June 15, 2012

The EPA and “Independence”

Filed under: Climate Politics

The public comment period is fast drawing to a close (June 25, 2012) on the EPA’s latest scheme to try to limit human greenhouse gas emissions (a fruitless task as far as climate change is concerned). The EPA’s Proposed Carbon Pollution Standard for Future Power Plants, announced on March 27, 2012, seeks to limit the emissions of carbon dioxide from new power plants to 1,000 lbs per megawatt hour. Such a standard would effectively bar any new coal-fired power plants from being built as such an emissions standard is not achievable by coal plants under current or near-term technology.

Accompanying its latest proposal, the EPA has produced a Regulatory Impact Analysis (RIA) that “discusses potential benefits, costs, and economic impacts of the proposed Standards of Performance for Greenhouse Gas Emissions for New Stationary Sources for Electric Utility Generating Units.” Chapter 3 of the RIA is concerned with “The climate change problem and rationale for rulemaking” and basically reiterates EPA’s version of the “science” behind its Endangerment Finding from December 2009, in which the EPA determined that human greenhouse gas emissions act to “threaten the public health and welfare of current and future generations” –a finding which opened the door for the EPA to regulate emissions of greenhouse gases from the U.S.

In order to make it seem as if they were keeping up with the latest scientific research on the topic of climate change (something which any more that a cursory inspection of the RIA reveals definitively is not the case at all), and that their opinions of the science behind the Endangerment Finding were robust, the EPA states that the Endangerment Finding has been bolstered by recent assessments by the National Research Council (NRC) which provide “independent” confirmation of the state of climate change science. From the RIA:

3.1.3 Recent Assessments

Since the Endangerment Finding was released, more recent assessments have produced similar conclusions to those of the assessments upon which the Finding was based. In May 2010, the NRC published its comprehensive assessment, “Advancing the Science of Climate Change” (2010). It concluded that “climate change is occurring, is caused largely by human activities, and poses significant risks for — and in many cases is already affecting — a broad range of human and natural systems.” Furthermore, the NRC stated that this conclusion is based on findings that are “consistent with the conclusions of recent assessments by the U.S. Global Change Research Program, the Intergovernmental Panel on Climate Change’s Fourth Assessment Report, and other assessments of the state of scientific knowledge on climate change.” These are the same assessments that served as the primary scientific references underlying the Administrator’s Endangerment Finding.

…Importantly, these recent NRC assessments represent another independent and critical inquiry of the state of climate change science, separate and apart from the previous IPCC, NRC, and USGCRP assessments.

However, it is clear from the (2010) NRC report “Advancing the Science of Climate Change” that it is not an “independent” assessment, as the EPA asserts. The EPA deceitfully backs its assertion of “independence” with the highly selective quote (reproduced above) that, out of context, gives the appearance that the NRC has arrived at its conclusions independently, and that they are “consistent” with the other assessment reports. But that is not the case at all.

In fact, the NRC describes its report as follows (in the Preface of report “Advancing the Science of Climate Change”, page ix):

In addition to drawing on the new scientific results being published nearly every week, we were aided in this task by the final U.S. Global Change Research Program (USGCRP) Synthesis and Assessment Product Global Climate Change Impacts in the United States (USGCRP, 2009a), the recent National Research Council (NRC) report Restructuring Federal Climate Research to Meet the Challenges of Climate Change (NRC, 2009k), and the four volumes of the fourth assessment report by the Intergovernmental Panel on Climate Change (IPCC, 2007a-d).

There is no definition of the term “independent” which includes being “aided” by other reports—especially the very same set of reports that the NRC report is supposed to be “independent” of! In fact, the on-line dictionary, dictionary.com defines “independent” as “not relying on another or others for aid or support.” As such, the EPA is 100% wrong is describing the NRC reports as representing “another independent and critical inquiry of the state of climate change science, separate and apart from the previous IPCC, NRC, and USGCRP assessments.”

How much the NRC report was “aided” by previous assessment reports of the USGCRP and the IPCC is clear from the numerous citations of those reports to base the major conclusions of the NRC report. Additionally, while the NRC claims to draw on “new scientific results being published nearly every week” in actuality, there is very little of the new and influential research that has been published since the release of the IPCC AR4 and USGCRP assessments that is included in the NRC reports. In some cases, the fact that the NRC report was produced in such close temporal proximity to the USGCRP report limits the cases of new science available for inclusion, and in other cases, it seems that the NRC selectively ignores scientific research that runs counter to the contents of the USGCRP and IPCC reports upon which it is primarily based.

