“If the EPA were to have done that with the regulations being proposed here … it is quite likely that their original Endangerment Finding would have to be revised and potentially overturned.”
The public comment period for the U.S. Environmental Protection Agency’s (EPA) proposed Standards of Performance for Greenhouse Gas Emissions for New Stationary Sources: Electric Utility Generating Units closed on June 25, 2012. A number of extensive comments were submitted arguing that the basis of the Endangerment Finding—that human greenhouse gas emissions (GHGs) “threaten the public health and welfare of current and future generations”—has become so outdated as to require a thorough re-assessment.
Strong cases were made that the EPA failed to completely consider new and influential scientific results which have a direct relevance to the impact that climate change as a result of human greenhouse gas emissions may have on the public health and welfare. Overwhelmingly, the “missing” science from the EPA’s support documents included evidence that either lessened the certainty that human GHG emissions were behind the observed changes in the climate, or provided examples of positive impacts resulting from climate change on human health and welfare.
It is a recipe for pure waste and unintented consequences if EPA continues to propose regulations based upon static, even outdated, science in a field where the scientific knowledge-base is rapidly evolving. In his public comment to the EPA, the Cato Institute’s Dr. Patrick Michaels neatly described this situation:
[N]o static report can provide long-term guidance as to the nature of climate change and its impacts as this field is constantly evolving under the weight of new scientific findings. Consequently, it is imperative EPA reassess the current scientific understanding on an annual basis, if not continuously. If the EPA were to have done that with the regulations being proposed here (consideration of my comments and Addendum would have been an appropriate place to start) it is quite likely that their original Endangerment Finding would have to be revised and potentially overturned.
Relying on dated and incomplete science in a rapidly evolving environment will almost certainly lead to poor regulations. In the name of science and in the spirit of responsible government, the EPA must revisit the Endangerment Finding before adopting sweeping regulations with potentially enormous economic and social implications.
As a demonstration that, indeed, new science (as well as overlooked or ignored science) can supplant existing science in many important topic areas related to climate change, Dr. Michaels included in his comments to the EPA a draft of a major report that he has been editing which serves as a re-evaluation of the potential impacts of climate change on the United States. Dr. Michaels views his report as an “Addendum” to the 2009 U.S. Global Change Research Program’s “Global Climate Change Impacts in the United States”—a report which synthesizes some 21 reports issued by the USGCRP since the early 2000s.
The final version of Dr. Michaels’ Addendum is planned to be released in late summer or early fall, but in the meantime, the Fourth Order Draft iscurrently available from the Cato Institute’s Center for the Study of Public Science and Public Policy and is well worth a look. It is especially insightful to compare, side-by-side, Dr. Michaels’ Addendum to the original USGCRP report (available here).
In addition to Dr. Michaels’ comment on new science overlooked by the EPA, Peabody Energy Company (the world’s largest private-sector coal company) submitted an extensive and detailed set of comments which included a lot of focus on new science missed by the EPA—science which Peabody argues should require that the EPA reassess their Endangerment Finding.
Anyone would have to be a fool to believe that the EPA actually practices or bases any of its decisions based on scientific facts. It never has and never will.
Absolutely correct! It all started with the decision to ban the use of DDT in 1970. That decision was not based on science, which was unable to determine a link between DDT and eggshell thinning in birds, but on politics. They even admitted that it was a political decision. The EPA is a pseudo-scientific organization and always will be.
I think more significant was The Highway Safety Act and the National Traffic and Motor Vehicle Safety Act, passed in 1966.
The discussion in Congress was whether or not seat belts were a good idea. The discussion was never about whether or not the Constitution enabled the Feds to involve themselves with such. This was landmark, and a million regulations followed. Including banning DDT.
Sorry meant to say. Anyone would have to be a fool to believe that the EPA actually practices science, and or bases any of its decisions based on scientific facts. It never has and never will.
The EPA will not revisit the Endangerment Finding “(i)n the name of science and in the spirit of responsible government” because the EPA agenda is not responsible government but government with more micro-control of its ‘subjects.’
