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Looking for critique of NCEE comments on EPA GHG review
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Dan Whaley  
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 More options Jun 30, 7:17 pm
From: Dan Whaley <dan.wha...@gmail.com>
Date: Tue, 30 Jun 2009 16:17:02 -0700 (PDT)
Local: Tues, Jun 30 2009 7:17 pm
Subject: Looking for critique of NCEE comments on EPA GHG review
I've run across this recently.

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

Internal NCEE review of EPA's endangerment analysis for GHG emissions
under the Clean Air Act.

Curious if others have developed or are in progress on a response to
these criticisms.

Dan


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David Schnare  
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 More options Jun 30, 10:29 pm
From: David Schnare <dwschn...@gmail.com>
Date: Tue, 30 Jun 2009 22:29:24 -0400
Local: Tues, Jun 30 2009 10:29 pm
Subject: Re: [geo] Looking for critique of NCEE comments on EPA GHG review

Dan, et al.:

The NCEE report has been discussed at length at Wattsupwiththat.com.  The
basic purpose of the report was not to impeach the IPCC report, it was to
identify science that had been developed since the IPCC report was prepared,
and to note that if that new science proved valid, then the scientific basis
of the AR4 report was put at issue.  The report author, Alan Carlin, a
member of this geoengineering google group, I might add, does believe the
new science seriously undercuts the IPCC report.

Nevertheless, the real story is that EPA had made its mind up before it
examined all the science.  That violates the Administrator's stated policies
and is improper for a governmental science body.

David Schnare.

On Tue, Jun 30, 2009 at 7:17 PM, Dan Whaley <dan.wha...@gmail.com> wrote:

> I've run across this recently.

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

> Internal NCEE review of EPA's endangerment analysis for GHG emissions
> under the Clean Air Act.

> Curious if others have developed or are in progress on a response to
> these criticisms.

> Dan

--
David W. Schnare
Center for Environmental Stewardship

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Ken Caldeira  
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 More options Jul 1, 12:10 am
From: Ken Caldeira <kcalde...@globalecology.stanford.edu>
Date: Wed, 1 Jul 2009 05:10:57 +0100
Local: Wed, Jul 1 2009 12:10 am
Subject: Re: [geo] Re: Looking for critique of NCEE comments on EPA GHG review

That NCEE report is full of misleading pseudo-information that will result
in a lot of smart people having to waste a lot of time responding to a wide
range of canards.

A report like that is a disservice, and not a useful contribution to
informed scientific discussion.


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David Schnare  
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 More options Jul 1, 8:01 am
From: David Schnare <dwschn...@gmail.com>
Date: Wed, 1 Jul 2009 08:01:48 -0400
Local: Wed, Jul 1 2009 8:01 am
Subject: Re: [geo] Re: Looking for critique of NCEE comments on EPA GHG review

Ken and I part ways on whether EPA should take time to clear the air  
on these issues.  Competent people disagree, so government has a legal  
duty to take a look at the arguments.

David Schnare
Center for Environmental Stewardship

On Jul 1, 2009, at 12:10 AM, Ken Caldeira <kcalde...@globalecology.stanford.edu


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Ken Caldeira  
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 More options Jul 1, 12:53 pm
From: Ken Caldeira <kcalde...@stanford.edu>
Date: Wed, 1 Jul 2009 17:53:13 +0100
Local: Wed, Jul 1 2009 12:53 pm
Subject: Re: [geo] Re: Looking for critique of NCEE comments on EPA GHG review

The US Government (and most other governments of the world) have already
carefully reviewed and approved the IPCC AR4 reports.

No new information that challenges the basic scientific facts laid out in
those reports.

Incompetent people also disagree. Does the government have a legal duty to
examine every spurious claim?

___________________________________________________
Ken Caldeira

Carnegie Institution Dept of Global Ecology
260 Panama Street, Stanford, CA 94305 USA

kcalde...@ciw.edu; kcalde...@stanford.edu
http://dge.stanford.edu/DGE/CIWDGE/labs/caldeiralab
+1 650 704 7212; fax: +1 650 462 5968


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David Schnare  
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 More options Jul 1, 1:30 pm
From: David Schnare <dwschn...@gmail.com>
Date: Wed, 1 Jul 2009 13:30:15 -0400
Local: Wed, Jul 1 2009 1:30 pm
Subject: Re: [geo] Re: Looking for critique of NCEE comments on EPA GHG review

Actually, Ken, there is data before the agency that challenges the
projections of the IPCC, which is more important than challenging the "basic
scientific facts" laid out in the AR4 reports.

As for the government, under common law dating to the 16th century and under
US law, EPA has a duty to seek comment and respond to all the comments, even
the stupid ones.  Some say it's called democracy, but it isn't.  It is the
way we, as a law-based society, ensure that the government is not arbitrary
and capricious.

When the government fails (or refuses) to examine the "spurious" comments
made, how does the public know (1) the comments were "spurious" and (2) that
the government didn't ignore non-spurious comments at the same time.

