near significant bodies of water due to the very unusual properties of the water molecule. This makes it impossible that there can be any substantial increase in temperatures in tropical areas (where much of the heat from the sun enters the climate system) near water, and hence no danger of the catastrophic increases predicted by the alarmists. And most of Earth’s surface is water. The temperature control system includes a number of emergent climate phenomena, including clouds, thunderstorms, tornadoes, monsoons, hurricanes, ocean currents, and coastal fog. The steadily increasing radiation from the sun during the existence of the Earth has a far stronger effect on Earth’s temperature balance than the very minor alleged effects of higher CO₂, but Earth’s temperatures have been decreasing on balance over its lifetime. This appears to be best explained by Earth’s temperature control system that prevents Earth’s temperatures from increasing (but not from decreasing), particularly in tropical areas near abundant water.

In some cases the temperature control system redistributes heat from high to low temperature areas (example: ocean currents). In other areas it prevents heat from entering the climate system (example: clouds). In other cases it actually increases the radiation of heat out of the climate system (example: thunderstorms). Since these emergent climate phenomena exist, catastrophic increases in global temperatures appear to be impossible as long as they do.

4. The Alarmists’ Whole Approach Ignores the Effects of Earth’s Temperature Control System. It only deals with “forcings” allegedly resulting from higher CO₂ levels as if the Earth had no natural temperature control system. To prove their conclusions it must be shown that whatever temperature increases may result from higher levels of CO₂ are not dissipated by Earth’s temperature control system in such a way as to negate the temperature increasing effects of these alleged forcings. So unless it can be shown that CO₂ decreases the effectiveness of the temperature control system CO₂ increases would be largely if not totally irrelevant. The alleged added heat generated by higher atmospheric CO₂ is simply dissipated by one or more of the temperature control system’s emergent climate phenomena. This has rarely if ever even been discussed by climate alarmists let alone proved not to be the case.

5. Their Basic Hypothesis Does Not Satisfy the Scientific Method since reasonable inferences based on their key alarmist hypothesis can be shown to be false.

6. Numerous Other Significant Inconsistencies between climate alarmist science and real world observations; there are so many, in fact, that very extensive books have been written about them by distinguished scientists and carefully reviewed by numerous experts.

None of this was seriously discussed when the Endangerment Finding was approved in great haste and little serious discussion in 2009. Clearly it is long past time for the robust, meaningful discussions that Administrator Pruitt and most skeptics believe are necessary. Altering our entire way of life at monumental costs, negative benefits, and no meaningful discussion are simply not a prudent course for public policy and will result in enormous losses for taxpayers, ratepayers, and the nation unless EPA or the courts change the Obama Administration’s Endangerment Finding. The Trump Administration is trying to reduce the impact of the Obama CO₂ emission reduction regulations but could be much more effective and efficient about it by reopening the Endangerment Finding and making the needed robust, meaningful discussion part of the proceedings.