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United States Environmental Protection
Agency
EPA Docket ID Number EPA-HQ-OAR-2009-0171
In
re:
Proposed
Endangerment and
Cause or Contribute
Findings for
Greenhouse Gases
Under Section 202(A)
of the Clean Air Act; Proposed Rule,
74
FR 18,886 (Apr. 24, 2009)
Supplement to the
October
5th Petition of the Competitive Enterprise Institute
To
Reopen This Proceeding in Light of
Newly
Released Information
Competitive Enterprise Institute
1899
L Street, NW, 12th Floor
Washington, D.C. 20036
(202) 331-1010
Sam Kazman, General Counsel
Hans Bader, Senior Counsel
December 2, 2009
Environmental Protection Agency
EPA Docket Center (EPA/DC)
Mailcode 6102T
Attention Docket ID No. EPA-HQ-OAR-2009-0171
1200 Pennsylvania Avenue, N.W.
Washington, D.C. 20460
By electronic delivery to: GHG-Endangerment-Docket@epa.gov
And by hand delivery to the EPA Docket Center
Emergency Supplement to CEI’s October 5th Petition To Reopen
This Proceeding in Light of Newly Released Information
Re: Proposed Endangerment and
Cause or Contribute Findings for
Greenhouse
Gases Under Section 202(a) of the Clean Air Act
Docket ID
No. EPA-HQ-OAR-2009-0171
Contact Information
Name: Sam Kazman, General Counsel
Organization: Competitive Enterprise Institute
(CEI)
Mailing Address: 1899 L Street, 12th Floor
Washington, DC 20036
Phone: 202-331-2265
E-mail: skazman@cei.org
INTRODUCTION
On October 5, CEI
petitioned EPA to reopen its Endangerment Proceeding because of a disclosure by
the University of
East Anglia’s Climate
Research Unit (CRU) that it had destroyed the raw data for its data set of
global surface temperatures. In our
view, this destruction of data was a major breach of scientific standards. It warranted
a reexamination of the studies based on that data, and a reopening of the
comment period to allow public response to this issue.
EPA has not responded to our petition.
In the past two weeks, however, new information has surfaced
which casts far greater doubt on the validity of CRU’s work. In the view of many, this information
destroys CRU’s reputation entirely.
Yesterday, CRU director Dr. Phil Jones announced that he was stepping
down from his position temporarily while the university conducts an
investigation of the released material.
CRU Update (Dec. 1,
2009), http://www.uea.ac.uk/mac/comm/media/press/2009/nov/homepagenews/CRUupdate
PURPOSE OF THIS FILING
The purpose of this filing is to put EPA on notice that new
information has very recently been released, whose content is so grave that it
may well destroy EPA’s basis for an Endangerment Finding. At a minimum, it requires EPA to reopen this
proceeding and engage in a full examination of this information, accompanied by
public comment. If the new material is serious enough to have led to the departure, at
least temporarily, of CRU’s Director, then for that same reason it justifies
EPA’s reopening this proceeding.
CEI will submit
to EPA a more detailed examination of the new information shortly. However, given the possibility that EPA may
be on the verge of issuing its final decision, it is important that this agency
be formally notified of both the existence of this information and the fact of
Dr. Phil Jones’ departure from CRU.
THE NATURE OF THE NEW
INFORMATION
On Thursday, November 19th several thousand emails
and documents from the Climate Research Unit of East Anglia University became available
for download from the Internet.
The released information is voluminous. It consists of more than 157 megabytes of
data, including over 1,000 emails and 3,400 other documents. Its contents are still being analyzed, and
will be for some time to come, but a number of things are apparent. There were conscious efforts by leading
climate scientists to misrepresent or falsify data, to evade FOIA requests, and
to inject intentional bias into the scientific peer review process. There
were also admissions in these emails that global warming largely ceased in the
last 10-15 years, despite public claims that it was continuing.
In addition to the emails, sections of annotated computer
code from programs used to process climate data were among the revealed
documents. The annotations by programmers indicate that the
programs were written in such a way as to artificially adjust the data to meet
their needs.
Two representative examples of analyses of this information
are: I. Murray, Three Things You Absolutely Must Know About Climategate (Nov. 24,
2009), http://pajamasmedia.com/blog/three-things-you-absolutely-must-know-about-climategate/;
C. Monckton, Climate Sensitivity
Reconsidered (Sept. 12, 2008), http://scienceandpublicpolicy.org/images/stories/papers/monckton/climate_sensitivity_reconsidered.pdf
This new information casts grave doubt on the body of
research underlying EPA’s Endangerment Proposal, and may well entirely destroy
the basis for EPA’s proceeding; namely, the major assessment reports of both
the Intergovernmental Panel on Climate Change (IPCC) and the U.S. Climate
Change Science Program (CCSP).
74 FR 18,894 col. 1.
A zip folder containing the files may be downloaded from
these two locations:
http://www.filedropper.com/foi2009
http://www.megaupload.com/?d=XD050VKY
A search engine for browsing through the emails by keyword
may be found here:
http://www.eastangliaemails.com/
In addition, CEI
is today filing a CD containing the data with EPA’s Docket Center.
CONCLUSION
For the foregoing reasons, EPA should immediately suspend
any action it is about to take on an Endangerment Finding, and reopen this
proceeding for an investigation of, and public comment on, the newly-released
information.