I'm thinking it's about time we reintroduced a course in civics to the
scientific community.

David.

On Wed, Jul 1, 2009 at 12:53 PM, Ken Caldeira <kcalde...@stanford.edu>wrote:

--
David W. Schnare
Center for Environmental Stewardship

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Eugene I. Gordon  
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 More options Jul 1, 2:29 pm
From: "Eugene I. Gordon" <euggor...@comcast.net>
Date: Wed, 1 Jul 2009 14:29:54 -0400
Local: Wed, Jul 1 2009 2:29 pm
Subject: RE: [geo] Re: Looking for critique of NCEE comments on EPA GHG review

David, it is not clear that all scientists need a course in civics. However,
i would strongly support you when it comes to climate science or any other
science wherein the grant money that is available is exceptional and the
participants protect their booty by going along with the consensus. Climate
science is an old boys club. I trust nothing they say unless scientists who
are not members of the club give it a thumbs up. That has not happened.
Thumbs down is more representative.

Certainly Lindzen has laid out the intracacies of "one hand washes the
other." It is hard to believe that is not the case.

-gene

  _____  

From: geoengineering@googlegroups.com
[mailto:geoengineering@googlegroups.com] On Behalf Of David Schnare
Sent: Wednesday, July 01, 2009 1:30 PM
To: Ken Caldeira
Cc: geoengineering@googlegroups.com
Subject: [geo] Re: Looking for critique of NCEE comments on EPA GHG review

Actually, Ken, there is data before the agency that challenges the
projections of the IPCC, which is more important than challenging the "basic
scientific facts" laid out in the AR4 reports.  

As for the government, under common law dating to the 16th century and under
US law, EPA has a duty to seek comment and respond to all the comments, even
the stupid ones.  Some say it's called democracy, but it isn't.  It is the
way we, as a law-based society, ensure that the government is not arbitrary
and capricious.  

When the government fails (or refuses) to examine the "spurious" comments
made, how does the public know (1) the comments were "spurious" and (2) that
the government didn't ignore non-spurious comments at the same time.

I'm thinking it's about time we reintroduced a course in civics to the
scientific community.

David.

On Wed, Jul 1, 2009 at 12:53 PM, Ken Caldeira <kcalde...@stanford.edu>
wrote:

The US Government (and most other governments of the world) have already
carefully reviewed and approved the IPCC AR4 reports.

No new information that challenges the basic scientific facts laid out in
those reports.

Incompetent people also disagree. Does the government have a legal duty to
examine every spurious claim?

___________________________________________________
Ken Caldeira

Carnegie Institution Dept of Global Ecology
260 Panama Street, Stanford, CA 94305 USA

kcalde...@ciw.edu; kcalde...@stanford.edu
http://dge.stanford.edu/DGE/CIWDGE/labs/caldeiralab
+1 650 704 7212; fax: +1 650 462 5968  

On Wed, Jul 1, 2009 at 1:01 PM, David Schnare <dwschn...@gmail.com> wrote:

Ken and I part ways on whether EPA should take time to clear the air on
these issues.  Competent people disagree, so government has a legal duty to
take a look at the arguments.

David Schnare
Center for Environmental Stewardship

On Jul 1, 2009, at 12:10 AM, Ken Caldeira

<kcalde...@globalecology.stanford.edu> wrote:

That NCEE report is full of misleading pseudo-information that will result
in a lot of smart people having to waste a lot of time responding to a wide
range of canards.

A report like that is a disservice, and not a useful contribution to
informed scientific discussion.

On Wed, Jul 1, 2009 at 3:29 AM, David Schnare < <mailto:dwschn...@gmail.com>

dwschn...@gmail.com> wrote:

Dan, et al.:

The NCEE report has been discussed at length at Wattsupwiththat.com.  The
basic purpose of the report was not to impeach the IPCC report, it was to
identify science that had been developed since the IPCC report was prepared,
and to note that if that new science proved valid, then the scientific basis
of the AR4 report was put at issue.  The report author, Alan Carlin, a
member of this geoengineering google group, I might add, does believe the
new science seriously undercuts the IPCC report.  

Nevertheless, the real story is that EPA had made its mind up before it
examined all the science.  That violates the Administrator's stated policies
and is improper for a governmental science body.

David Schnare.

On Tue, Jun 30, 2009 at 7:17 PM, Dan Whaley < <mailto:dan.wha...@gmail.com>

dan.wha...@gmail.com> wrote:

I've run across this recently.

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

Internal NCEE review of EPA's endangerment analysis for GHG emissions
under the Clean Air Act.

Curious if others have developed or are in progress on a response to
these criticisms.

