Conclusions from suppressed EPA report on CO2 Endangerment

[TimBikes]

The EPA is in the process of determining whether CO2 should be regulated as a dangerous pollutant under the clean air act. Their own researchers produced a 98 page report that was critical of such a finding. Unfortunately for science, the EPA has suppressed the report under political pressure. Just what does the suppressed report conclude?

“The current Draft TSD is based largely on the IPCC AR4 report, which is at best three years out of date in a rapidly changing field. There have been important developments in areas that deserve careful attention in this draft.” Then the report goes on to list specific problems with the IPCC driven interpretation of climate change, including:

• Global temperatures have declined—extending the current downtrend to ll years with a particularly rapid decline in 2007-8; in addition, the PDO [Pacific Decadal Oscillation] went negative in September, 2007 and the AMO [Atlantic multidecadal Oscillation] in January, 2009, respectively. At the same time atmospheric CO2 levels have continued to increase and CO2 emissions have accelerated.
  
  
• The consensus on past, present and future Atlantic hurricane behavior has changed. Initially, it tilted towards the idea that anthropogenic global warming is leading to (and will lead to) to more frequent and intense storms. Now the consensus is much more neutral, arguing that future Atlantic tropical cyclones will be little different that those of the past.
  
  
• 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.
  
  
• One of the worst economic recessions since World War II has greatly decreased GHG emissions compared to the assumptions made by the IPCC. To the extent that ambient GHG levels are relevant for future global temperatures, these emissions reductions should greatly influence the adverse effects of these emissions on public health and welfare. The current draft TSD does not reflect the changes that have already occurred nor those that are likely to occur in the future as a result of the recession. In fact, the topic is not even discussed to our knowledge.
  
  
• A new 2009 paper finds that the crucial assumption in the GCM models used by the IPCC concerning strongly positive feedback from water vapor is not supported by empirical evidence and that the feedback is actually negative.
  
  
• A new 2009 paper by Scafetta and West suggests that the IPCC used faulty solar data in dismissing the direct effect of solar variability on global temperatures. Their research suggests that solar variability could account for up to 68% of the increase in Earth’s global temperatures.
  
  

They then say: "These six developments alone should greatly influence any assessment of ‘vulnerability, risk, and impacts' of climate change within the U.S. But these are just a few of the new developments since 2006.”



The report also notes other important inconsistencies between the temperature and other scientific data and the GHG/CO2 hypothesis and suggests that these inconsistencies would need to be carefully explained for the draft TSD to be credible. They state:

• (A) By far the best single explanation for global temperature fluctuations is variations in the PDO/ENSO. ENSO appears to operate in a 3-5 year cycle. PDO/AMO appear to operate in about a 60-year cycle. This is not really explained in the draft TSD but needs to be, or, at the very least, there needs to be an explanation as to why OAR believes that these evident cycles do not exist or why they are much more unimportant than we believe them to be.
  
  
• ( B )There appears to be a strong association between solar sunspots/irradiance and global. temperature fluctuations. It is unclear exactly how this operates, but it may be through indirect solar variability on cloud formation. This topic is not really explored in the Draft TSD but needs to be since otherwise the effects of solar variationsmay be misattributed to the effects of changes in GHG levels.
  
  
• (C) Changes in GHG concentrations appear to have so little effect that it is difficult to find any effect in the satellite temperature record, which started in 1978.
  
  
• (D) The surface measurements (HADCRUT) are more ambiguous than the satellite measurements in that the increasing temperatures shown since the mid-1970s could either be due to the rapid growth of urbanization and the heat island effect or by the increase in GHG levels. However, since no such increase is shown in the satellite record it appears more likely that urbanization and the UHI effect are the most likely cause. If so, the increases may have little to do with GHGs and everything to do with the rapid urbanization during the period. Given the discrepancy between surface temperature records in the 1940-75 and 1998-2008 and the increases in GHG levels during these periods it appears even more unlikely that GHGs have much effect on measured surface temperatures either. These points need to be very carefully and fully discussed in the draft TSD if it is be scientifically credible.
  
  
• (E) Hence it is not reasonable to conclude that there is any endangerment from changes in GHG levels based on the satellite record, since almost all the fluctuations appear to be due to natural causes and not human-caused pollution as defined by the Clean Air Act. The surface record is more equivocal but needs to be carefully discussed, which would require substantial revision of the Draft TSD.
  
