1. An amalgamation of government agency comments sent from the Office of Management and Budget to the EPA earlier this year is in stark contrast to the official position presented by President Barack Obama and his Cabinet officials.Among other warnings (see below), the memo says the basis for the EPA's statement that greenhouse gases "overwhelmingly" endanger public health and welfare because they contribute to global warming was "especially weak." The report says that predictions of devastating climate change are "accompanied by uncertainties so large that they potentially overwhelm the magnitude of the harm." Here are some more points from those memos as posted on the Senate's Committee on Environment and Public Works web site yesterday.
OMB Memo: Serious Economic Impact Likely From EPA CO2 Rules
WASHINGTON (Dow Jones)
U.S. regulation of greenhouse gases such as carbon dioxide "is likely to have serious economic consequences" for businesses small and large across the economy, a White House memo warned the Environmental Protection Agency earlier this year.
The nine-page document also undermines the EPA's reasoning for a proposed finding that greenhouse gases are a danger to public health and welfare, a trigger for new rules.
...
Cabinet officials, including the president's climate-change czar, Carol Browner, have said the administration would prefer Congress create greenhouse-gas regulations through legislation, and not through the EPA's Clean Air Act authority.
But the White House has given the EPA the green light to move ahead with regulation under the Clean Air Act, a move deemed by some analysts as political leverage to push Congress to act because of the bluntness of the tool.
According to government records, the document was submitted by the OMB as comment on the EPA's April proposed finding that greenhouse gases are a danger to public health and welfare, a key trigger for regulation of the gases emitted from cars, power plants, and potentially any number of other sources, including lawn mowers, snowmobiles and hospitals.
While business groups have warned about the potential for a cascade of regulation and litigation, the EPA has said that greenhouse-gas rules would only be for large emitters.
The memo - marked as "Deliberative-Attorney Client Privilege" - doesn't have a date or a named author. But an OMB spokesman confirmed it was prepared by Obama administration staff as part of the inter-agency review process of the proposed endangerment finding.
"It's a conglomeration of counsel we've received from various agencies...and it's not indicative of an OMB or administration-wide position," an OMB official said.
OMB spokesman Tom Gavin said, "It's up to the EPA now to consider the various suggestions that were part of the interagency review and make some decisions on which direction they want to move."
The position outlined in the memo is at odds with other White House documents on the proposed endangerment rule, which appear to affirm the EPA's decision to move ahead with the endangerment finding.
"Making the decision to regulate CO2 under the [Clean Air Act] for the first time is likely to have serious economic consequences for regulated entities throughout the U.S. economy, including small businesses and small communities," the OMB document reads.
"The finding should also acknowledge the EPA has not undertaken a systemic risk analysis or cost-benefit analysis," it reads.
The head of the U.S. Chamber of Commerce's environment and regulatory affairs, William Kovacs, said the memo "confirms almost everything we've been saying on the spillover effects of regulating greenhouse gases." He said the OMB legal brief exposes the administration and the EPA to litigation if it finalizes the endangerment finding and begins to regulate greenhouse gases under the Clean Air Act, particularly because it was drafted during the deliberation process.
Although an official within the EPA's Climate Change Division said the agency "considers everything we receive," an EPA spokeswoman couldn't immediately comment on the extent to which memo influenced the drafting of the proposed rule.
Earlier this year, EPA chief Lisa Jackson dismissed concerns raised by groups such as the Chamber and the National Association of Manufacturers, saying, "It is a myth...[that] EPA will regulate cows, Dunkin' Donuts, Pizza Huts, your lawn mower and baby bottles."
The White House legal brief starts by questioning the link between the EPA's scientific technical endangerment proposal and the EPA's political summary. Jackson said in the endangerment summary that "scientific findings in totality point to compelling evidence of human-induced climate change, and that serious risks and potential impacts to public health and welfare have been clearly identified..."
"The finding rests heavily on the precautionary principle, but the amount of acknowledged lack of understanding about the basic facts surrounding [greenhouse gases] seem to stretch the precautionary principle to providing regulation in the face of unprecedented uncertainty," the memo reads.
For example, the memo notes, the EPA endangerment technical document points out there are several areas where essential behaviors of greenhouse gases are "not well determined" and "not well understood."
The OMB memo questions with concern the adequacy of the EPA finding that the gases are a harm to the public when there is "no demonstrated direct health effects," and the scientific data on which the agency relies are "almost exclusively from non-EPA sources."
Based on the "dramatically expanded precautionary principle," the EPA would be petitioned to find endangerment and regulate many other alleged "pollutants," including electro-magnetic fields, noise, and salts called percholorates.
The memo also warns that the endangerment finding, if finalized by the administration, could make agencies vulnerable to litigation alleging inadequate environmental permitting reviews, adding that the proposal could unintentionally trigger a cascade of regulations.
The administration last week avoided requiring permitting reviews that would need to consider the impact of greenhouse gases when it decided not to revoke a Bush administration rule on polar bears. Although the Interior Secretary said greenhouse gases were the primary cause of the bear's loss of sea-ice habitat, the animal's listing as a threatened species couldn't be used to prevent oil refineries and coal-power plants from being built.
The White House, in a tortously written rebuttal, at first appears to be denying the report exists. On closer reading, they seem to be saying "So what? OMB is just reporting that other people have other opinions!" Never fear, the White House knows all and is infallible.
Meanwhile, apparently seeing the writing on the wall, the Obama administration announced that they would prefer a solution through legislation. What a coincidence; the House Democratic leaders said this evening they had reached agreement within their caucus on climate-change legislation that sets easier targets for emissions reductions and renewable-energy requirements than originally proposed. Mr. Waxman told reporters late Tuesday that he has agreed to amend the legislation so that it requires a cut in U.S. greenhouse-gas emissions of 17% below 2005 levels by 2020, rather than a 20% cut in that time frame and to give, rather than sell, a certain percentage of the carbon emission "permits" to various industries.
The madness continues. The Obama administration is next in line to compete on "Dancing With The Stars."
2. A computer programmer/modeler named Dan Hughes has submitted comments to the EPA (see EPA Docket ID No. EPA-HQ-OAR-2008-0508) throwing doubt on the validity of the climate simulations and the science behind them.
"One crucial and necessary first step is that application of Verification procedures have shown that the numbers produced by the software accurately reflect both (1) the original intent of the continuous equations for the models, and (2) the numerical solution methods applied to the discrete approximations to the continuous equations. That is, Verification shows that the equations have been solved correctly. Verification procedures are designed to answer the question, Do the calculated numbers actually satisfy the coded discrete equations and do the solutions of the discrete equations converge to solution of the continuous equations. Neither of these extremely critical properties has been demonstrated for any GCM. None of the GCM codes, and very likely none of any of the enormous number of other computer codes, used in the IPCC processes have been Verified to be correct. Equally important, none of the Journals in which the papers reviewed by the IPCC process are published have editorial policies that require that the software on which papers are based to be Verified.
"All software can be Verified. Objective technical criteria and associated success metrics can be developed and applied in a manner that provides assurances about the correctness of the coding of the equations and their numerical solutions. Lack of Verification leaves open the potential that the numbers from the software are simply results of “bugs” in the coding."
Fatal? Maybe not. But it's one more in a string of evidences that the "science" behind "global warming" is sloppy. Step two, if it turns out that the models can be verified, is to determine if they would have accurately predicted what has happened in the past. From everything I have seen, they do not.
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