First is the distinction made between "utterly politicized scientists," such as those at the center of the CRU controversy, and scientists committed to disinterested, objective science in the field of climatology (and all other fields), who deserve praise and support. It points to the importance of openness and transparency in practicing good science-and shows how those principles were, at times, ignored or flouted. Second, it shows how the EPA relied heavily on the IPCC's Fourth Assessment Report to make its endangerment finding for greenhouse gases. The IPCC's report was marred by errors and exaggerations. EPA failed to do its own independent review of the IPCC's science, so its finding is flawed, and EPA should dispense with it and start over again.
From the Introduction, Section 1:
As noted, the CRU controversy features emails from the world's leading climate scientists-emails that show behavior contrary to the practice of objective science and potentially federal law. We note at the outset an important distinction between, as Stephen Hayward put it, "utterly politicized scientists," such as those at the center of this controversy, and "more sober scientists" doing important work in the field of climatology. One of the motivations behind the Minority Report is to ensure that the CRU scandal does not "cast a shadow on the entire field," for, as Hayward noted, there are undoubtedly "a lot of unbiased scientists trying to do important and valuable work."
We agree with Hayward that this scandal "may represent a tipping point against the alarmists." And we agree wholeheartedly that the "biggest hazard to serious climate science all along was not so much contrarian arguments from skeptics, but rather the damage that the hyperbole of the environmental community would inflict on their own cause."
Transparency and openness are essential to producing good science. In 2006, in a report examining the work of Professor Michael Mann, one of the central figures in the CRU controversy, the National Research Council stated:
"Our view is that all research benefits from full and open access to published datasets and that a clear explanation of analytical methods is mandatory. Peers should have access to the information needed to reproduce published results, so that increased confidence in the outcome of the study can be generated inside and outside the scientific community."
This clear and time-honored principle was under attack in the CRU emails. The evidence suggests these scientists had a bias toward concealing data and methods, and preventing scientists with contrary views from publishing their work in peer-reviewed journals. The UK's Chief Scientific Adviser, John Beddington, condemned this behavior, writing that, "I don't think it's healthy to dismiss proper scepticism. Science grows and improves in the light of criticism."
Commenting on the CRU scandal, Ralph Cicerone, President of the National Academy of Sciences, wrote that such behavior "impedes science" and "breeds conflict." Further, he wrote that, "Clarity and transparency must be reinforced to build and maintain trust-internal and external-in science." According to recent polling, the scientists' failure to follow Cicerone's exhortation has significantly eroded public trust in climate change science.
From "Section 4: Endangerment Finding and EPA Reliance on IPCC Science":
Published on December 15, 2009, EPA's endangerment finding concluded that greenhouse gases (GHGs) endanger public health and welfare, and that the combined emissions of these GHGs from new motor vehicles and new vehicle engines contribute to greenhouse gas air "pollution," which endangers public health and welfare.92 As EPA repeatedly explains, the finding primarily relies on IPCC science.93 And on the critical issue of whether anthropogenic GHGs are causing climate change, the Administrator relied nearly exclusively on the work of the IPCC.
We believe EPA's response to the CRU issues is insufficient. EPA addresses the CRU controversy in its "Response to Public Comments Volume 2: Validity of Observed and Measured Data," which accompany the Endangerment Finding. In this volume, the agency largely dismisses the impact of the CRU emails. EPA also dismisses the comments regarding the destruction or inaccessibility of raw data to support such temperature records, arguing "the ability for commenters (or EPA) to reproduce or check raw data is not a requirement before EPA may rely on information, especially information widely accepted in the scientific community."
EPA also clearly rejects every comment requiring a reassessment of the IPCC's scientific conclusions. Without any analysis or discussion, EPA has either discarded the adverse comments or has prejudged the issues by not providing detailed discussion and analysis of the competing comments. EPA's only response is to repeat the mantra that the IPCC, CCSP/USGCRP, and NRC reports have gone through comprehensive review and peer review.
However, this "comprehensive" review failed to uncover key errors in the IPCC reports and their incorporation into the endangerment finding. Over the last several weeks, the media has uncovered significant errors and non peer-reviewed material in the IPCC's Fourth Assessment Report (AR 4). As it turns out, the IPCC mistakenly claimed that global warming would:
- Melt Himalayan glaciers by 2035;
- Endanger 40 percent of Amazon rainforests;
- Melt mountain ice in the Alps, Andes, and Africa;
- Deplete water resources for 4.5 billion people by 2085, neglecting to mention that global warming could also increase water resources for as many as 6 billion people;
- Lead to rapidly increasing costs due to extreme weather-related events; and
- Slash crop production by 50 percent in North Africa by 2020.
In addition, the IPCC:
- Incorrectly stated that 55 percent of the Netherlands lies below sea level;
- Included a diagram used to demonstrate the potential for generating electricity from wave power that has been found to contain numerous errors;
- Used a biased report by the activist group Defenders of Wildlife to state that salmon in US streams have been affected by rising temperatures; and
- Downplayed the increase in sea ice in the Antarctic to dramatize the observed decline in sea ice in the Arctic.
Despite EPA's insistence that the IPCC assessment reports are the world's most comprehensive and accurate assessments of climate change, the flaws in the IPCC reports indicate serious deficiencies in the IPCC's peer-review process. These flaws and deficiencies should prod EPA back to the drawing board, issuing notice and comment on what the mistakes mean and how they affect EPA's conclusion that GHGs endanger public health and welfare.