  
• (F) There is a strong possibility that there are some other natural causes of global temperature fluctuations that we do not yet fully understand and which may account for the 1998 temperature peak which appears on both the satellite and surface temperature records. This possibility needs to be fully explained and discussed in the Draft TSD. Until and unless these and many other inconsistencies referenced in these comments are adequately explained it would appear premature to attribute all or even any of what warming has occurred to changes in GHG/CO2 atmospheric levels.
  
  

These inconsistencies are so important and sufficiently abstruse that in our view EPA needs to make an independent analysis of the science of global warming rather than adopting the conclusions of the IPCC and CCSP without much more careful and independent EPA staff review than is evidenced by the Draft TSD.

As discussed in these comments, we believe our concerns and reservations are sufficiently important to warrant a serious review of the science by EPA before any attempt is made to reach conclusions on the subject.

No wonder the report was suppressed.

[robbyr2]

Well, I'm sure the story isn't over. Famously dim-witted Sen Inhofe is going to investigate why the EPA suppressed a "report" (read non-scientific BS) by some $80K a year EPA economist. His supervisors think he should stick to his job which is the "science" of economics. Sounds good to me.

[chogan2]

Intelligent readers may want to see the actual story. Starting with the fact that it wasn't suppressed. Continuing with the fact that (as noted above) the lead writer is an economist (as am I), and neither author is a climate scientist. Followed by the fact that "the report" did not meet the EPA's standards of accuracy (read: it's wrong on the facts).

RealClimate

Or just go read the report and see what you think. If the first paragraph of the preface is not enough to convince you that the authors are not merely fully of baloney, but are true loose cannons, then you've probably never written an official US government publication. Basically, they start the report by saying, oh, man, the EPA is going to be in real trouble if all this science turns out to be wrong.

http://cei.org/cei_files/fm/active/0/DOC062509-004.pdf


My favorite, from the executive summary (ie., important enough be listed as a significant finding):

"Finally, there is an obvious logical problem posed by steadily increasing US health and welfare measures and the alleged endangerment of health and welfare in this draft TSD during a rapid rise in at least C02 ambient levels. This discontinuity needs to be carefully explained in the draft TSD or the conclusions changed."

In other words, because rising C02 levels have not yet caused enough of a problem to offset all other technology-driven gains in health and welfare, we should not judge that rising C02 levels will cause a problem in the future. That's pretty stupid no matter how you slice it. Just from a standpoint of logic. And, apparently, the authors not only did not realize the ill-logic of that statement, they were sufficiently proud of that line of reasoning that they offered it as the conclusion of the executive summary.

But sometimes it's the little things that tell you the most. The posted draft has the date carefully redacted on the title page. But the footer of every other page clearly shows the date. Do you really want to take your advice on climate change from people who take the time to ink out the date at the top of the page, but somehow don't notice that the date is printed at the bottom of all the other pages?

Get a grip, folks. On the one hand, you have governments of countries across the globe, researchers at top universities, a broad and deep body of peer-reviewed scientific literature, and so on and so on. And the best the opposing viewpoint can do is to tout stuff like this? If all you can do is scrape the bottom of the barrel, it's a pretty good sign that the barrel is empty.

[Shawn Clark]

The preface is hilarious. It says in effect, "We've got nothing, but decided to make some noise." These clowns are completely outside their discipline yet aggressively pushing their own theories, pretty much standard example of arriving at an answer then arranging information to support that answer--reality be damned.

The best pages in the report are labeled: "This page intentionally left blank."

[TimBikes]

Ah - the dimwits on the left have spoken. They can't argue with the factual issues raised in the report so they do the usual - ad hom attacks.

FYI, the report was co-authored by two researchers within EPA - one who has written extensively on environment and public policy issues since the 1960s and the other who is an environmental scientist at EPA. The report was indeed quashed as these emails indicate:

"...the administration has decided to move forward on endangerment and your comments do not help the legal or policy case for the decision." ... "I can only see one impact of your comments given where we are in the process, and that would be a very negative impact on our office."

Just like you guys - the EPA administrators do not dispute the factual data in the report, only that it would make things difficult for them since "endangerment" is already a foregone conclusion based on the political mandate from above. Talk about an "inconvenient truth"!