Dan

--

David W. Schnare
Center for Environmental Stewardship

--
David W. Schnare
Center for Environmental Stewardship


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DW  
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 More options Jul 6, 6:17 pm
From: DW <dan.wha...@gmail.com>
Date: Mon, 6 Jul 2009 15:17:58 -0700 (PDT)
Local: Mon, Jul 6 2009 6:17 pm
Subject: Re: Looking for critique of NCEE comments on EPA GHG review
For what it's worth, the real climate critique here was helpful-- i
hadn't seen it originally.

http://www.realclimate.org/index.php/archives/2009/06/bubkes/#more-691

26 June 2009
Bubkes
Filed under:

    * Climate Science
    * Greenhouse gases

— gavin @ 8:00 - (Chinese (simplified)) (English)

Some parts of the blogosphere, headed up by CEI (”CO2: They call it
pollution, we call it life!“), are all a-twitter over an apparently
“suppressed” document that supposedly undermines the EPA Endangerment
finding about human emissions of carbon dioxide and a basket of other
greenhouse gases. Well a draft of this “suppressed” document has been
released and we can now all read this allegedly devastating critique
of the EPA science. Let’s take a look…

First off the authors of the submission; Alan Carlin is an economist
and John Davidson is an ex-member of the Carter administration Council
of Environmental Quality. Neither are climate scientists. That’s not
necessarily a problem – perhaps they have mastered multiple fields? –
but it is likely an indication that the analysis is not going to be
very technical (and so it will prove). Curiously, while the authors
work for the NCEE (National Center for Environmental Economics), part
of the EPA, they appear to have rather closely collaborated with one
Ken Gregory (his inline comments appear at multiple points in the
draft). Ken Gregory if you don’t know is a leading light of the
Friends of Science – a astroturf anti-climate science lobbying group
based in Alberta. Indeed, parts of the Carlin and Davidson report
appear to be lifted directly from Ken’s rambling magnum opus on the
FoS site. However, despite this odd pedigree, the scientific points
could still be valid.

Their main points are nicely summarised thus: a) the science is so
rapidly evolving that IPCC (2007) and CCSP (2009) reports are already
out of date, b) the globe is cooling!, c) the consensus on hurricane/
global warming connections has moved from uncertain to ambiguous, d)
Greenland is not losing mass, no sirree…, e) the recession will save
us!, f) water vapour feedback is negative!, and g) Scafetta and West’s
statistical fit of temperature to an obsolete solar forcing curve
means that all other detection and attribution work is wrong. From
this “evidence”, they then claim that all variations in climate are
internal variability, except for the warming trend which is caused by
the sun, oh and by the way the globe is cooling.

Devastating eh?

One can see a number of basic flaws here; the complete lack of
appreciation of the importance of natural variability on short time
scales, the common but erroneous belief that any attribution of past
climate change to solar or other forcing means that CO2 has no
radiative effect, and a hopeless lack of familiarity of the basic
science of detection and attribution.

But it gets worse, what solid peer reviewed science do they cite for
support? A heavily-criticised blog posting showing that there are bi-
decadal periods in climate data and that this proves it was the sun
wot done it. The work of an award-winning astrologer (one Theodor
Landscheidt, who also thought that the rise of Hitler and Stalin were
due to cosmic cycles), a classic Courtillot paper we’ve discussed
before, the aforementioned FoS web page, another web page run by Doug
Hoyt, a paper by Garth Paltridge reporting on artifacts in the NCEP
reanalysis of water vapour that are in contradiction to every other
reanalysis, direct observations and satellite data, a complete reprint
of another un-peer reviewed paper by William Gray, a nonsense paper by
Miskolczi etc. etc. I’m not quite sure how this is supposed to compete
with the four rounds of international scientific and governmental
review of the IPCC or the rounds of review of the CCSP reports….

They don’t even notice the contradictions in their own cites. For
instance, they show a figure that demonstrates that galactic cosmic
ray and solar trends are non-existent from 1957 on, and yet cheerfully
quote Scafetta and West who claim that almost all of the recent trend
is solar driven! They claim that climate sensitivity is very small
while failing to realise that this implies that solar variability
can’t have any effect either. They claim that GCM simulations produced
trends over the twentieth century of 1.6 to 3.74ºC – which is simply
(and bizarrely) wrong (though with all due respect, that one seems to
come directly from Mr. Gregory). Even more curious, Carlin appears to
be a big fan of geo-engineering, but how this squares with his
apparent belief that we know nothing about what drives climate, is
puzzling. A sine qua non of geo-engineering is that we need models to
be able to predict what is likely to happen, and if you think they are
all wrong, how could you have any faith that you could effectively
manage a geo-engineering approach?

Finally, they end up with the oddest claim in the submission: That
because human welfare has increased over the twentieth century at a
time when CO2 was increasing, this somehow implies that no amount of
CO2 increases can ever cause a danger to human society. This is just
boneheadly stupid.

So in summary, what we have is a ragbag collection of un-peer reviewed
web pages, an unhealthy dose of sunstroke, a dash of astrology and
more cherries than you can poke a cocktail stick at. Seriously, if
that’s the best they can do, the EPA’s ruling is on pretty safe
ground.

If I were the authors, I’d suppress this myself, and then go for a
long hike on the Appalachian Trail….

On Jul 1, 11:29 am, "Eugene I. Gordon" <euggor...@comcast.net> wrote:

...

read more »


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