Showing posts sorted by date for query Endangerment Finding. Sort by relevance Show all posts
Showing posts sorted by date for query Endangerment Finding. Sort by relevance Show all posts

Friday, June 30, 2017

Team B, Red Teaming and Steve Koonin

The Trump administration has been pushing the idea of a "Red Team" to re-examine the EPAs endangerment finding.  As Eli has pointed out, this is not a Red Team effort but a Team B attempt.  Red teams bring in experts in the field who have not been involved in a specific report to critically evaluate it.  Team B was a group run by Richard Pipes to exaggerate Soviet capabilities in the mid-1970s in order to justify an arms build up by tearing down CIA analysis.  Team B brings in ideologues to write a report that conforms to the ideology of those who commission their work. 

Joshua Rovner, in his book, Facixing the Facts, National Security and the Politics of Intelligence"points out where the Pipes Team B exercise went

The actual intelligence picture was irrelevant.  Team B simply assumed that Moscow was actively seeking any technology that would allow it to gain a decisive strategic advantage
 And Team B's imagination was quite fertile 
The Team B exercise corrupted the estimative process in ways that were wholly predictable.  The theoretical benefits of competition were lost because the composition of Team B was lopsided, because the panel spent as much time criticizing the intelligence community as it did evaluating the Soviet threat, and because the outside group relied on open sources.  The administration was warned of these problems in advance but did not intervene to insulate the NIE process from political bias.  On the contrary, it allowed the exercise to proceed in order to satisfy domestic political imperatives.
 There is much more at the link detailing the disastrous errors in the Team B report but the worst outcome was Star Wars, as the following Reagan administration used it as justification for the Star Wars build out. 

So let the bunnies count the ways that this administration's EPA administrator will build out his Team B
  • The membership of Team B Climate will be lopsided
  • Team B will spend as much time criticizing the IPCC and National Academy reports as evaluating the threat from climate change
  • Team B will rely on open sources, lord help us, like Watts Up With That, Curry's Climate Etc.
Any bunny thinking not, well Eli has a few carrots to wager on each proposition.

History Commons has a long discussion of Team B's fantasies including
Lack of Facts Merely Proof of Soviets' Success - One example that comes up during the debate is B’s assertion that the USSR has a top-secret nonacoustic antisubmarine system. While the CIA analysts struggle to point out that absolutely no evidence of this system exists, B members conclude that not only does the USSR have such a system, it has probably “deployed some operation nonacoustic systems and will deploy more in the next few years.” The absence of evidence merely proves how secretive the Soviets are, they argue. 
Climateball players have seen this before, and indeed, the run up to the Iraq War featured exactly the same playbook (see History Commons).

Brad Plumer points to Joseph Majkut at the Niskanen Center wondering what could be wrong with such an exercise.   Now Brad is a reasonable guy and the Niskanen Center is reasonable as real conservatives can be, but when Eli points out that the pawn is poison Majkut replies
Koonin, of course, is the apparatchik who tried to hijack the APS's drafting of their statement on climate change which required, amongst other things, that wiser heads on the drafting committee step in and Koonin huffing off in full regalia.  Eli has written several brilliant posts on the entire farrago but there was one thing that he missed coming from early on in the process, February 2013, which shows what Koonin was up to
The type of statement APS should make – simple & declarative or one that incorporates many details – needs consideration. The Intergovernmental Panel on Climate Change (IPCC) is also due to report on climate change in 2013; using their review as a trigger for an in-depth look at the APS statement is appropriate.

Commentary: J. Trebes agreed that using the IPCC review as a trigger is appropriate. Using it as a scientific basis for our statement will mitigate scientific argument within the APS. S. Koonin cautioned that APS should create its own statement and make its own judgment, separate from the IPCC report.
And he tried, oh my how he tried.


Saturday, January 19, 2013

Eli Has Been Asked

to comment on Mann vs. National Review and the Competitive Enterprise Institute.  Well actually John and Eli have pretty much stated the facts of the case, and Eli believes that even with the increased cost of popcorn due to climate change induced crop failure it is well worth the entertainment value. 