________________________
Sam
Kazman
General
Counsel
Related Files:
CEI Filing - EPA-HQ-OAR-2009-0171.pdf
Twitter
Facebook
YouTube
Open Market Blog
Globalwarming.org
Bureaucrash
CEI On Demand Video
Liberty Week Podcast
Newsletter Signup
RSS Feeds
Amended Petition to the EPA on the Proposed Endangerment Finding for Greenhouse Gases
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United States Environmental Protection
Agency
EPA Docket ID Number EPA-HQ-OAR-2009-0171
In
re:
Proposed
Endangerment and
Cause or Contribute
Findings for
Greenhouse Gases
Under Section 202(A)
of the Clean Air Act; Proposed Rule,
74
FR 18,886 (Apr. 24, 2009)
Supplement to the
October
5th Petition of the Competitive Enterprise Institute
To
Reopen This Proceeding in Light of
Newly
Released Information
Competitive Enterprise Institute
1899
L Street, NW, 12th Floor
Washington, D.C. 20036
(202) 331-1010
Sam Kazman, General Counsel
Hans Bader, Senior Counsel
December 2, 2009
Environmental Protection Agency
EPA Docket Center (EPA/DC)
Mailcode 6102T
Attention Docket ID No. EPA-HQ-OAR-2009-0171
1200 Pennsylvania Avenue, N.W.
Washington, D.C. 20460
By electronic delivery to: GHG-Endangerment-Docket@epa.gov
And by hand delivery to the EPA Docket Center
Emergency Supplement to CEI’s October 5th Petition To Reopen
This Proceeding in Light of Newly Released Information
Re: Proposed Endangerment and
Cause or Contribute Findings for
Greenhouse
Gases Under Section 202(a) of the Clean Air Act
Docket ID
No. EPA-HQ-OAR-2009-0171
Contact Information
Name: Sam Kazman, General Counsel
Organization: Competitive Enterprise Institute
(CEI)
Mailing Address: 1899 L Street, 12th Floor
Washington, DC 20036
Phone: 202-331-2265
E-mail: skazman@cei.org
INTRODUCTION
On October 5, CEI
petitioned EPA to reopen its Endangerment Proceeding because of a disclosure by
the University of
East Anglia’s Climate
Research Unit (CRU) that it had destroyed the raw data for its data set of
global surface temperatures. In our
view, this destruction of data was a major breach of scientific standards. It warranted
a reexamination of the studies based on that data, and a reopening of the
comment period to allow public response to this issue.
EPA has not responded to our petition.
In the past two weeks, however, new information has surfaced
which casts far greater doubt on the validity of CRU’s work. In the view of many, this information
destroys CRU’s reputation entirely.
Yesterday, CRU director Dr. Phil Jones announced that he was stepping
down from his position temporarily while the university conducts an
investigation of the released material.
CRU Update (Dec. 1,
2009), http://www.uea.ac.uk/mac/comm/media/press/2009/nov/homepagenews/CRUupdate
PURPOSE OF THIS FILING
The purpose of this filing is to put EPA on notice that new
information has very recently been released, whose content is so grave that it
may well destroy EPA’s basis for an Endangerment Finding. At a minimum, it requires EPA to reopen this
proceeding and engage in a full examination of this information, accompanied by
public comment. If the new material is serious enough to have led to the departure, at
least temporarily, of CRU’s Director, then for that same reason it justifies
EPA’s reopening this proceeding.
CEI will submit
to EPA a more detailed examination of the new information shortly. However, given the possibility that EPA may
be on the verge of issuing its final decision, it is important that this agency
be formally notified of both the existence of this information and the fact of
Dr. Phil Jones’ departure from CRU.
THE NATURE OF THE NEW
INFORMATION
On Thursday, November 19th several thousand emails
and documents from the Climate Research Unit of East Anglia University became available
for download from the Internet.
The released information is voluminous. It consists of more than 157 megabytes of
data, including over 1,000 emails and 3,400 other documents. Its contents are still being analyzed, and
will be for some time to come, but a number of things are apparent. There were conscious efforts by leading
climate scientists to misrepresent or falsify data, to evade FOIA requests, and
to inject intentional bias into the scientific peer review process. There
were also admissions in these emails that global warming largely ceased in the
last 10-15 years, despite public claims that it was continuing.
In addition to the emails, sections of annotated computer
code from programs used to process climate data were among the revealed
documents. The annotations by programmers indicate that the
programs were written in such a way as to artificially adjust the data to meet
their needs.
Two representative examples of analyses of this information
are: I. Murray, Three Things You Absolutely Must Know About Climategate (Nov. 24,
2009), http://pajamasmedia.com/blog/three-things-you-absolutely-must-know-about-climategate/;
C. Monckton, Climate Sensitivity
Reconsidered (Sept. 12, 2008), http://scienceandpublicpolicy.org/images/stories/papers/monckton/climate_sensitivity_reconsidered.pdf
This new information casts grave doubt on the body of
research underlying EPA’s Endangerment Proposal, and may well entirely destroy
the basis for EPA’s proceeding; namely, the major assessment reports of both
the Intergovernmental Panel on Climate Change (IPCC) and the U.S. Climate
Change Science Program (CCSP).
74 FR 18,894 col. 1.
A zip folder containing the files may be downloaded from
these two locations:
http://www.filedropper.com/foi2009
http://www.megaupload.com/?d=XD050VKY
A search engine for browsing through the emails by keyword
may be found here:
http://www.eastangliaemails.com/
In addition, CEI
is today filing a CD containing the data with EPA’s Docket Center.
CONCLUSION
For the foregoing reasons, EPA should immediately suspend
any action it is about to take on an Endangerment Finding, and reopen this
proceeding for an investigation of, and public comment on, the newly-released
information.
________________________
Sam
Kazman
General
Counsel
Related Files: CEI Filing - EPA-HQ-OAR-2009-0171.pdf