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Sunday, June 28, 2009
Some Select EPA Endangerment Comments

By Joseph D’Aleo

Now with the climate bill forced through the house even before it was finished being written and with the last minute addition of over 300 pages and certainly before it was read, the action shifts to the senate. We all need to turn our attention to our senators and make it known this bill is bad for America and that they will be held accountable for the damages done if it passes.

The administration is trying another path through the EPA as you likely know. They prefer the congressional route as the EPA regulation route could be/will be tied up in the courts. The time for public comments on the EPA endangerment findings here and the Technical Support Document has past. 3,717 comments were filed. Go to this site to see them. Some comments were asked not to be posted but considered in evaluation. Here are just a few of those most relevant that we found and or were sent to Icecap as well as those we submitted.

U.S. Chamber of Commerce filings: The Alliance for Clear Climate Economics and Science Solutions (ACCESS) was created to ensure that any regulation of greenhouse gases using existing environmental laws not harm the economy and American jobs, be based on sound science and allow for public review of all underlying data and scientific analysis. On June 23, 2009, the Chamber filed a Petition for a Formal “On the Record” Endangerment Finding using Administrative Procedure Act 556 and 557.  The Chamber also filed extensive written comments in response to EPA’s proposed endangerment finding for motor vehicles, analyzing the scientific, legal and policy grounds EPA has set forth for making such a finding. You can access the filings here. There was an important attachment to the main comment by Wolff here on the EPA approach taken to the relevant scientific literature in the TSD and briefly comments on the peer-review process for the TSD.

The very detailed comments Of The American Farm Bureau Federation, Deseret Power Electric Cooperative And Sunflower Electric Power Corporation on the EPA’S Proposed Endangerment Finding are here. Commenters believe that the Endangerment Finding Proposal, including the attached Technical Support Document ("TSD"), presents an incomplete discussion of climate change science. The Environmental Protection Agency ("EPA" or “Agency") has ignored literally hundreds of peer-reviewed scientific articles that are at odds with major portions of EPA’s conclusions. These studies were also not accounted for in the reports of the United Nations International Panel on Climate Change ("IPCC") and the United States Climate Change Science Program ("CCSP") on which EPA heavily relies.

Heartland’s excellent EPA comment is here. They have a listing of other posted comments here.

CEI filing is here. Chris Horner of CEI here. CEI also filed an EPA internal study autrhored by Alan Carlin that was suppressed here.

One of Dr. Roy Spencer’s comments is here.

One of Dr. John Christy’s comments is filed here.

Parts of Dr. Roger Pielke Sr.’s testimony to congress was put on file as a comment here.

Anthony Watts submitted a letter with his publication Is the US Surface Station Record Reliable.

The Heartland and Dr. Singer and Dr. Idso submitted the NIPCC report Climate Change Reconsidered .

Steve McIntyre commented on the EPA findings. Here is one of his comments.

William DiPucchio submitted this comment.

John McLean’s document on the IPCC here was resubmitted. 

Icecap submitted 9 comments, summarized here with links to principal comment content.

Invited presentation video by Dr. Nicola Scafetta, Duke University to EPA February 2009 here. Powerpoint PDF is here.


Posted on 06/28 at 11:37 PM
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