Yesterday's release of Michael Mann's response to NR and CEI requests for dismissal under the DC anti-SLAPP statue give no reason to change a bunny's mind. (Link to follow)

The response brings to the fore that there are two separate causes of action, first the odious comparison to Jerry Sandusky which has occupied the forefront of discussion, is cited for causing emotional distress, but, perhaps more importantly are claims of defamation

  • Defendant Simberg’s statement, published by CEI on Openmarket.org, that Dr. Mann
    had engaged in “data manipulation,” “academic and scientific misconduct,” and was
    “the posterboy of the corrupt and disgraced climate science echo chamber.” Compl. ¶
    48.
  • Defendant Steyn’s statement, published by NRO on National Review Online, that Dr.
    Mann “was the man behind the fraudulent climate-change ‘hockey-stick’ graph, the
    very ringmaster of the tree-ring circus.” Compl. ¶ 60.
  • Mr. Lowry’s statement, published by NRO on National Review Online, calling Dr.
    Mann’s research “intellectually bogus.” Compl. ¶ 72.
  • Defendant CEI’s press release, adopting and republishing the above statement by Mr.
    Lowry calling Dr. Mann’s research “intellectually bogus.”
Given their long history pursuing Mann, NR and CEI are going to have an interesting time claiming they didn't mean it.  In this regard, Mann's lawyers point to the many investigations, importantly to one in particular, claims by CEI contesting the basis of the EPA's greenhouse gas endangerment finding that lead to an investigation by the EPA
As EPA’s review and analysis shows, the petitioners routinely take these private e-mail communications out of context and assert they are ‘‘smoking gun’’ evidence of wrongdoing and scientific manipulation of data. EPA’s careful examination of the e-mails and their context shows that the petitioners’ claims are exaggerated, are often contradicted by other evidence, and are not a material or reliable basis to question the validity and credibility of the body of science underlying the Administrator’s Endangerment Finding or the Administrator’s decision process articulated in the Findings themselves Petitioners’ assumptions and subjective assertions regarding what the e-mails purport to show about the state of climate change science are clearly inadequate pieces of evidence to challenge the voluminous and well documented body of science that is the technical foundation of the Administrator’s Endangerment Finding.
Although CEI appealed this to the DC Circuit, which rejected their appeal.  This considerably weakens their arguments because you  cannot bring a matter before the courts and then reject the court's decision (note:  a petition for en banc review was denied in December but there still may be a further appeal to the Supreme Court) 

Thursday, July 19, 2012

EINAL

Brian Angliss has part two (start here) of a four part series on the DC Circuit Court of Appeals ruling endorsing the EPA endangerment finding for CO2 and the way in which the EPA proposes to deal with emissions.  Eli did a fast drive by about a month ago, but Brian has taken his time.  Worth reading.

For those bunnies not deeply into the Federal District Courts, the DC Circuit, aka, the Federal Circuit, is probably the most important Court of Appeals in the US because it gets all (EINAL, most) of the cases involving federal regulations.  Given the recent unpleasantness it is pretty well stacked with wingnuts, including Sentelle and Rogers, two of the three judge panel.  Tatel, the third, was a Clinton appointee.

Tuesday, June 26, 2012

The IPCC and the Federal District Court of Appeals

Sometimes a bunny just hangs about after quoting someone else and watches heads explode.  The Court was not amused.

 Those petitions asserted that internal emails and documents released from the University of East Anglia’s Climate Research Unit (CRU)—a contributor to one of the global temperature records and to the IPCC’s assessment report—undermined the scientific evidence supporting the Endangerment Finding by calling into question whether the IPCC scientists adhered to “best science practices.”

The petitions pointed to factual mistakes in the IPCC’s assessment report resulting from the use of non-peer-reviewed studies and several scientific studies postdating the Endangerment Finding as evidence that the Endangerment Finding was flawed.

According to EPA, the petitioners’ claims based on the CRU documents were exaggerated, contradicted by other evidence, and not a material or reliable basis for questioning the credibility of the body of science at issue; two of the factual inaccuracies alleged in the petitions were in fact mistakes, but both were “tangential and minor” and did not change the key IPCC conclusions; and the new scientific studies raised by some petitions were either already considered by EPA, misinterpreted or misrepresented by petitioners, or put forth without acknowledging other new State Petitioners have not provided substantial support for their argument that the Endangerment Finding should be revised. State Petitioners point out that some studies the IPCC referenced in its assessment were not peer-reviewed, but they ignore the fact that (1) the IPCC assessment relied on around 18,000 studies that were peer-reviewed, and (2) the IPCC’s report development procedures expressly permitted the inclusion in the assessment of some non-peer-reviewed studies (“gray” literature).