[Politburo]

What factual information in the report? None of it is new, and has been previously debunked.

The report was not "quashed". An endangerment finding represents the consensus of EPA scientists. It doesn't mean that they all agree 100%, and not every viewpoint will get represented in the finding. I'm sure there are some scientists at EPA who felt they could have gone further than what was published, or otherwise disagree with some parts of the finding.

[chogan2]

Originally Posted by TimBikes

Ah - the dimwits on the left ... ad hom attacks.

Whereas calling me a dimwit, that's not an ad hominem attack.

First, I cited the excellent discussion of the content of the report given on Realclimate.org. That's a critique by real, actual climate scientists, and is more informed than anything I could offer. Intelligent readers should be able to go there and follow the links for a detailed analysis of the content.

Second, I cited an argument from the paper that I could readily understand, one that I think is obviously false on its face. So, if you have more to offer than ad hominem attacks, defend what the authors literally said in the final paragraph of their executive summary, as cited above.

Third, I may not be a climate expert, but I am very much a researcher. The authors of the paper clearly are not, and clearly do not do proper research here.

Let me give you an example.

The issue of water vapor/cloud cover feedback is a key unresolved uncertainty in general circulation models. It was highlighted by the IPCC and has been the topic of fairly intensive investigation for the past decade at least. There's not much uncertainty about water vapor, but lots of uncertainty about clouds. There are hundreds of peer-reviewed articles relevant to this issue.

Out of that entire body of literature, the author chose to cite exactly one (1) peer-reviewed empirical analysis (Paltridge 2009) as the basis for the conclusions of that section of the paper. At least, that's the only empirical study of atmospheric water vapor that I see in that section of the report.

So, just to be clear here, for those of you who don't do research for a living, the right thing to do would be to review the entire broad and deep existing literature. Or at least gloss one of the existing reviews in this area.

The EPA paper, by contrast, takes one study and ignores everything else.

But did they even do that correctly? Nope. Their conclusion is vastly stronger than the conclusion that the authors of the scholarly paper in question. What the authors of that empirical study said was: we know that radiosonde data on upper atmosphere humidity are unreliable, but we took it at face value, and when we did that, it disagrees with the existing satellite-based measurements. (And, incidentally, pretty much all of the other research out there.) But if it were true, that would be important -- and here's the key part, here's what they actually concluded -- so it might be worthwhile for somebody to go back and clean up that data and see how it looks once all the existing known artifacts are removed.

Don't believe me? I've copied the abstract of their article below. Read the last line of the abstract.

That's all the authors of that peer-reviewed paper were willing to conclude. Which is quite reasonable, and, really all they could conclude in a peer-reviewed journal, because their finding is at odds with pretty much all the other research in this area.

The upshot is that the EPA staffers made a whole lot more out of that than the actual researchers did. Exaggerating the findings of a single study is simply not proper research. It's not research at all, not as I know the term.

Here, below is the abstract of Paltridge 2009, which, as I said, appears to be the sole piece of peer-reviewed empirical evidence they cite when questioning the feedback effects of water vapor. (Not even clouds, mind you, where there is significant uncertainty, water vapor.)

"The National Centers for Environmental Prediction (NCEP) reanalysis data on tropospheric humidity are examined for the period 1973 to 2007. It is accepted that radiosonde-derived humidity data must be treated with great caution, particularly at altitudes above the 500 hPa pressure level. With that caveat, the face-value 35-year trend in zonal-average annual-average specific humidity q is significantly negative at all altitudes above 850 hPa (roughly the top of the convective boundary layer) in the tropics and southern midlatitudes and at altitudes above 600 hPa in the northern midlatitudes. It is significantly positive below 850 hPa in all three zones, as might be expected in a mixed layer with rising temperatures over a moist surface. The results are qualitatively consistent with trends in NCEP atmospheric temperatures (which must also be treated with great caution) that show an increase in the stability of the convective boundary layer as the global temperature has risen over the period. The upper-level negative trends in q are inconsistent with climate-model calculations and are largely (but not completely) inconsistent with satellite data. Water vapor feedback in climate models is positive mainly because of their roughly constant relative humidity (i.e., increasing q) in the mid-to-upper troposphere as the planet warms. Negative trends in q as found in the NCEP data would imply that long-term water vapor feedback is negative—that it would reduce rather than amplify the response of the climate system to external forcing such as that from increasing atmospheric CO2. In this context, it is important to establish what (if any) aspects of the observed trends survive detailed examination of the impact of past changes of radiosonde instrumentation and protocol within the various international networks."

