The Scientific Case for Vacating the EPA’s Carbon Dioxide Endangerment Finding

This 24-page report by Patrick J. Michaels and Kevin D. Darayatna of the Competitive Enterprise Institute shows why the EPA’s “endangerment finding” was based on bad science and should be repealed.

Executive Summary

The U.S. Environmental Protection Agency’s (EPA) 2009 “Endangerment Finding” from carbon dioxide (CO2) and other greenhouse gases grants the agency a legal mandate that can have profound and far-reaching effects. The Finding is based largely on a Technical Support Document that relies heavily upon other mandated reports, the so-called National Assessments of global climate change impacts on the United States.

The extant Assessments at the time of the Endangerment Finding suffered from serious flaws. We document that using the climate models for the first Assessment, from 2000, provided less quantitative guidance than tables of random numbers—and that the chief scientist for that work knew of this problem.

All prospective climate impacts in the Endangerment Finding are generated by computer models that, with one exception, made systematic and dramatic errors over the climatically critical tropics. Best scientific practice would be to emphasize the working model, which has less warming in it than all of the others.

Instead, the EPA relied upon a community of wrong models.

New research compares what has been observed to what is forecast, and finds that warming in this century will be modest—near the lowest extreme of the prospective range given by the United Nations.

The previous administration justified its policy choices by calculating the Social Cost of Carbon [dioxide]. We interfaced their model with climate forecasts consistent with the observed history and enhanced the “fertilization” effect of increasing atmospheric concentrations of CO2. We find that making the warming and the vegetation response more consistent with real-world observations yields a negative cost under almost all modeled circumstances.

This constellation of unreliable models, poor scientific practice, and exaggerated estimates of the Social Cost of Carbon argue consistently and cogently for the EPA to reopen and then vacate its endangerment finding from carbon dioxide and other greenhouse gases.

The full document is available on the Competitive Enterprise Institute website at https://cei.org/content/scientific-case-vacating-epas-carbon-dioxide-endangerment-finding

See also: Dump EPA endangerment finding

Repeal the EPA endangerment finding

The Center for the Study of Carbon Dioxide and Global Change has send a 139-page petition to the Environmental Protection Agency (EPA) urging them to end their 2009 “endangerment finding”  for greenhouse gases due to lack of evidence.

The press release notes:

Over ten years have elapsed since the EPA Administrator made this judgment in its so-called CO2 Endangerment Finding. During that time a considerable amount of scientific research has been conducted on the potential impacts of rising greenhouses gases on humanity and the natural world. The additional knowledge obtained from such research and observations reveal quite clearly that rising greenhouse gases do not represent what EPA identified in 2009 to be a current or future threat to public welfare.

According to the Center’s Chairman, Dr. Craig Idso, who is the lead author of the petition, “multiple observations made over the past decade confirm the projected risks and adverse consequences of rising greenhouse gases are failing to materialize. The truth is, in stark contrast to the Endangerment Finding, CO2 emissions and fossil fuel use during the Modern Era have actually enhanced life and improved humanity’s standard of living. And they will likely continue to do so as more fossil fuels are utilized.”

The 139-page petition by the Center highlights multiple peer-reviewed scientific studies in support of this thesis. In particular, the petition shows (1) there is nothing unusual or unnatural about Earth’s current warmth or rate of warming, (2) historic and modern records of atmospheric CO2 and temperature violate established principles of causation, (3) model-based temperature projections since 1979 artificially inflate warming (compered to observations) by a factor of three, invalidating the models and all their ancillary claims associated with greenhouse gas-induced warming, and that (4) key adverse effects of greenhouse gas-induced warming,
including extreme weather events, temperature-induced mortality and sea level rise, are not occurring despite EPA predictions they should be worsening.

The petition also presents compelling evidence that CO2 emissions and fossil energy use provide critical benefits that act to enhance health and welfare for humanity and the natural world. According to Dr. Idso, “Without adequate supplies of low-cost centralized energy derived from fossil fuels, few, if any, of the major technological and innovative advancements of the past two centuries that have enhanced and prolonged human life could have occurred. Additionally, without the increased CO2 emissions from fossil fuel use over the past two centuries, Earth’s terrestrial biosphere would be nowhere near as vigorous or productive as it is today. Rather, it would be devoid of the growth-enhancing, water-saving and stress-alleviating benefits it has reaped in managed and unmanaged ecosystems from rising levels of atmospheric CO2 since the Industrial Revolution began.”

Download the entire petition here:

Click to access EPAPetitionCO2ScienceMarch2020.pdf