PUBLIC SUBMISSION | As of: February 08, 2009 Tracking No. 8070d747 Comments Due: November 28, 2008 |
Docket: EPA-HQ-OAR-2008-0318
Advanced Notice of Proposed Rulemaking for Greenhouse Gases Under the Clean Air Act
Comment On: EPA-HQ-OAR-2008-0318-0117
Regulating Greenhouse Gas Emissions Under the Clean Air Act
Document: EPA-HQ-OAR-2008-0318-0270
Comment submitted by M. R. Fox Ph.D.
September 18, 2008
Gentlemen:
I am submitting this testimony in opposition to the “Advanced Notice of Proposed
Rulemaking for Greenhouse Gases Under the Clean Air Act”,
Document number EPA-HQ-OAR-2008-0318-0117
Docket number EPA-HQ-OAR-2008-0318.
For the sake of completeness and minimal loss of context, I am requesting that
the entire texts of my links be included in my comments.
Introduction
The scientific case against man-made global warming has collapsed. A number of
recent analyses of the International Panel on Climate Change (IPCC), its
science, its computer models, its review processes including the dubious
selections of reviewers, have been shown to be mortally flawed. As Christopher
Monckton recently observed:
“No serious scientist, therefore, can any longer take any of the IPCC’s
conclusions seriously for a single moment longer. As Lord Lawson of Blaby has
long argued, the IPCC should now be abolished. It cannot serve any useful
purpose in future, because it has dishonestly lent its support not merely to the
falsification of scientific results but to the persistent maintenance of that
falsification. The IPCC is finished.” (http://tinyurl.com/6d279c).
To be very clear, my message is that the EPA should never, now or ever, be
proposing mitigation of man-made CO2 on a body of “scientific” literature which
is so flawed, unreplicated, indefensible, and dishonest.
Monckton has provided much more essential and detailed analyses of the
scientific malpractices of the IPCC and its acolytes which are presented later
in this document.
Deming Testimony
There have been demonstrable activities to suppress the climate data over the
past 1000 years. For example in the Dec. 6, 2006 Senate testimony of Dr. David
Deming (shown here http://tinyurl.com/yf9q8t), described a situation where a
global warming scientist, apparently thought that Deming was an ally. Deming
stated “I had another interesting experience around the time my paper in Science
was published. I received an astonishing email from a major researcher in the
area of climate change. He said, "We have to get rid of the Medieval Warm
Period." The eagerness to omit or neglect or destroy actual climate data is
reprehensible, and utterly unscientific and unprofessional.
The obvious reasons for the request to suppress data are that the Medieval
Warming Period (MWP) was warmer than the temperatures of today. Such
evidence of
earlier warming periods makes it much more difficult to convince an unaware
public that today’s warming is man-made, when the climate history is filled with
such warming periods. Many eras in the past have shown warmer periods and
greater CO2 levels than they are today without any human impacts. It gets
worse, far, far worse.
The Hockeystick Fraud
The Hockeystick is a name given to a graph of reconstructed temperature data (
Mann, Michael E.; Bradley, Raymond S. & Hughes, Malcolm K. (1998), "Global-
scale
temperature patterns and climate forcing over the past six centuries" (PDF),
Nature 392: 779-787).
The “handle” of the hockeystick graph is intended to portray rather flat,
constant global temperatures extending from about 1000 AD to about 1900. At
this time the global temperatures turn sharply upward indicating the “blade” of
the hockeystick.
The overall message is/was that after about a 900 year period of constant
temperatures, the global temperatures rose sharply upward beginning around 1900,
allegedly. This is often assumed to be the beginning of the industrial age, and
therefore the presumed beginning of significant man-made CO2 emissions. This is
incorrect.
In fact the natural warming period we are currently in did not begin in 1900.
It began at the deepest part of the Little Ice Age when the colder global
temperatures began to reverse and then increase. In an excellent paper
describing the retreats of glaciers, J. Oerlemans (http://tinyurl.com/5eeya5)
showed that the glaciers from around the world began retreating nominally in
1750, 150 years before 1900. Thus, the warming began in this period as well,
not in 1900 so often claimed.
This Hockeystick graph has been featured prominently and globally in a major
scientific journal, referenced above. It has been given pivotal importance in
several of the IPCC assessment reports, and featured prominently in Al Gore’s
documentary “An Inconvenient Truth”, which now is discredited too. See here
(http://tinyurl.com/36pzfe), here (http://preview.tinyurl.com/2cpsyd), and here
(http://tinyurl.com/huf6d).
