Scientific Shortcomings in the EPA's Endangerment Finding from Greenhouse Gases

Abstract

On April 24, 2009, the U.S. Environmental Protection Agency issued a finding of “proposed endangerment” from climate change caused by six greenhouse gases, with the largest contributions to warming resulting from emissions of carbon dioxide and methane.

In Proposed Endangerment, the EPA requested comments “on the data on which the proposed findings are based, the methodology used in obtaining and analyzing the data, and major legal interpretations and policy considerations underlying the proposed findings.”

We answered the EPA’s request in a filing on June 23, 2009. This article details some of the most relevant findings in our response. In general, we found that Proposed Endangerment suffered from systematic errors that were inevitable, given that the way in which the EPA chose to determine the required background science had to result in both biased and outmoded climate science. In addition, the EPA made grand and sweeping assumptions about human adaptation to climate that are of such illogic as to invalidate the entire study. We believe that these systematic errors call into question any attempt on the EPA’s part to subsequently issue regulations on greenhouse gas emissions.

Keywords: criticism of the scientific community, global warming skepticism, climate change science

JEL Classification: Q54, Q58