The Concerned Household Electricity Consumers Council ONCE AGAIN calls on President Trump and EPA to Revisit and Revoke the Scientifically Invalid CO2 Endangerment Finding
Key Points:
1. Just Released, Even More Definitive research findings make it even more certain that CO2 is not a pollutant but rather a beneficial gas that should not be regulated.
2. If the Endangerment Finding is not vacated, whether the current administration likes it or not, it is certain that electric utility, automotive and many other industries will face ongoing EPA CO2 regulation.
3. This scientifically illiterate regulation will raise energy prices thereby reducing U.S. economic growth and jobs.
May 22, 2017
The Concerned Household Electricity Consumers Council announces that on May 8, 2017 it filed with EPA a Supplement to the Council’s January 20, 2017 Petition asking the Agency to reconsider the scientifically invalid Endangerment Finding on which all Obama-era greenhouse gas regulations are based. The Supplement may be found here.
The Council’s original Petition (here demonstrated that the Endangerment Finding is nothing more than assumptions that have each been disproved by the most relevant empirical evidence from the real world. The original Petition was substantially based on a major peer-reviewed 2016 scientific paper by James Wallace, John Christy and Joseph D’Aleo (Wallace 2016) that analyzed the best available temperature data sets and “failed to find that the steadily rising atmospheric CO2 concentrations have had a statistically significant impact on any of the 13 critically important tropical and global temperature time series data sets analyzed.” The full text of Wallace 2016 may be found here.
The Supplement to the Petition now brings to the attention of EPA new developments, since the date of the Petition, that render the invalidation of the Endangerment Finding yet more definitive. First among the new developments is a new extensively Peer Reviewed April 2017 Research Report, also from Wallace, Christy and D’Aleo (Wallace 2017). Wallace 2017 can be found here.
Wallace 2017 takes a totally different analytical approach than Wallace 2016, and specifically estimates the impacts of the key natural factors, including solar, volcanic and oceanic/ENSO activity, on tropical and global temperatures. It concludes that once these natural factor impacts on temperature data are accounted for, there is no “natural factor adjusted” warming remaining to be attributed to rising atmospheric CO2 levels. That is, these natural factor impacts fully explain the trends in all relevant temperature data sets over the last 50 or more years. This research, like Wallace (2016) found that rising atmospheric CO2 concentrations did not have a statistically significant impact on any of the (14) temperature data sets that were analyzed. At this point, there is no statistically valid proof that past increases in atmospheric CO2 concentrations have caused what have been officially reported as rising, or even record setting, temperatures.
The Supplement to the Petition also demonstrates the improper use of Climate Models relied upon by EPA in the attribution of warming to human-related CO2 emissions. Court records make it very clear that the premise of using climate models in attribution is that such models are properly validated, provide reliable forecasts, and are unable to reproduce observed warming without the additional forcing from anthropogenic Green House Gases (GHGs). Wallace (2016) and Wallace (2017) both independently demonstrate that this premise is false. Both reports show that natural factors alone explain all the warming. Conversely, Climate models show a pattern of warming in the tropical troposphere that simply does not exist in nature - the Missing Tropical Hot Spot. Thus, the Climate Models have been invalidated and cannot be relied upon by EPA for attribution analysis in its Endangerment Finding. Therefore, simple but insistent logic precludes the use of invalidated climate models to attribute warming to human emissions of GHGs, and requires reconsideration of the Endangerment Finding.
The Supplement to the Petition also puts in the record before EPA information from the March 29, 2017 testimony of John Christy before Congress which also dealt with the Missing Tropical Hot Spot issue. Dr. Christy’s testimony can be found here. Dr. Christy’s Congressional testimony showed that the temperature trend, projected by climate models on which EPA relies, differs from the actual trend of observations at the 99% confidence level. Thus, the models used by EPA to conclude that greenhouse gases pose a “danger” to human health and welfare have failed a simple “scientific method” test. They have been invalidated.
The scientific invalidity of the Endangerment Finding becomes more blindingly obvious and undeniable with each day’s accumulation of empirical data. It is time for an honest and rigorous scientific re-evaluation of this Obama-era political document. The Nation has been taken down a tragically foolish path of pointless regulations and wasteful mal-investments to “solve” a problem which does not actually exist. Our leaders must summon the courage to acknowledge the truth and act accordingly.