It is useful to list some of the approval processes which led to this global
deception. The authors, scientists themselves, obviously approved of their own
creation. The peer reviewers assigned by the science journal approved it, the
editors of the science journal who reviewed, checked, and approved it, and the
reviewers of the IPCC reports, the editors of the IPCC documents. The producers
of Gore’s documentary approved it, presumably Mr. Gore himself, and the
thousands of school teachers around the world who required millions of students
to view and analyze it. The extent of global fear inspired by the educational
systems around the world is incalculable.
We now know that the Hockeystick graph is fraudulent
(http://www.climateaudit.org/). How should we treat those who approved it?
What should the EPA do now proposing to adopt rule making for CO2 mitigation.
To do so they must embrace the underlying fraudulent science, and the terrible
harm it will bring.
EPA action seems simple: do not proceed with the rule making for green house
gas
mitigation. Have the courage not to mitigate man-made CO2 and avoid joining with
the scientific deceptions.
Close analyses of the hockeystick scandal are essential for policy makers,
educators, media, and many scientific institutions and their PhD staffers. All
of them played a role in creating and/or spreading the deceptions. It has
shaken the pillars of institutional science to its foundation and undermined the
public trust science once had. We are either dealing with willful scientific
deceptions or woeful and lazy scientific mediocrity from PhDs themselves.
Clearly, as a group they are not to be trusted with science or policy making.
The world owes a great debt to many scientists (dismissed as skeptics) who have
recognized the deceptions, applied rigorous scientific review, and have worked
to share their findings with policy makers, stakeholders, and the public. Some
of that world’s debt must go to Ross McKittrick, Steve McIntyre, and Christopher
Monckton. They have the analytical and statistical skills; the infinite bulldog
tenacity to stay engaged with the deceivers, who simultaneously were being very
uncooperative (another sign of unscientific behavior).
The great statistical work done by these three may just have helped the world
avoid trillions in expenditures for unnecessary green house gas mitigation
measures, not to mention the avoidance of energy rationing and taxation set
forth by carbon dioxide cap and trade policy proposals as a result of the IPCC’s
conclusions.
The EPA should be mindful and grateful for these efforts for several reasons.
The first is that the EPA should not being seen as promoting or embracing
fraudulent science lest it lose its credibility as an agency designed to protect
and enhance the quality of our environment and natural resources. And the
second is that the sophisticated highly technical detective work to separate
fraudulent environmental science founded in political agendas, has largely been
done for them.
The high levels of sophisticated climate deceptions are stunning, but
fortunately for us, these 3 have unraveled the sordid tale and when, what, and
how they did it. The “why” may never be known.
The website of McIntyre and McKitrick (M&M) is at (http://tinyurl.com/awwva).
M&M have been analyzing the hockeystick affair for years, and much of the
analysis is posted here. Major hockeystick graph work by Christopher Monckton
is at (http://tinyurl.com/6d279c).
For the outside observer, none of this multi-year detailed, high level
scientific detective work would have been necessary, if they (M&M and Monckton)
had been dealing with honest and ethical scientists. Such defensive,
name-calling belligerence from scientists and their political mentors were
unheard of in the 20th century. In the pursuit of the best hypotheses such
scientists would happily turn over their data, computers, algorithms, and
analyses. The purpose was always and obviously to develop the best hypothesis
possible to enhance the quality of science, human life, and its environs. But
not with today’s global warming crowd. As we have now learned they have had a
lot to hide, a lot of sophisticated deceptions to hide.
As Dr. Deming’s conversation with a warming advocate shows (above), there was a
deliberate effort to “get rid of the Medieval Warming Period”. The Hockeystick
analyses shed more light on the scientific deception and fraudulence to
misrepresent the cyclic warming and cooling of the earth over time. The highly
sophisticated, computerized, complex, algorithms which gave rise to the
reconstructed temperature history of the last 1000 years, is for all intents and
purposes, scientific malpractice. It was not a mistake or an error in judgment.
We now know there is much more to the deceptions. The Medieval Warming
Period
(MWP) was removed with the computer work by a litany of scientific malpractices
spelled out in detail by Christopher Monckton’s analyses. At the same time the
Little Ice Age (LIA) was removed from the record as well. The Little Ice Age
occurred over a number centuries centered around 1680 to 1700. To deny the
existence of the Little Ice Age as these modelers do, is to deny the huge
historical record of those centuries filled with misery, cold, snow, ice, crop
failures, starvation, and famine.
Monckton’s recent study of the Hockeystick fiasco shows much of the deception
in
detail http://tinyurl.com/6d279c). It is an excellent study of scientific
corruption on an international scale.