Some examples of key research areas where of the lack of inclusion of new and influential research by the NRC and the strong reliance on the IPCC and the USGCRP reports by the NRC are illustrated by the following:

● The primary reference cited by the NRC to back the conclusions of the “Climate Forcing” section (p. 189-200) of “Advancing the Science of Climate Change” is Forster et al., 2007—which is Chapter 2 of the IPCC AR4 WGI report. In this section, the NRC fails to include the results of the new and influential study by Ramanathan and Carmichael (2009) in which it is shown the cumulative warming impact from human black carbon (soot) emissions (not a GHG) is much larger than described by the IPCC. The Ramanathan and Carmichael (2009) result implies that the warming effect of GHG emissions is less than previous assessments (such as the IPCC) have assigned to it.

● A primary reference cited by the NRC to back is findings reported in the “Climate Feedbacks and Sensitivity” section (p. 200-201) is Hegerl et al., 2007—which is Chapter 9 of the IPCC AR4 WGI report. Many of the other references were either dated and/or included in Hegerl et al., (2007). Absent from the NRC report is a large and growing collection of new and influential research findings which show that the estimates of climate sensitivity are much better constrained (especially on the high end) than reported in the IPCC AR4 (Annan and Hargreaves, 2009; Pueyo, 2011; Schmittner et al., 2011; Olson et al., 2012) and including central estimates for the climate sensitivity that fall beneath the IPCC AR4 central estimate of 3.0°C that was repeated by the NRC (Annan and Hargreaves, 2009; Lindzen and Choi, 2011; Pueyo, 2011; Schmittner et al., 2011). This new research greatly lessens the expectations for a large future temperature rise resulting from human GHG emissions.

● The NRC section “Attribution of Observed Climate Change to Human Activities” (p. 214-216) is replete with references to IPCC and USGCRP assessments. Of the 10 items included in the NRC’s bullet list. The large majority are based on direct citations of IPCC AR4 Chapters or previous (and somewhat dated) NRC reports.

● The section “Projections of 21st Century Climate” (p. 221-224) future projections of climate from climate models relies virtually exclusively on the results presented in the IPCC and USGCRP assessments.

● The section on “Causes of Sea Level Rise” (p. 238-243) fails to include any of a growing list of recent publications which find that the pumping of groundwater for irrigation and other uses is increasing rapidly across the world, and that this water, once stored in deep aquifers is now ending up in the oceans and contributing a sizeable fraction to the observed sea level rise. Recent estimates are than between 15 and 40% (and growing) of the current observed rate of sea level rise is being contributed by continental “dewatering” (Wada et al., 2010; Konikow, 2011; Wada et al., 2012; Pokhrel et al., 2012). These recent findings are in stark contrast to the NRC report which states that:

“There are additional contributions to sea level rise from other human activities such as wetland loss, deforestation, and the extraction of groundwater for irrigation and industrial use. While estimates of the size of these sources are somewhat uncertain, they are believed to be small relative to land ice melting and may be partially offset by the increased storage of water behind dams and in other surface reservoirs over the past century and a half (e.g., Chao et al., 2008).

Clearly, the NRC report is out-of-date on the issue as to the causes of and contribution to, recent sea level rise. In fact, the reported “acceleration” of sea level rise in recent decades can fully be explained by an “acceleration” of groundwater extraction around the globe (Wada et al., 2012).

● The section on “Projections of Future Sea Level Rise”(p. 243-245) makes inadequate mention of a growing list of new and influential publications which find that glacial processes in Greenland do not lend support a rapid and sustained increase in ice discharge from the Greenland ice sheet and thus do not support a large contribution of sea level rise from Greenland this century (e.g., van de Wal et al., 2008; Nick et al., 2009; Schoof, 2010; Bjørk et al., 2012). Without fully considering these scientifically important results, it is impossible to make an accurate assessment of the current sea level rise projections and gives rise to an overestimation of the future rate of sea level rise.

● The section on Public Health: Extreme Temperatures and Thermal Stress (P. 311-313), includes virtually none of a large number of influential publications that clearly and unequivocally demonstrate that populations readily adapt to heat waves (e.g., Davis et al., 2003; Barnett, 2007; Gosling et al., 2009; Kalkstein et al., 2010). The results of these studies, and others like them, suggest that if heat waves were to increase in frequency and intensity in the future, a declining population sensitivity would almost certainly be the result. Without adequately accounting for adaptation, both autonomous and planned, projections of negative health-related impacts from increasing heat waves are not robust and are inaccurate. The NRC report is grossly incomplete on this topic.

