Russ Steele
Steve McIntyre, Climate Audit, submitted comments on the EPA's Endangerment Finding and the Technical Supporting Document (TSD).The EPA documents are considred highly influential scientific assessments that relied on assessments carried out by parties external to the EPA, including the IPCC. In order for EPA to use an assessment with external party peer review, EPA Guidelines require that IPCC submit the assessment report together with a complete peer review record to EPA and that EPA officials evaluate the assessment and peer review record for compliance with EPA (and OMB) Guidelines. Highly unlikely it was done as required!McIntyre's submission to the EPA on endangerment finding has been published in the Science & Public Policy Institute's Reprint Series. It is a stunning indictment of the ERA's failure to follow its own guide lines in producing the and reviewing this highly influential scientific finding that could cost US citizens billions in carbon taxes
McIntyre's Conclusions
The Finding and the TSD are highly influential scientific assessments that relied on assessments carried out by parties external to the EPA, including the IPCC. In order for EPA to use an assessment with external party peer review, EPA Guidelines require that IPCC submit the assessment report together with a complete peer review record to EPA and that EPA officials evaluate the assessment and peer review record for compliance with EPA (and OMB) Guidelines. It is highly doubtful that either such a submission or such an evaluation ever happened. In addition, there is considerable evidence that IPCC peer review procedures fall well short of the “rigorous” standard required for highly influential scientific assessments including non-compliance with standards on data availability, due diligence and transparency. In the particular case of 1000-year temperature reconstructions, the TSD applied a graphic that employed proxies which the NRC 2006 panel had said should be avoided. the TSD itself did not comply with relevant guidelines.
Download the submission here.