Every EPA employee tasked with regulating air quality should read and understand
Monckton’s study, the work of M&M, and their implications. One of the largest
implications is that no CO2 mitigation efforts are scientifically justified, by
any federal agency, the EPA, or any of the individual state and environmental
agencies.
Instead of honorably acknowledging the corruption, the deceptions, and data
manipulations, an organized effort claimed that if there had been any warming
1000 years ago, it was not global, merely regional. Monckton’s study includes
22 chart and graphs from the scientific literature demonstrating that the MWP
was indeed global, with evidence of warming from all parts of the world. Vikings
in Greenland were growing crops and livestock in a much warmer land during the
MWP. (http://tinyurl.com/dd6bv).
The following 900 hundred words are taken directly from the conclusions of
Monckton’s Hockeystick study (http://tinyurl.com/6d279c).
“The continuing affair of the “hockey-stick” graph is a microcosm of the
profound collapse of the rigor, objectivity, and honesty that were once
hallmarks of the scientific community. The need to look to the State for very
nearly all science funding has inflicted upon the scientific community a dull,
dishonest uniformity, so that the deliberate falsification of results to support
the current official orthodoxy has become commonplace, particularly where the
climate question is concerned.
It was bad enough that one of those behind the “hockey stick” affair should have
told a fellow researcher, “We need to get rid of the medieval warm period.” It
was worse that the authors of the bogus graph attempted to do just that:
1. by ignoring, undervaluing or even suppressing proxies for northern-
hemisphere
temperature that did not suit the result they wanted;
2. by falsely stating that they had used data they had in fact replaced with
“estimates” of their own that gave them a less inconvenient answer;
3. by overvaluing by many orders of magnitude the contribution of
datasets that
suited the result they wanted.
It was worse still that the IPCC, several leading journals and numerous former
co-authors of the three fabricators of the hockey stick should have continued to
cling to it as though it were Gospel, even though it has been justifiably and
utterly discredited in the scientific literature. Instead they went through an
elaborate pantomime of rewriting and publishing previously-rejected papers with
the connivance of a dishonest journal editor, so that an entirely fictitious
scientific support for the false graph could be falsely claimed by the IPCC in
its current Fourth Assessment Report.
The IPCC might have regained some of the scientific credibility that it lost by
its publication of the 2001 graph if, in its 2007 assessment report, it had had
the integrity, honesty, and common sense to apologise for the failure of its
soi-disant “peer-review” process to identify the multiple and serious scientific
errors that led to the publication of the graph.
As it is, the IPCC, rather than apologizing, has chosen to participate in the
falsification of subsequent results purporting to uphold the original graph, and
altogether to ignore papers such as those whose graphs are shown here (In
original analysis--linked above), confirming the well-established historical
record of the existence of the medieval warm period.
To repeat, no serious scientist, therefore, can any longer take any of the
IPCC’s conclusions seriously for a single moment longer. As Lord Lawson of Blaby
has long argued, the IPCC should now be abolished. It cannot serve any useful
purpose in future, because it has dishonestly lent its support not merely to the
falsification of scientific results but to the persistent maintenance of that
falsification. The IPCC is finished.
Was there a medieval warm period? Yes.
Was that period warmer worldwide than the present? Yes.
Are today’s global temperatures exceptional? No.
Have the past ten thousand years been generally warmer than the present? Yes:
much warmer.
Is there, therefore, the slightest reason for the childish panic that the
environmental extremist movement and its servant the IPCC have attempted to
whip
up? No.
Should any government devote a single further penny to the climate scare? No.
Even if humankind is contributing significantly to warmer weather (which is
highly unlikely), adaptation to warmer weather as and if necessary would be
orders of magnitude cheaper than the measures to reduce carbon emissions that
the world’s extremist politicians are now so eagerly but purposelessly advocating.
The real cost of the flagrant abuses of the scientific method surrounding the
question of climate that are so well illustrated by the affair of the “hockey
stick” is a terrible, unseen cost in human lives.
The biofuel scam that arose directly out of the climate scare has taken
one-third of US agricultural land out of food production in just two years.
Similar economic disasters have occurred worldwide, not because of “global
warming” but because of the catastrophically bad policy-making that the “global
warming” scare has engendered among politicians too ignorant of science and too
lazy to do other than swim with the rising tide of pseudo-scientific nonsense.