In other words, the Paltridge et al acknowledge that the radiosonde data are unreliable for this use ("treated with great caution"), that they didn't screen the data ("face value"), that their measurements are at odds with the satellite measurements ("largely (but not completely) inconsistent with satellite data"). And their conclusion is that because of this, it would be worthwhile for somebody to look at the radiosonde data in detail (the last line of the abstract).

Is this a good enough critique of the quality of the "suppressed" EPA report? It is not worth looking at in any further detail.

Oh, hell, might as well address the "suppression" issue. Can I quote what the EPA said:

"Certain opinions were expressed by an individual [Carlin] who is not a scientist and was not part of the working group dealing with this issue,” said EPA spokesperson Adora Andy. “Nevertheless, several of the opinions and ideas proposed by this individual were submitted to those responsible for developing the proposed endangerment finding. Additionally, his manager allowed his general views on the subject of climate change to be heard and considered inside and outside the EPA and presented at conferences and at an agency seminar. The individual was also granted a request to join a committee that organizes an ongoing climate seminar series, open to both agency and outside experts, where he has been able to invite speakers with a full range of views on climate science. The claims that his opinions were not considered or studied are entirely false.”


You can find a writeup of that at:

http://www.grist.org/article/2009-06...f-suppression/

What they didn't let him do was screw up the real science behind the finding. That's not suppression, that's doing their job.

By the way, back when I worked for a federal legislative branch organization, if one of my papers had ever found its way to the public without the consent of my bosses, I'd have been fired. Period. No excuses. The fact that the EPA needed to have a press conference to deal with the fallout, and is apparently going to have a Senate investigation of it, and this guy still has his job -- that speaks well of the EPA's tolerance for dissent.

Finally, you will note that the "suppressed" EPA document has a cut-and-pasted look to it. Apparently, if the comments on realclimate.org are correct, that's because large sections of it were lifted verbatim from other "denialist" work, without citation as to source. In other words, large sections of this were not, in fact, written by the nominal authors. For a civil servant to do that, in a document intended as formal written comments on a major regulatory action, is way, way outside the rules. Pretty sure that would be actionable (ie., sufficient reason to fire the guy.) Nothing wrong with quoting material but honest research tells you where the quotes are from. Again, if the realclimate.org comments are correct (and by the look of the document, there would seem to be something to that), the fact that he's still employed, after a stunt like that, speaks well of the EPA's tolerance.

[Fibb222]

Tim go back to school! heh!

[SageBrush]

If you want to see suppression of EPA, turn the clock back to the Bush era. Reports that reached the White House were returned to the EPA with writing guidance what to include and what to delete; what to discuss, and what to ignore.

[TimBikes]

Originally Posted by chogan2

Whereas calling me a dimwit, that's not an ad hominem attack.

LOL. Fair enough Chogan - point taken. In any case, it was more intended for robby and shawn but if it will make you feel better, I will retract the comment and offer my apologies to anyone who was insulted.

Now - on to the topic...

As for your original comment - it really made no argument about the empirical data represented in Carlin & Davidson's comments. You simply noted that it was unreasonable to conclude that because CO2 had not caused any damage that it wouldn't (if I recall your summation correctly). Either way (if you are right or Carlin) - it really does not speak to the accuracy of attributing climate change to CO2 whereas other points from their paper do. For instance, as you rightly point out, the uncertainties around clouds/water vapor are quite important.

So let me ask a question - is it reasonable to have an endangerment finding when the behavior of the primary greenhouse gas (water vapor) is so poorly understood? After all, based on GCMs a strong positive feedback mechanism related to water vapor is pretty much required to produce the high levels of future warming projected by the models. Without a strong positive feedback mechanism, any CO2 warming would likely be minor.

That unresolved issue alone should be more than enough to derail a factual finding of endangerment - since the facts are not entirely known. Carlin's other points - whether you believe he should have released them in the manner that he did or not - only raise additional questions of the EPA's integrity in its endangerment analysis.

As the EPA email notes, "the administration has decided to move forward on endangerment"... facts be damned.