Science has value to the EPA only insofar as it can be used (and abused) to support the agenda. The evidence for this is in the blatant cherry-picking of scientific opinions (aka ‘data’) that backs the agenda and total disregard of conflicting and contrary science.
The EPA has shown itself to be a self-serving bureaucracy pushing a left-wing agenda. It is worse than a complete waste of money, it wastes our economy. We would be well ahead eliminating the EPA, even if we took the money spent on it, and simply burned that money.
I wonder if the current and former environmental wackos working or worked at the EPA are starting to feel pretty stupid in view of the fact that the Goracle’s crusade is imploding?
Some will admit they were duped but most will fade from prominance rather than admit they were had.
The science of climate change is very much on the side of the skeptics yet we now have the worlds biggest carbon tax. You have the EPA. The way we will defeat the tax is not through science, although that will give moral righteousness, it will be by publicising the job losses and adverse effects on the economy. Contempory experience shows there are no upsides to green energy and none to the shutting down of carbon based fuels. The failure of Solandra and similar heavily subsidised green companies upsets voters because of the waste of their taxes more so than them finding they were lied to by the scientists and politicians. The hip pocket is all most voters have the time and inclination to worry about..
Good points.
It’s wishful thinking that the EPA will revisit the Endangerment Finding or lighten up on implementation of GHG rules. They’ve won a court challenge to the finding and have been putting out badly written, poorly conceived environmental regulations as fast as they can. They’ve just finalized a new edition of the GHG rules. If the current administration stays in power, I predict they will do away with the Tailoring rule and put GHG emissions on the same levels as criteria pollutants for Title V and PSD (decreasing thresholds from 75,000/100,000 tpy to 100/250 tons/year). The ensuing mess will be greater than the current PM2.5, mercury, boiler and utility rules combined. I think it would be very difficult to unbreak these eggs and I don’t think Romney would be willing to try it.
So fast that I’ve given up trying to read all the proposals. It just gets confusing when your notes are completely wrong when the final rule comes out, and then it gets challenged and overturned. It’s a complete mess
And Bob, I came to the same conclusion when reading the last edition. That’s what people fail to understand. Obama’s speeches and promises violate the constitution. The rule, on the other hand, does not. It clearly states. In fact, in the section where they proposed flex permits in all but name, it is actually quite explicit that they intend to expand it to all sources. After all, the justification for the tailoring rule was the “step-by-step” process. We start reasonable, and go step by step into the mouth of madness.
This looks a whole lot like Europe in 1937. Government. Run. Amok. Yet the whole shebang running to the tune of a charismatic leader.
One hopes that the shine has come off the Obysmal apple. If all the idiot ‘students’, the black Cargo Cutlers, and the White Guilters stay home in droves due to Hopium fatigue, we may be able to reclaim our country in the name of the Constitution. Then again….
Alert!! Links in the article above do not take you to the url which was intended by the author. Instead, the links go to a 2009 brochure which reviews pro-AGW arguments. The links go here: http://downloads.globalchange.gov/usimpacts/pdfs/climate-impacts-report.pdf BEFORE you change the links back to the intended urls, copy all of your html code from this page and then track backwards to locate the IP address and MAC code of the machine which made the nefarious changes. This will be useful to expose the culprit. This wreaks of climategate. Here’s the paragraph with the changed links. “The final version of Dr. Michaels’ Addendum is planned to be released in late summer or early fall, but in the meantime, the Fourth Order Draft iscurrently available from the Cato Institute’s Center for the Study of Public Science and Public Policy and is well worth a look. It is especially insightful to compare, side-by-side, Dr. Michaels’ Addendum to the original USGCRP report (available here).” The links on Knappenberger’s page in Master Resource have the same problem.
Slow down Bud. There’s no evidence of malfeasance. I’ll ask Chip if the links are as he intended or if he linked the wrong items. There’s no need to assume conspiracy when simple source error will do.
I hope you are right. It seems a highly unlikely error for Chip to make twice.
By the way, I sent a similar alert to Chip.
“unable to determine a link between DDT and eggshell thinning in birds,”
And yet, without DDT, the problem magically vanished.
I’m starting to think that there are only about a half dozen people who do all the talking here.
Seven, now.