Moreover, as EPA determined, the limited inaccurate information developed from the gray literature does not appear sufficient to undermine the substantial overall evidentiary support for the Endangerment Finding. State Petitioners have not, as they assert, uncovered a “pattern” of flawed science.

Only two of the errors they point out seem to be errors at all, and EPA relied on neither in making the Endangerment Finding. First, as State Petitioners assert, the IPCC misstated the percentage of the Netherlands that is below sea level, a statistic that was used for background information. However, the IPCC corrected the error, and EPA concluded that the error was “minor and had no impact,” and the Endangerment Finding did not refer to the statistic in any way. Id. at 49,576–77. Second, the IPCC acknowledged misstating the rate at which Himalayan glaciers are receding. EPA also did not rely on that projection in the Endangerment Finding. studies.

Running with Rabett

Eli is pleased to announce that the US Court of Appeals for the Federal District, agrees with the Bunny that the EPA has it nailed.  As those of you with only mild cases of Alzheimers (not Eli) may remember, this blog featured a number of rather trenchant comments from the EPA's endangerment finding about excess atmospheric greenhouse gases.

Today, a panel made, bunnies would think, in denialist heaven, gave them the heave ho.  Judges Sentelle, Rogers and Tatel told Ken Cuccinelli and Co. where to insert their pleadings.

we conclude: 1) the Endangerment Finding and Tailpipe Rule are neither arbitrary nor capricious; 2) EPA’s interpretation of the governing CAA provisions is unambiguously correct; and 3) no petitioner has standing to challenge the Timing and Tailoring Rules. We thus dismiss for lack of jurisdiction all petitions for review of the Timing and Tailoring Rules, and deny the remainder of the petitions.
A great deal of the attack on the endangerment finding relied on accusing the EPA of outsourcing to the IPCC and the NRC and various other assessments.  The court had a Rabett Run class answer for that
State and Industry Petitioners assert that EPA improperly “delegated” its judgment to the IPCC, USGCRP, and NRC by relying on these assessments of climate-change science. See U.S. Telecom Ass’n v. FCC, 359 F.3d 554, 566 (D.C. Cir. 2004). This argument is little more than a semantic trick. EPA did not delegate, explicitly or otherwise, any decision-making to any of those entities. EPA simply did here what it and other decisionmakers often must do to make a science-based judgment: it sought out and reviewed existing scientific evidence to determine whether a particular finding was warranted. It makes no difference that much of the scientific evidence in large part consisted of “syntheses” of individual studies and research.  Even individual studies and research papers often synthesize past work in an area and then build upon it. This is how science works. EPA is not required to re-prove the existence of the atom every time it approaches a scientific question.
Something we should quote in the future.  And here is one that Nigel Persaud will just love
EPA further relied upon evidence of historical estimates of past climate change, supporting EPA’s conclusion that global temperatures over the last half-century are unusual. Endangerment Finding, 74 Fed. Reg. at 66,518. Scientific studies upon which EPA relied place high confidence in the assertion that global mean surface temperatures over the last few decades are higher than at any time in the last four centuries.  Technical Support Document for the Endangerment Finding (TSD), at 31. These studies also show, albeit with significant uncertainty, that temperatures at many individual locations were higher over the last twenty-five years than during any period of comparable length since 900 A.D. Id.
And right below that one in the kisser for the Post Normal Science crowd
they contend that the record evidences too much uncertainty to support that judgment. But the existence of some uncertainty does not, without more, warrant invalidation of an endangerment finding. If a statute is “precautionary in nature” and “designed to protect the public health,” and the relevant evidence is “difficult to come by, uncertain, or conflicting because it is on the frontiers of scientific knowledge,”
 More to follow

Tuesday, February 28, 2012

It comes in threes

The first is the Court of Appeals hearing on the EPA endangerment finding, Eli did a series on that but the long and the short is that the Supreme Court said that EPA had to treat CO2 as a pollutant, and it is going to be REAL hard to get past that. Brad Johnson sets the stage and it looks like the judges are not happy campers with denial (from Greenwire, paywall)