The environmental extremists have already killed 50 million children through
malaria (http://tinyurl.com/5m7w4b) by their promotion of the now-canceled ban
on the use of DDT. For decades DDT was the only effective agent against the
anopheles mosquito that spreads the infective parasite. They are still
threatening harm to millions more in poverty through their latest
scientifically-baseless scare – the “global warming” panic pandemic. This added
misery will be achieved by denying those in poverty access to energy,
electricity, clean water, food, shelter, and a healthy economy.
Food riots are occurring throughout the world among the poorest of the poor in
many countries: but the desperation, starvation, disease, and death that
accompany the sudden famines that the biofuel-driven doubling of world food
prices has engendered are scarcely reported by our news media. As Monckton
states in his full analysis, people in Haiti are eating mud pies made of earth,
water, a tiny knob of butter, and a pinch of salt; or they sell the mud pies to
less fortunate neighbours at 3 US cents each. Thus are the wages of
pseudo-science and its dominos.
The Wegman Committee
Finally, the final report of a panel of three independent statisticians,
chaired by the eminent statistics professor, Edward Wegman, chairman of the
U.S. National Academy of Sciences Committee on Theoretical and Applied
Statistics, has resoundingly upheld the M&M criticisms of the famous "hockey
stick" graph. See here (http://tinyurl.com/awwva).
The Primitive Computer Models
Christopher Monckton and M&M have specifically and in incredible detail analyzed
the technical and political fiascos behind the famous computer models as well.
Monckton’s computer model analysis is linked here (http://tinyurl.com/6edjzo),
M&M are here (http://tinyurl.com/awwva).
These should be required reading for all EPA officials with the slightest
interest in good science and good energy policy.
My 1700 word review of Monckton’s Computer Model Studies is linked here
(http://tinyurl.com/6f7cz7), and does not begin to give this analysis justice.
Some of the climate computer model flaws Monckton’s discovered are listed
below.
They are devastating to the man-made global warming hypothesis and the
computer
modeling. These have profound implications for policy makers and the energy and
economic future of our country. How the EPA or any other state or federal agency
would base their CO2 mitigation rulemaking and regulations on such flawed
science is inconceivable.
For the sake of sound mitigation and energy policies, we had better learn these
of these flaws below:
Point 1: There are… serial, serious failures of the computer models of climate
….the computer models upon which the UN’s climate panel unwisely founds its
entire case have failed and failed and failed again to predict major events in
the real climate.
a. The models have not projected the current multidecadal stasis in “global
warming”:
b. no rise in temperatures since 1998; falling temperatures since late 2001;
temperatures not expected to set a new record until 2015 (Keenlyside et al.,
2008).
c. nor (until trained ex post facto) did they predict the fall in temperatures
from 1940-1975;
d. nor 50 years’ cooling in Antarctica (Doran et al., 2002) and the Arctic
(Soon, 2005);
e. nor the absence of ocean warming since 2003 (Lyman et al., 2006; Gouretski &
Koltermann, 2007);
f. nor the behavior of the great ocean oscillations (Lindzen, 2007),
g. nor the magnitude nor duration of multi-century events such as the Mediaeval
Warm Period or the Little Ice Age;
h. nor the decline since 2000 in atmospheric methane concentration (IPCC, 2007);
i. nor the active 2004 hurricane season;
j. nor the inactive subsequent seasons;
k. nor the UK flooding of 2007 (the Met Office had forecast a summer of
prolonged droughts only six weeks previously);
l. nor the solar Grand Maximum of the past 70 years, during which the Sun was
more active, for longer, than at almost any similar period in the past 11,400
years (Hathaway, 2004; Solanki et al., 2005);
m. nor the consequent surface “global warming” on Mars, Jupiter, Neptune’s
largest moon, and even distant Pluto;
n. nor the eerily-continuing 2006 solar minimum;
o. nor the consequent, precipitate decline of ~0.8 °C in surface temperature
from January 2007 to May 2008 that has canceled out almost all of the observed
warming of the 20th century. (Complete references are listed in the full linked
document).
As Monckton states, the computer models are demonstrable failures.
Point 2: The IPCC’s method of evaluating climate sensitivity is inadequate and
error-laden Monckton showed that the IPCC’s method of evaluating climate
sensitivity can be reproduced by nothing more complicated than a few equations
which, if the IPCC’s values for certain key parameters are input to them,
generate the IPCC’s central estimate of climate sensitivity to a high precision.
Nowhere else has this method been so clearly or concisely expounded before.