The Council brought its Petition because the Obama-era greenhouse gas regulations threaten, as President Obama himself conceded, to make the price of electricity “skyrocket”. All Americans will benefit from a new era where the cheapest sources of energy can also compete and prevail in the marketplace.
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Icecap Note: in the areas where the green agenda has been aggressively pursued as in California and in the northeast with RGGI, rate payers are paying the highest prices in the nation for electricity.
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The Sierra Club and UCS which pushed RGGI and successively fought the introduction of a new natural gas pipeline needed to meet the electrical generation needs of the region as nuclear plants, oil and coal plants are decommissioned. The region is attempting to bring in hydropower from Quebec through the Northern Pass project but environmentalists are fighting that too. The small and and increasingly unpopular wind projects approved are unreliable, as Europe sadly found, requiring ready back-up generation or hydropower. The result of the green forced rate increases has been a loss of industry to states where power is cheaper.
CO2 is a beneficial gas as former co founder of Greenpeace, Ecologist Dr. Patrick Moore presents here.
Press Release Monday, April 24, 2017
WASHINGTON, D.C. The lack of pipeline infrastructure in the northeast has resulted in some of the highest electricity rates in the nation for families and business -and it will only get worse, according to a new report by the U.S. Chamber’s Institute for 21st Century Energy.
The latest installment in the Energy Institute’s Energy Accountability Series asks the question: “What if pipelines aren’t built into the northeast?” In the states examined, the report finds that the lack of additional pipeline infrastructure would cost over 78,000 jobs and $7.6 billion in GDP by 2020.
“Environmental groups seeking to ‘keep it in the ground’ are fighting to block virtually every project that would bring additional natural gas into in the northeast,” said Karen Harbert, president and CEO of the Energy Institute. “As a result, residents in the northeast are paying the highest electricity rates in the continental United States, with no relief in sight if infrastructure is not built. High energy prices are costing the region jobs and income, so maintaining the status quo will be painful.”
According to the U.S. Energy Information Administration, in 2015, Connecticut had the highest electricity rates in the nation (lower 48 states), while Massachusetts ranks third, Rhode Island is second, New Hampshire ranks fifth, New York is eighth, Vermont is seventh, New Jersey is eight, and Maine comes in at ninth.
Enlarged
Meanwhile, continued development of shale oil and gas in Pennsylvania, Ohio, West Virginia, and elsewhere has helped reduce U.S. dependence on foreign energy and brought back thousands of manufacturing jobs. However, the lack of access to markets in the northeast will cost those states jobs and revenue, which is also covered in the report.
The resources they produce could be used to relieve capacity problems in the northeast, but continued legal challenges and political opposition have stalled or slowed planned infrastructure projects such as the Constitution Pipeline and Access Northeast pipeline.
“As the regulatory and price environment continues to encourage the use of natural gas, northeast states will find themselves increasingly starved of the energy needed to power the economy and keep the lights on,” said Harbert. “Our analysis demonstrates that there is simply not enough capacity to meet demand, and families, consumers, and businesses will all pay the price.”
The economic impact analysis in the report estimates the potential impacts over the next 4 years, and includes all recently announced pipeline projects. To estimate economic impacts, the report uses publicly available economic data from announced pipeline projects, energy demand forecasts, and announced retirements of nuclear generators.
The inputs were run through the IMPLAN model to estimate the overall macroeconomic effects of preserving the status quo, which effectively prevents new pipeline infrastructure from being developed in the region.
To see a breakdown by state, visit. The report includes analysis for New England, New York, New Jersey, Pennsylvania, Ohio, and West Virginia.
The Energy Accountability Series takes a substantive look at what could happen if energy proposals from political candidates and interest groups were actually adopted.
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ICECAP COMMENT: The Sierra Club is running ads here in NH saying they are helping with the RGGI and their ‘successful’ blocking of natural gas pipelines to save northeast ratepayers on energy. Actually because of the Sierra Club blockage of NATGAS and RGGI, we pay the highest prices for electricity in the nation (together with California), twice the rate of some other states. The Chamber of Commerce says this will lead to still higher prices and job losses. I have always been environmentally conscious and a conservationist but this is criminal overreach, and I am especially appalled by the lies in advertising.