Patrick Day of the Coalition for Responsible Regulation argued that the finding “erroneously decided to completely divorce” the risk assessment from the agency’s regulatory decisions. EPA’s inadequate endangerment finding, he said, authorizes “ineffective and perhaps even fruitless regulations.”
Judge David Tatel, who was particularly aggressive in questioning both sides, sharply dismissed Day’s logic.
“I do not understand your argument,” he said. “Why don’t you try again?”
Tatel and Sentelle both seemed concerned that the petitioners were asking the court to overturn the scientific basis for EPA’s endangerment finding or the Supreme Court’s decision in Massachusetts. Both judges indicated that was not their job.
UPDATE: From Reuters
U.S. Circuit Judge David Tatel pointing out the agency had found the science certain enough. "To win here, you have to make an argument that EPA's decision is actually arbitrary and capricious," Tatel said.
and from the Environmental Defense Fund
Against this backdrop, today’s Petitioners forwarded non-scientific reasons that they claimed would permit EPA to avoid finding that greenhouse gases are harmful to human health. That line of reasoning prompted Chief Judge Sentelle to note that:
Sometimes in reading Petitioners’ briefs, I got the feeling that Massachusetts hadn’t been decided.
Among these non-scientific factors: Petitioners urged that EPA must consider humans’ ability to adapt to a changing climate in determining whether greenhouse gases endanger human health. In a hypothetical, Judge Tatel probed the flawed implications of that argument – he asked whether Petitioners’ position meant that EPA could determine that a cancer-causing pollutant did not pose a danger to public health on the grounds that society may, at some future point, develop a cure for cancer.
The second is a bit of serious merriment, as the folks at the Canadian Committee for the Advancement of Scientific Skepticism (CASS) fisk Tom Harris' version of a climate change course. Tom, a public relations guy, took over a Carleton University course from Tim Patterson, a noted rock head and denialist there. Evidently lectures at CU are (partially) available as videos to those taking the class and to staff, so a staff member asked for and got access. The Ottawa Skeptics had a field day and dug out 142 issues for the bunnies delectation. Eli, being a backwards bunny will start at the back. Others (one, two, three, ) have taken the lead
T. Harris Claim 142. ‚Climate science is changing quickly.‛
CASS makes the excellent point that climate science is undergoing refinement reinforcing basic ideas rather than rebuilding from scratch but Eli asks why not, we bunnies are changing the climate at lightening (for geology) speed, which is the problem. One of the principles of engineering is if you want to understand how a system works, give it a kick and observe. Unfortunately, if you are in the box, this can be annoying.
T. Harris Claim 141. ‚Prepare for global cooling.‛
Often referred to as the Year 10K problem. Eli would suggest that it would be a good thing to hang around for.

Oh hell, its the usual spinach. Go read the CASS report, Skeptical Science or Coby Beck and the other blogs.

Eli admires how CASS anticipates the spittle headed its way. The CU faculty find that academic freedom depends on academic responsibility
Academic freedom carries with it the duty to use that freedom in a manner consistent with the scholarly obligation to base research and teaching on an honest search for truth.
They show in their report, that in Harris' class
There was no free exchange of ideas, but the one-sided presentation of a biased viewpoint that contradicts much established research. Indeed, not only were alternative views not given time, but students were actively encouraged to ridicule those individuals who espoused views considered "alarmist" by the instructor (see our comment concerning "blooper of the week" above). Finally, as we demonstrate extensively in our analysis, the material presented was not an adequate representation of the current state of the field of climate science. The teaching of critical thinking and skepticism is healthy in a university setting where students are expected to move beyond the confines of rote learning.
but, dear parents of pre-college bunnies who wonder what they will expose the young'uns to, there is a far more serious issue here. The major responsibility of the faculty at any university or college is to evaluate itself. In the strongest form this occurs in hiring and the granting of tenure, where the department faculty plays a decisive role in figuring out if the applicants have half a clue about the field they will teach and do research in.

Not so well known is that the faculty also evaluates adjuncts, instructors, whatever you call em. There is no way that the Carleton University Department of Earth Sciences met its responsibilities in this case. Harris is simply not qualified to teach a course on climate change.

