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Climate Hustle

Skeptical Science on steroids: the EPA response to 300,000 public comments

Posted on 9 April 2010 by John Cross

Guest post by John Cross

I suspect that it was lost among all the excitement of the hacked CRU e-mails, but on December 7, the US Environmental Protection Agency (EPA) issued a statement (2.4Mb PDF) saying that it had found that “the current and projected concentrations of the six key well-mixed greenhouse gases--carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6)--in the atmosphere threaten the public health and welfare of current and future generations.” While important, this is essentially an administrative procedure - a response to a Supreme Court ruling.

However what is interesting is that last year the EPA requested public comments as part of this process. And did they ever get some - over 300,000 of them. Now a lot were comments saying “well done”, however there were a significant number of comments raising issues about the science to which the EPA was required to respond. Just recently the EPA released its analysis of and response to the questions. The response consists of 11 volumes totalling over 700 pages of detailed discussion of the questions. The document makes for very interesting and informative reading and I would encourage all to have a look. By the way, the original comments / questions are available if you are willing to look hard enough. If I find anything interesting in there, I will post it in the comments.

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Comments

Comments 1 to 25:

  1. On a preliminary skim of the "Petitions for Reconsideration", it is worth noting that all but one petition bases its argument on the so-called "Climategate scandal" (the exception being the Chamber of Commerce, which appears to be making an argument for industry self-regulation against EPA intervention).

    A quick perusal again suggests the petitioners' arguments are the same exaggerations and distortions that may sway Fox News viewers, but the EPA will need to make a considered and logically sound response. When that happens, I suspect it will be a very handy document for us all to read.
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  2. RE#1 nautilus_mr
    I agree.

    Some of the petitions are embarrassing. Looking at the Competitive Enterprise Institute's petition they even include Watts' "study" as part of their argument against the EPA regulating greenhouse gases.

    Just yesterday the vice president of strategy at the Competitive Enterprise Institute did an opinion piece at the Washington Post attacking no not the science but that the EPA is only wanting to regulate greenhouse gases for power and money.

    Maybe he should have stuck to what was written in the petition...but I doubt it would have had the same emotional response as the stories comments show. I just hope these people aren't the voting type.

    There are some big name climate skeptics in these petitions so it may be worth it if one had more time, to categorize the main arguments that the petitions have in common as it could very much gleam the overall strategies of the agencies that produce them. I may have a go on the weekend if I get time.
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  3. Incidentally, I have just sent the EPA an email asking if there was a projected timeline for responses to the petitions. I will let you all know what reply I get.
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  4. Thanks for this post John, I was indeed wondering at the time of publishing in dec 09 , if this would be a "gamechanger"
    Ie , is someone , an organisation or individual ,going to sue a coalburning powerstation or some such, for threatening the health and wellbeing of future generations.
    It certainly would be an educational court case.
    Or is a response from a federal agency to a supreme court ruling
    essentially useless as a basis for prosecution?
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  5. Another quick initial peek into the petition of the Chamber of Commerce p.28, indicates a significant cost for small businesses by referring to a study of the Heritage Foundation.

    In this study it is mentioned that 3 million jobs would be lost by 2029 as direct consequence by referring (ref. 10) to another prior study from the Heritage Foundation as response to the advanced notice of the EPA decision.

    This latter study used a macroeconomic model to make the projection, where they assume the economy grows without major disruptions including "large oil price shocks, untoward swings in macroeconomic policy, or excessively rapid increases in demand". These assumptions are naturally extremely unrealistic.

    Furthermore, it just so happens that Paul Krugman, Nobel Prize winner in macroeconomics, last year at the London School of Economics stated that the last 30 years of macroeconomical models are at least useless. For example, during the first semester the economics student is taught that markets are in equilibrium by supply meeting demand. This notion was disproven by Benoit Mandelbrot already back in 1963.