Authors’ Comments on their Two Research Reports:
On the Existence of a “Tropical Hot Spot” & The Validity of EPA’s CO2 Endangerment Finding, Abridged Research Report, August 2016, and
On the Existence of a “Tropical Hot Spot” & The Validity of EPA’s CO2 Endangerment Finding, Abridged Research Report, April 2017, Second Edition
On April 29, 2017, TWTW stated the following:
“Revised Paper by Wallace, Christy, and D’Aleo: In his testimony, Christy discusses the simple statistical model used in the August {2016} paper by Wallace, Christy, and D’Aleo. At the time of Christy’s testimony, the paper was undergoing revision and made stronger {Emphasis Added}. The paper has been reviewed by several experts in relevant sciences and statistics.”
The authors would like to clarify the situation; two separate and distinct research activities were carried out, each culminating in a separately peer reviewed research report. They were each published simultaneously on many different web sites, but 7 months apart. Importantly, there have been no revisions to either research report.
Both research efforts set out to test for the Existence of a “Tropical Hot Spot” and the Validity of EPA’s CO2 Endangerment Finding. Both dealt carefully and properly with econometric simultaneous equation parameter estimation issues in the two separate structural analyses that were carried out. And, both efforts involved the same three authors. Each analyzed the same Tropical, Contiguous U.S. and Global Temperature data sets.
“The objective of this research was to determine whether or not a straightforward application of the “proper mathematical methods” would support EPA’s basic claim that CO2 is a pollutant. Stated simply, their claim is that GAST is primarily a function of four explanatory variables: Atmospheric CO2 Levels (CO2), Solar Activity (SA), Volcanic Activity (VA), and a coupled ocean-atmosphere phenomenon called the El Nino-Southern Oscillation (ENSO.)”
However, the model explanatory variables used in the two separate research activities were very different. Readers should recall frequent debates among climate scientists as to which Natural Factor explanatory variable was most important - solar or oceanic/ENSO activity. The first research effort focused on testing the explanatory power of using just ENSO variables (i.e., specifically MEI related variables) and volcanic activity and was publicly released as the August 2016 Peer Reviewed report.
The Peer Reviewed Second Edition, publicly released in April 2017, explicitly included all three Explanatory variables, that is, solar, volcanic and oceanic/ENSO activity. From a purely statistical analysis standpoint, the results were invariably excellent in both modeling exercises.
The temperature data measurements that were analyzed were taken by many different entities using balloons, satellites, buoys and various land based techniques. Needless to say, if regardless of data source, the structural analysis results are the same, the analysis findings should be considered highly credible. The fact that two separate research efforts came to the same conclusions implies that the findings should be considered quite robust.
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Press Release and Research Report “On the Existence of a “Tropical Hot Spot” & The Validity of EPA’s CO2 Endangerment Finding: April 24, 2017
As a prelude to the Press release and Research Report, I have chosen to post the introduction on the press release and significance of this research report by Dr. Alan Carlin, a report reviewer and Retired Senior Analyst and manager EPA from his web site.
Second Edition of path breaking Research Report Further Shows the Scientific Invalidity of Climate Alarmism
Despite Saturday’s so-called “March for Science,” the almost simultaneous release of a second edition of a Research Report showing the exact opposite of what some of the marchers claim to be the conclusions of climate science has brought home the Orwellian reality that the marchers have gotten their claims concerning what the science says exactly backwards. The Climate March website says their forces of “The Resistance” won’t tolerate “institutions that try to “skew, ignore, misuse or interfere with science.” If the marchers really support science, they should be supporting climate skeptics, not the climate alarmists. How Orwellian can you get? The science is clear.
The authors of a path breaking August 2016 research report released today a Second Edition of their Research Report. The conclusions disproving the validity of USEPA’s three lines of evidence for their 2009 Endangerment Finding for Greenhouse Gases and very clearly demonstrating the lack of a statistically significant impact of increasing atmospheric levels of CO2 on global and tropical temperatures remain the same. However, the analysis process utilized is both more elegant and easier to understand. It demonstrates that Natural Factors involving solar, volcanic and oceanic activity fully explain the Earth’s tropospheric and surface temperatures. And, that CO2 plays no significant role.