Something else will turn up

Tuesday, December 13, 2011

Eli can retire, the EPA on Africa Gate

Stoat has arisen to contemplate the libel suit that Irene Meichsner brought (and won two out of three falls) from Stefan Rahmstorf. This showed up in a post on Klima Zwiebel, and, of course, at the non-innocent Roger Pielke's. Not innocent because Roger was deep into this thing early on.

It arises from some mischief that Eli's friends Jonathan Leake and Richard North had got up to, accusing the IPCC AR4 of making unjustified accusations about how climate change coule lead to decreased ag yields in Africa. IM, simply adopted their frame. Stoat makes the important point that no one is looking at whether SR was right or wrong on the science. The point he won is that the court agreed that his statement

Reading helps, if the author of the article, IM, herself had once looked in the IPCC report, she would have found out that the accusations were completely false.
was an allowable difference of opinion. But of course there is more

Turns out that the EPA and it's various friends in the denialsphere had already read the IPCC report AND the background information (this is long folks)
-------------------------------------------------

Comment (2-10):
The Competitive Enterprise Institute, the Ohio Coal Association, Peabody Energy, and the Southeastern Legal Foundation take issue with a statement in Section 16(b) of the TSD that: “In some countries, yields from rain-fed agriculture could be reduced by up to 50% by 2020.” They claim the statement originated from gray literature in the IPCC AR4 and is therefore illegitimate. Southeastern Legal Foundation concludes: “The African Crop Yields claim stands as another example of the IPCC making a claim of imminent disaster that inappropriately relied on non-peer-reviewed literature…”

Response (2-10):
The IPCC statement cites a report by Dr. Ali Agoumi, a climate expert from Morocco (Agoumi, 2003) that was published by the International Institute for Sustainable Development (IISD) and funded by the government of Canada, the U.S. Agency for International Development, and other public and private institutions. Based on EPA’s review of the report, it appears that the 50% number was not obtained from the peer-reviewed literature but rather from “vulnerability studies on three North African countries (Algeria, Morocco and Tunisia) with respect to climatic changes.” These vulnerability studies were prepared under the U.N. Environment Programme Global Environment Fund and included in the National Communications of these three countries to the U.N. Framework Convention on Climate Change (Ministry of Territory Development and Environment, 2001, Kingdom of Morocco, 2001 and Republic of Tunisia, 2001).

In response to publicity regarding this purportedly unsubstantiated statement in the IPCC report, Dr. Coleen Vogel, a contributing lead author of the IPCC chapter on Africa impacts, described the context in which Dr. Agoumi’s research was used. She explained that Agoumi’s report received rigorous scrutiny by her fellow authors and was thoroughly discussed during development of the chapter (Kretzmann, 2010). She explained that the decision to include this (gray literature) study was based on the paucity of peer-reviewed material relating to some parts of the world, particularly Africa, and the desire of the authors of the report to provide balanced information. The process described by Dr. Vogel is consistent with the IPCC’s guidance on the use of gray literature, as previously described in Volume 1 of the RTC document and further discussed in Subsection 2.2.4.4 of this Response to Petitions (RTP) document.

Finally, we note that this statement relates to impacts outside the United States, and it did not materially impact the determination of endangerment of public health and welfare in the United States. As noted in Subsection 2.1.1, the Endangerment Finding states (Section III.D): “The Administrator looked first at impacts in the United States itself, and determined that these impacts are reasonably anticipated to endanger the public health and the welfare of the U.S. population. That remains the Administrator’s position, and by itself supports her determination of endangerment.”

Comment (2-11):




Referring to an analysis published by Ben Pile, co-editor of the blog climateresistance.org on the blog of Roger Pielke, Jr. (Pile, 2010), the Southeastern Legal Foundation states that the primary reference supporting the IPCC’s statement on African crop yields “Vulnerability of North African Countries to Climatic Changes” (Agoumi, 2003) was from IISD, an advocacy group.

Regarding the IISD reference, Peabody Energy states:

Thus, the EPA based its findings on the IPCC WGII report, which based its findings on a report [the IISD report] published by an organization with a declared political interest in climate change that based its findings from an assessment of other non-peer reviewed national studies. This is not the way EPA science should be carried out.

