The EPA and “Independence”
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.