Skeptics have long argued that fluctuations in global temperatures are not primarily due to human-caused emissions of CO2 from using fossil fuels to improve their lives, and have generally attributed these fluctuations to changes in the sun, our source of heat and light. The importance of solar, and other natural factor fluctuations has now been shown to be the case despite many tens of billions of taxpayer dollars spent by the US and other governments to try to disprove the obvious and mislead the public on this central scientific issue in the climate debate.
So the new Edition does not contradict any of the conclusions reached last fall, but now provides a more understandable and common sense explanation for fluctuations in global and tropical temperatures. Nothing that U.S. EPA, the UN, or even President Obama have done, or even could have done, could have had significant effect on the Earth’s temperature. The effect of their attempts to do so will be to line the pockets of “renewable” energy sources at the expense primarily of the less well-off the both in the US and the rest of the world and of decreasing the productivity of green plants and humans by discouraging the use of fossil fuel energy and thus CO2 emissions.
Previously climate skeptics have raised myriad reasons why reducing human CO2 emissions would have little effect on global temperatures despite arguments based on elaborate climate models that had never been proper validated. These Climate Models invariably predict that higher CO2 levels will lead to higher temperatures. The Research Report 12 separate times invalidates this assumption. It robustly invalidates the argument that reductions in CO2 emissions as advocated by the UN and the Obama Administration will have statistically significant (i.e., different from zero) effect on global temperatures. So they are a total waste of taxpayer and ratepayer dollars. And, very harmful to job creation, economic growth and the poor.
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PRESS RELEASE:
Abridged Research Report Second Edition, April 2017
A just released peer reviewed Climate Science Research Report has proven that it is all but certain that EPA’s basic claim that CO2 is a pollutant is totally false.
All research was done pro bono ICECAP NOTE: as has been the case with the numerous comment filings, letters, editorials, research reports and Amici briefs to the DC Circuit Court and SCOTUS. The team of scientists, economists and climatologists are not in for profit but we truly care about our environment and its inhabitants. We apply the seemingly forgotten scientific method and utilize rigorous statistical analysis techniques to determine the validity of politically driven claims, frivolously accepted and used to justify policies that force those who can least afford it to ride the Green Express Train to Energy Poverty.
This research failed to find that the steadily rising Atmospheric CO2 Concentrations have had a statistically significant impact on any of the 14 temperature data sets that were analyzed. The tropospheric and surface temperature data measurements that were analyzed were taken by many different entities using balloons, satellites, buoys and various land based techniques. Needless to say, if regardless of data source, the analysis results are the same, the analysis findings should be considered highly credible.
The analysis results invalidate EPA’s CO2 Endangerment Finding, including the climate models that EPA has claimed can be relied upon for policy analysis purposes. Moreover, these research results clearly demonstrate that once the solar, volcanic and oceanic activity, that is, natural factor, impacts on temperature data are accounted for, there is no “record setting” warming to be concerned about. In fact, there is no Natural Factor Adjusted Warming at all. The authors of this report claim that there is no published, peer reviewed, statistically valid proof that past increases in atmospheric CO2 concentrations have caused the officially reported rising, even claimed record setting temperatures. And, EPA’s Climate Models fail to meet this test.
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From the Second Edition Report:
ABSTRACT
The objective of this research was to determine whether or not a straightforward application of the “proper mathematical methods” would support EPA’s basic claim that CO2 is a pollutant. These analysis results would appear to leave very, very little doubt but that EPA’s claim of a Tropical Hot Spot (THS), caused by rising atmospheric CO2 levels, simply does not exist in the real world. Also critically important, this analysis failed to find that the steadily rising Atmospheric CO2 Concentrations have had a statistically significant impact on any of the 14 temperature data sets that were analyzed.
The temperature data measurements that were analyzed were taken by many different entities using balloons, satellites, buoys and various land based techniques. Needless to say, if regardless of data source, the structural analysis results are the same, the analysis findings should be considered highly credible.
