Suppressed Text of EPA Staffer's Skeptical Assessment of 'Endangerment' Finding
Background (by Dan Miller, Executive Vice President, The Heartland Institute)
Alan Carlin, a 38-year veteran of the U.S. Environmental Protection Agency, has written a 98-page report on the shaky science embraced by EPA and employed by global warming alarmists. EPA suppressed this report, according to emails discovered by the Competitive Enterprise Institute and posted on its Web site here.
Carlin had submitted the report to his superiors for EPA to consider as it deliberated whether carbon dioxide “endangers” human health and welfare.
Congress has relied heavily on EPA to justify increased regulation of carbon dioxide, including last week’s narrow passage in the House of the Waxman-Markey bill to cap emissions and trade permits for emissions above the cap.
In email exchanges between March 12 and March 17, Carlin asked his superior, Al McGartland, to forward his comments to the office responsible for managing the endangerment finding’s development. McGartland declined, writing, “The administrator and the administration has decided to move forward on endangerment, and your comments do not help the legal or policy case for this decision.”
Summary of Comments by Alan Carlin
These comments were prepared during the week of March 9-16, 2009 and are based on the March 9 version of the draft EPA Technical Support document for the endangerment analysis for Greenhouse Gases under the Clean Air Act. On March 17, the Director of the National Center for Environmental Economics (NCEE) in the EPA Office of Policy, Economics, and Innovation communicated his decision not to forward these comments along the chain-of-command that would have resulted in their transmission to the Office of Air and Radiation, the authors of the draft TSD.
These comments (dated March 16) represent the last version prepared prior to the close of the internal EPA comment period as modified on June 27 to correct some of the non-substantive problems that could not be corrected at the time. No substantive change has been made from the version actually submitted on March 16. The following example illustrates the type of changes made on June 27. Prior to March 16 the draft comments were prepared as draft comments by NCEE with Alan Carlin and John Davidson listed as authors. In response to internal NCEE comments this was changed on March 16 to single author comments with assistance acknowledged by John Davidson. There was insufficient time, however, because of deadlines imposed by the Office of Air and Radiation, to make the corresponding change in the use of the word “we” to “I” implicit in the change in listed authorship. This change has been made in this version.
It is very important that readers of these comments understand that these comments were prepared under severe time constraints. The actual time available was approximately 4-5 working days. It was therefore impossible to observe normal scholarly standards or even to carefully proofread the comments. As a result there are undoubtedly numerous unresolved inconsistencies and other problems that would normally have been resolved with more normal deadlines. No effort has been made to resolve any possible substantive issues; only a few of the more evident non-substantive ones have been resolved in this version.
It should be noted, of course, that these comments represent the views of the author and not those of the US Environmental Protection Agency or the NCEE.