    Now, if climate models that can explain the past, the present and the future (with known shortcomings) are under intense scrutiny, why would anyone trust wrong macroeconomic simulations based on "no disruptions"?

    Tit-for-tat.
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  6. re: #5

    That is a good point. One of the reasons many attempts to model economies and markets fall short is because they employ models in which all the variables are considered independent. As people like Mandelbrot pointed out, the position of a market or a key variable in an economy today is greatly influenced by the perceptions and beliefs of the participants within the system -all highly dependent on recent activity within the system.

    This means economic models are far less viable than models of physical systems, in which the characteristics and behaviour of the elements in the system do not radically change without notice. There are naturally degrees of certainty about how chemicals interact within a natural system, but there is no sense in which a CO2 molecule will unexpectedly change its behaviour because it suddenly changes its confidence about the behaviour of other molecules.

    I won't go further, because I realise it may be OT, but just thought it was an interesting point..
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  7. nautilus_mr

    As people like Mandelbrot pointed out, the position of a market or a key variable in an economy today is greatly influenced by the perceptions and beliefs of the participants within the system -all highly dependent on recent activity within the system.

    While this is true, it does not limit successfull modeling efforts of economic systems or human behavior in general. For example, I can point you to the publications of Eugene Stanley, Didier Sornette, Albert-Laszlo Barabasi and Dirk Helbing, whom are all physicists.

    As Krugman says:"economists favour beauty over truth" - and I think this is the central problem.
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  8. nautilus_mr #1: Good call. I had not gotten around to looking at the petitions yet; am still working my way through the comments. There is a comment by Steve Mcintyre who bases his argument mostly on the assumption that the IPCC document did not pass peer-review (or was inadequately peer-reviewed) and therefor did not meet the EPAs own guidelines and should not be used as a reference.

    I like John's title and noticed that there was a similarity between the EPA's response and Skeptical Science. However I would call it Skpetical Science on on aspirin. Does the EPA response have its own iPhone App? I think not!

    John (Cross)
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  9. nautilus_mr #1 says: the exception being the Chamber of Commerce, which appears to be making an argument for industry self-regulation against EPA intervention

    Self regulation would be great. But sadly, industry manoeuvers seem to bend towards denialism.
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  10. re #7 Jacob,

    I get what you are saying and thankyou for the references - of those you mention, I have only read Sornette's "Why Stock Markets Crash" - a magnificent book.

    It seems to me the critical issue is that the inherent properties of the systems to be modelled, the object of study, place fundamental constraints on what models can achieve.

    I suspect we agree that one cannot use the particular challenges of economic models in order to attack the possibility of reliable climate modelling.

    - it makes no sense, refusing to eat apples because one has an allergy to oranges!
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  11. Incidentally, I sent the EPA an email asking if there was a time line for responding to the petitions. When I get a reply, I'll let you know (goodness knows how many lunatic emails they have to sift through, so it may take a while).
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  12. FWIW, Rabett Run has been posting a series of the better responses from the EPA response to comments:
    Part 6: how we know warming isn't a result of increased solar output
    part 5: The Roger Pielke Jr. flood-related damage meme
    part 4: why looking at global temperature makes sense
    Part 3: No, it isn't some solar magnetic or solar wind effects
    part 2: global warming is not a result of humidity changes
    Part 1: CO2 concentrations really have risen
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  13. Wow, I've just spent a couple of hours reading some of the response volumes. These are absolute GOLD.

    Lucid, balanced, thorough. Volume 1 spells out clearly that the EPA is obliged to carefully consider every available source -so there is no valid charge that they have relied solely on the IPCC and ignored the sceptics.

    These volumes look like they are among the most comprehensive resources on climate change available. Downloading every volume is one of my best uses of bandwidth for a while!
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  14. There is a lot of time before November and the US electorate changes quickly. If we have a record hot summer and a category 5 hurricane hits the US there will be a lot more concern about global warming than if the summer is cold. I teach High School and I have a lot of students who say "this winter was cold globaly' because here in Florida it was cold. Their notion of "global" means the weather at their house.