Thus, the analysis results invalidate each of the Three Lines of Evidence in its CO2 Endangerment Finding. Once EPA’s THS assumption is invalidated, it is obvious why the climate models EPA claims can be relied upon for policy analysis purposes, are also invalid. And, these results clearly demonstrate - 14 separate and distinct times in fact— that once just the Natural Factor impacts on temperature data are accounted for, there is no “record setting” warming to be concerned about. In fact, there is no Natural Factor Adjusted Warming at all. Moreover, over the time period analyzed, these natural factors have involved historically quite normal solar, volcanic and ENSO activity. At this point, there is no statistically valid proof that past increases in atmospheric CO2 concentrations have caused the officially reported rising, even claimed record setting temperatures.
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Icecap Note:
To not be able to invalidate the hypothesis (commonly called prove) that CO2 was a major (i.e., statistically significant) driver of changes in global temperatures, what are called simultaneous equation parameter estimation techniques must be applied. If CO2 in fact does not have a significant impact, it is rather straightforward to test how much of the earth’s temperature variation can be explained by natural factors (e.g., solar, oceanic and volcanic activity.) It turns out that once these natural factor impacts are removed, the NF Adjusted Temperatures have a flat trend and bear no statistical significant relationship to CO2. These analysis results were found for 14 separate topical and global temperature data sets. This research finding leaves no room for CO2 to have any measurable impact on global atmospheric and surface temperatures. The scientific method requires that such analyses findings be fully reproducible. And, these are.
Unlike most peer (pal) reviewed papers, the authors made available to our peer reviewers and anyone (including you) access to the data sets. Also a blueprint to the methods was explicitly described in the Preface and a full set of summary statistical results in the report. Anyone with knowledge of the proper use of regression analysis involving simultaneous equation systems can fully understand and replicate this work. However reading the Preface would lend those without simultaneous modeling experience, the ability to fully understand the findings of this work.
The Undersigned Agree with the Conclusions of this Report:
Dr. Alan Carlin
Retired Senior Analyst and manager, US Environmental Protection Agency, Washington, DC.
Author, Environmentalism Gone Mad, Stairway Press, 2015.
Ph.D., Economics, Massachusetts Institute of Technology, Cambridge, MA.
BS, Physics, California Institute of Technology, Pasadena, CA.
Dr. Theodore R. Eck
Ph.D., Economics, Michigan State University
M.A, Economics, University of Michigan
Fulbright Professor of International Economics
Former Chief Economist of Amoco Corp. and Exxon Venezuela
Advisory Board of the Gas Technology Institute and Energy Intelligence Group
Dr. Craig D. Idso
Chairman, Center for the Study of Carbon Dioxide and Global Change
Ph.D., Geography, Arizona State University
M.S., Agronomy, University of Nebraska, Lincoln
B.S., Geography, Arizona State University
Dr. Richard A. Keen
Instructor Emeritus of Atmospheric and Oceanic Sciences, University of Colorado
Ph.D., Geography/Climatology, University of Colorado
M.S., Astro-Geophysics, University of Colorado
B.A., Astronomy, Northwestern University
Dr. Anthony R. Lupo
IPCC Expert Reviewer
Professor, Atmospheric Science, University of Missouri
Ph.D., Atmospheric Science, Purdue University
M.S., Atmospheric Science, Purdue University
Dr. Thomas P. Sheahen
Ph.D., Physics, M.I.T.
B.S., Physics, M.I.T.
Dr. George T. Wolff
Former Chair EPA’s Clean Air Scientific Advisory Committee
Ph.D., Environmental Sciences, Rutgers University
M.S., Meteorology, New York University
B.S., Chemical Engineering, New Jersey Institute of Technology
This Pro Bono Research Is Dedicated to the Memory of Dr. William M. Gray (Emeritus) Professor of Atmospheric Science, Colorado State University
The authors of this research are very much interested in knowing the names and credentials of individuals who would like to add their names to the list of scientists whose names may appear in the report under the following statement: “The Undersigned Agree with the Conclusions of this Report.”
After reading and thinking about this research report, if you would like to have your name added to the list, please send your name and credentials in a fashion similar to those listed in the August 2016 Research Report.
Please send this information to the following dedicated email address: thsresearch@aol.com.