“If the EPA were to have done that with the regulations being proposed here … it is quite likely that their original Endangerment Finding would have to be revised and potentially overturned.”
The public comment period for the U.S. Environmental Protection Agency’s (EPA) proposed Standards of Performance for Greenhouse Gas Emissions for New Stationary Sources: Electric Utility Generating Units closed on June 25, 2012. A number of extensive comments were submitted arguing that the basis of the Endangerment Finding—that human greenhouse gas emissions (GHGs) “threaten the public health and welfare of current and future generations”—has become so outdated as to require a thorough re-assessment.
Strong cases were made that the EPA failed to completely consider new and influential scientific results which have a direct relevance to the impact that climate change as a result of human greenhouse gas emissions may have on the public health and welfare.…
In my last post, I pointed out a problem with the EPA’s major finding that:
Most of the observed increase in global average temperatures since the mid-20th century is very likely due to the observed increase in anthropogenic GHG [greenhouse gas] concentrations.
I showed that it could be reasonably and straightforwardly argued that less than half of the warming since 1950 contained in the “observed” global temperature history can be attributed to anthropogenic greenhouse gas emissions. This is bad for the EPA, as this finding was simply parroted by the EPA from the IPCC Fourth Assessment Report (AR4)—a report relied on heavily by the EPA in underpinning its Endangerment Finding (that greenhouse gases released by human activities “threaten the public health and welfare of current and future generations.”). When the IPCC is wrong, so is the EPA.…