    California is concerned about warming becasue they are already short of water. Less rain is forcast for the future. People will start to care when their life is affected more than it is now. The question is: how much more?
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  15. Wow

    Have a look at the level of detail this report goes into. And look at how often the papers cited are seldom from any of the 'usual suspects' who are attacked over climate change.

    Its strength seems to be the scale of it. It's weekness is the scale of it. Too many people are going to glaze over at the scale of the work here.

    Suggestion John (in all that spare time you have). Link many of your sceptic argument rebuttals to corresponding entries in the EPA document.
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  16. Thanks for posting about this. It's mind-boggling how much work has gone into the EPA's response to the comments.

    Reading through several of the sections I was surprised how many comments involved quotes from Plimer's book. Then I noticed that they were all from a single individual (11454.1).
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  17. RE #5:
    Now, if climate models that can explain the past, the present and the future (with known shortcomings) are under intense scrutiny, why would anyone trust wrong macroeconomic simulations based on "no disruptions"?


    This statement is very important because nature is not a static phenomenon.
    There are many factors involved, and any statement should be accompanied by the epilogue "if other factors remain constant."

    Seizing the opportunity, watch a new argument to the skeptic.

    termostato.htm..
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  18. RE #17:

    You're absolutely right, nature is not a static phenomenon. And the best climate models attempt to account for and reproduce the responses of the earth's climate to the varying influences over time, and, IMHO, do a pretty remarkably good job of it.

    Which is exactly why a "no disruptions" economic model is suspect, because, as the events of the past 2 years demonstrate, the global economy is also very far from a static system, and is, in fact, far more volatile than the earth's climate. (I'd hate to think what kind of climate change would be equivalent to the 1929 crash or the GFC - perhaps some of those mass extinctions from ancient prehistory?)

    In any event, I suspect I'll be losing a few evenings to perusing the EPA responses... the ones I've looked at so far are quite well written!
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  19. I've been going through the EPA's responses to the comments and they are excellent. I've been adding bookmarks in the pdf files so as to easily refer back to specific points.

    Most of the issues raised are fairly standard and already covered on SkepticalScience, but if I come across any that aren't I'll add them to your list.
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    Response: When you add them, could you also post a comment here mentioning the argument (perhaps also including the volume and page #)? Would save me a little time in tracking it down in the EPA reports. Many thanks! :-)
  20. Why has this huge amount of useful work had a lot more publicity instead of the storm in a tea cup that was so-called "Climategate"
    Very good to see it being brought to our attention.
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  21. Damn I missed out a "not" after "work" of course!
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  22. @19 - Happy to note the volume and page number. Would you like the bookmarked pdf files? (It will take a while to go through them all.)
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    Response: Whatever is easiest - just posting comments with missing arguments as you go is fine. I downloaded all the PDFs (but not with your bookmarks, of course).
  23. This is OT but I wish to offer KUDOS to John Cook because at a recent Brookhaven National Lab hosted event titled Alan Alda Brings Passion for Communicating Science to Brookhaven Lab, John Cook was hailed as somebody who was doing science messaging the right way!
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    Response: Thanks for the kind words in your blog post, Scott.
  24. Re #18

    "And the best climate models attempt to account for and reproduce the responses of the earth's climate to the varying influences over time, and, IMHO, do a pretty remarkably good job of it."

    But these climate modelers did not predict that the ammonium produced by decomposition of organic matter disperse and waterproofs the clay soil.
    Today, the evaporation of water on the continents is reduced and requiring to the oceans to warm up to replenish the moisture in the air.
    I'm trying to draw attention of the scientific world to this fact.
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  25. By the way, has anyone seen Jo Nova's article on ABC drum? She is spinning up a storm, comments thread well over 350. She is claiming CRU is a white wash... when is the media going to cotton onto to how the deniers exploit the "fair and balanced" approach?
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