And, once the IPCC’s method is clearly seen for what it is, it is at once
apparent that their method suffers from a series of major defects that render it
useless for its purpose. The laboratory experiments that form the basis for
estimates of forcings do not translate easily to the real atmosphere, so that
the IPCC’s claimed “Levels of Scientific Understanding” for the forcings are
exaggerated; its estimates of the feedbacks that account for two-thirds of total
forcing are subject to enormous uncertainties not fairly reflected in the tight
error-bars it assigns to them; the feedback-sum is unreasonably close to the
point of instability in the Bode feedback equation (important in the study of
circuitry [and climate] feedbacks), which has in any event been incorrectly used
for amplification in a chaotic system, when it was designed only for systems
whose initial state was linear.
The IPCC’s value for the no-feedbacks climate sensitivity parameter is the
highest in the mainstream literature, and is inconsistent with the value
derivable from the 2001 report; the value of this and other parameters are not
explicitly stated; etc., etc.
Point 3: The IPCC’s value for climate sensitivity depends upon only four
scientific papers Climate sensitivity is the central – properly speaking, the
only – question in the debate about the extent to which “global warming” will
happen. Monckton’s presentation of the IPCC’s method of calculating how much
the
world will warm in response to a doubling of CO2 concentration shows that the
IPCC’s values for the three key parameters whose product is climate sensitivity
are taken not from 2,500 papers in the literature but from just four papers.
Had a wider, more representative selection of papers been relied upon, a far
lower climate sensitivity would have resulted.
Point 4: Uncertainty in evaluating climate sensitivity is far greater than the
IPCC admits. The IPCC baselessly states that it is 90% sure we (humans) caused
most of the observed warming of the past half-century (or, more particularly,
the warming in the 23 years between 1975 and 1998: the remaining 27 years were
in periods of cooling). However, the uncertainties in the evaluation of climate
sensitivity are so great that any conclusion of this kind is meaningless. None
of the three key parameters whose product is climate sensitivity can be directly
measured; attempts to infer their values by observation are thwarted by the
inadequacies and uncertainties of the observations depended upon; and, in short,
the IPCC’s conclusions as to climate sensitivity are little better than guesswork.
Point 5: The published literature can be used to demonstrate lower climate
sensitivity. The second part of Monckton’s paper examines the literature on
climate sensitivity. A surprisingly small proportion of all papers on climate
change consider this central question. The vast majority concentrate on assuming
that the IPCC’s climate-sensitivity estimate is right and then using it to
predict consequences (though, as Schulte, 2008, has shown, none find that the
consequences are likely to be catastrophic). Monckton demonstrates, using
papers
from the literature, that it is at least as plausible to find a climate
sensitivity of <0.6 C as it is to find the IPCC’s 3.3C ( a factor of 5--- such a
large uncertainty does not inspire confidence).
Point 6: Even if climate sensitivity is high, adaptation is more cost-effective
than mitigation Monckton concluded as follows: “Even if temperature had risen
above natural variability, the recent solar Grand Maximum may have been chiefly
responsible. Even if the sun were not chiefly to blame for the past
half-century’s warming, the IPCC has not demonstrated that, since CO2 occupies
only one-ten-thousandth part more of the atmosphere that it did in 1750, it has
contributed more than a small fraction of the warming.”
Monckton’s analysis here is a major contribution to understanding a difficult
subject. He has broken through the dense modeling processes, not to mention the
ad hominem attacks, in such a way that many more can understand its
weaknesses.
It is time to break the relationship between energy policy and computer
forecasting. It is time for the EPA to understand and appreciate the flaws of
the existing hypothesis. The evidence for man-made CO2 being the cause of
warming or of the recent cooling does not exist. As such it is time for the EPA
to drop the efforts of mitigating man-made CO2 when such mitigation so clearly
is doomed to failure.
The models are not sources of climate information so badly needed to formulate
rational energy policy without the threats of economic suicide. In fact they
have been fertile grounds for mischief, very dangerous mischief. The economic
and energy future of our nation should not rest so completely on such primitive,
whimsical modeling.
Leaders of the EPA
Based upon these highly technical and thoroughly researched subjects within the
manmade global warming issues, we have clearly demonstrated scientific
corruption and exaggerations on the highest levels. As it stands at present,
there is no demonstrable evidence showing that man-made CO2 is contributing in
any measurable way to the current period of modest global warming. In fact we
appear to be entering a period of no warming at all, and for the last 7 years
modest cooling. A hypothesis which predicts CO2 causes warming, cannot
explain
recent cooling period while CO2 increases. The hypothesis is falsified, and no
man-made CO2 mitigation is necessary.
We request that the EPA not proceed with rule-making for CO2 mitigation.
Michael R. Fox Ph.D.
mike@foxreport.org