These examples are not intended to be a comprehensive documentation of all the instances of NRC’s direct reliance on the IPCC and USGCRP report, but are more than sufficient to demonstrate that the NRC report “Advancing the Science of Climate Change” is by no means “independent” of the IPCC and/or USGCRP assessment reports. Nor are these examples isolated instances. The NRC readily admits that the report relies heavily on the IPCC and USGCRP reports, as is clearly apparent from a simple perusal of the NRC report and its numerous citations of the IPCC and USGCRP reports to base its conclusions. Additionally, many of the examples listed above show that neither is the NRC a complete or balanced extension of the IPCC and USGCRP reports. A great many new and influential scientific research results have either been excluded, ignored, or published after the release of the NRC report.

The EPA’s contention that the findings in the NRC reports are “independent” and a “critical inquiry” into the nature of climate change, and that they add further support to the EPA’s Endangerment Finding is, simply put, incorrect and misleading.


Annan, J.D., and J.C. Hargreaves, 2009. On the generation and interpretation of probabilistic estimates of climate sensitivity. Climatic Change, 104, 324-436.

Barnett, A.G., 2007. Temperature and cardiovascular deaths in the U.S. Elderly: Changes over time. Epidemiology, 18, 369-372.

Bjørk, A. A., et al., 2012. An aerial view of 80 years of climate-related glacier fluctuations in southeast Greenland. Nature Geoscience, 5, 427-432, doi:10.1038/NGEO1481.

Davis, R.E., P.C. Knappenberger, P.J. Michaels, and W.M. Novicoff, 2003. Changing heat-related mortality in the United States. Environmental Health Perspectives, 111, 1712–1718.

Gosling, S.M., et al., 2008. Associations between elevated atmospheric temperature and human mortality: a critical review of the literature. Climatic Change, doi_10.1007/s10584-008-9441-x

Kalkstein, L.S., S. Greene, D.W. Mills, and J. Samenow, 2010. An evaluation of the progress in reducing heat-related human mortality in major U.S. cities. Natural Hazards, doi:10.1007/s11069-010-9552-3

Konikow, L., 2011. Contribution of Global Groundwater Depletion Since 1900 to Sea-Level Rise. Geophysical Research Letters, 38, L17401, doi:10.1029/2011GL048604.

Lindzen, R.S., and Y-S. Choi, 2011. On the observational determination of climate sensitivity and its implications. Asia-Pacific Journal of Atmospheric Sciences, 47, 377-390.

Nick, F. M., et al., 2009. Large-scale changes in Greenland outlet glacier dynamics triggered at the terminus. Nature Geoscience, 2, 110-114, DOI:10.1038/ngeo394.

Olson, R., et al., 2012. A climate sensitivity estimate using Bayesian fusion of instrumental observations and an Earth System model. Journal of Geophysical Research, 117, D04101, doi:10.1029/2011JD016620,

Pokhrel, Y.A. et al (2012) Model estimates of sea-level change due to anthropogenic impacts on terrestrial water storage. Nature Geoscience, doi:10.1038/ngeo1476

Pueyo, S., 2011. Solution to the paradox of climate sensitivity. Climatic Change, doi:10.1007/s10584-011-0328-x.

Ramanathan V., and G. Carmichael, 2009. Global and regional climate changes due to black carbon. Nature GeoScience, 1, 221-227.

Schmittner, A., et al., 2011. Climate sensitivity estimated from temperature reconstructions of the Last Glacial Maximum. Science, 334, 1385-1388, doi: 10.1126/science.1203513

Schoof, C., 2010. Ice-sheet acceleration driven by melt supply variability. Nature, 468, 803-805.

van de Wal, R. S. W., et al., 2008. Large and rapid melt-induced velocity changes in the ablation zone of the Greenland ice sheet. Science, 321, 111-113.

Wada, Y., et al. 2010. Global Depletion of Groundwater Resources. Geophysical Research Letters, 37, L20402, doi:10.1029/2010GL044571.

Wada, Y., et al., 2012. Past and future contribution of global groundwater depletion to sea-level rise. Geophysical Research Letters, 39, L09402, doi:10.1029/2012GL051230.

No Comments

No comments yet.

RSS feed for comments on this post.

Sorry, the comment form is closed at this time.

Powered by WordPress