Comments of Arthur G. Randol III, Ph.D., on EPA’s Proposed Endangerment Finding

Dr. Randol criticizes, among other things, the models relied on by EPA to predict global warming. The models themselves and their input assumptions were not made public and thus cannot be independently validated, Dr. Randol states. None of the models EPA uses in the Endangerment Finding are on the approved list as determined by EPA guidance for evaluating models to determine their utility and objectivity, EPA’s Council for Regulatory Environmental Modeling (CREM) Model Assessment Guidance, he further states. “EPA has not met the Information Quality Act burden to show that the model(s) … used in the Endangerment Finding have ANY skill in forecasting, either at a global or a U.S. regional level, sufficient for policymaking.”