Comments of Ken Haapala of the Nongovernmental International Panel on Climate Change on EPA’s Proposed Endangerment Finding

Haapala urged EPA to withdraw its proposed endangerment finding because it does not include the best available science and much of it is speculation. Haapala particularly criticized the omission of critical historical temperature data; its focus on the past 50 years, which omits the early 20th Century warming, mid-Century cooling, and the current cooling. No rigorous scientific justification exists demonstrating a human fingerprint on warming—this exists in models only, not in empirical science. The computer models fail to include all factors causing climate variability and there is not enough data available for input into the models for them to be reliable. In addition, much of the available data is inferior.