Response (2-11):
The implication that the credibility of IPCC’s statement on African crop yields is diminished because the IPCC’s source (Agoumi, 2003) for the statement was published by an advocacy organization or an organization with a “declared political interest in climate change” is unsupported. The organization in question is IISD, which describes itself as follows:

The International Institute for Sustainable Development contributes to sustainable development by advancing policy recommendations on international trade and investment, economic policy, climate change, measurement and indicators, and natural resource management. By using Internet communications, we report on international negotiations and broker knowledge gained through collaborative projects with global partners, resulting in more rigorous research, capacity building in developing countries and better dialogue between North and South.

IISD’s vision is better living for all—sustainably; its mission is to champion innovation, enabling societies to live sustainably. IISD receives operating grant support from the Government of Canada, provided through the Canadian International Development Agency (CIDA) and Environment Canada, and from the Province of Manitoba. The institute receives project funding from the Government of Canada, the Province of Manitoba, other national governments, United Nations agencies, foundations and the private sector. IISD is registered as a charitable organization in Canada and has 501(c)(3) status in the United States.

We find no reason to question the credibility and legitimacy of information produced by this organization on the basis of either its mission or funding sources. Moreover, neither the Southeastern Legal Foundation nor Peabody Energy provide any support for the implication that work by an organization such as IISD is automatically suspect or flawed.

Finally, Peabody Energy’s statement that EPA’s findings are based on this material is incorrect. As noted in Subsection 2.1.1, the Endangerment Finding states (Section III.D): “The Administrator looked first at impacts in the United States itself, and determined that these impacts are reasonably anticipated to endanger the public health and the welfare of the U.S. population. That remains the Administrator’s position, and by itself supports her determination of endangerment.”

We discuss the legitimacy of the science and underlying references for the African crop yields statement in Response 2-12.

Comment (2-12):
The Southeastern Legal Foundation alleges that EPA uncritically adopted the IPCC’s “faulty conclusion” with respect to crop yields. It refers to a blog by writer/commentator Richard North (North, 2010) to conclude the Agoumi (2003) reference cited by the IPCC on the issue of rain-fed agricultural yields in Africa relies on studies that “do not support the proposition for which they are cited.”

Relying on Richard North’s blog, the Southeastern Legal Foundation summarizes the vulnerability studies cited by Agoumi (2003) from the National Communications of Morocco, Tunisia, and Algeria. The Southeastern Legal Foundation notes that the Morocco National Communication “lends some support [to the Agoumi reference], saying that by 2020 during drought conditions cereal yields would decline up to 50%” but that “the data apply to cereal yields only, not crops in general as is implied by the IPCC.” The Southeastern Legal Foundation further states that “Algeria’s report said their yields would double, and be trimmed only slightly by ‘climate change’” and “Tunisia’s submission concluded the picture was mixed, but they could have an increase in rain and agricultural production.”

Response (2-12):
The IPCC’s statement on rain-fed agriculture in Northern Africa is not “faulty” and the Southeastern Legal Foundation presents no evidence that it was included uncritically in EPA’s TSD. Furthermore, the Southeastern Legal Foundation’s portrayal of findings on climate and crop yields from the National Communications of Morocco, Tunisia, and Algeria derived from Richard North’s blog is not complete. When all of the information in these National Communications is considered, we find there is broad support for Agoumi’s (2003) statements on North African rain-fed agriculture, which are:

  • “Some of the key statistics regarding water, soil, urban areas and coastal zones are outlined below. . . . Decreasing rain-based agricultural yields with grain yields reduced by up to 50 percent in periods of drought.”
  • “Studies on the future of vital agriculture in the region have shown the following risks, which are linked to climate change: . . . deficient yields from rain-based agriculture of up to 50 percent during the 2000–2020 period.”

PBL, in its report Assessing an IPCC Assessment (PBL, 2010a), makes the following important point with respect to IPCC’s statement on rain-fed agriculture in Africa:

This statement is not directly a statement on climate change, but on climate variability: in individual years, droughts can cause up to 50% in yield reductions. The implicit message here is that when droughts would become more frequent due to climate change, more years with up to 50% in yield reductions would occur. The statement could easily mislead readers into thinking that average annual yields could be reduced by up to 50% due to climate change. In the Summary for Policymakers of the Working Group II Report, the paragraph that contains this statement starts with a sentence introducing the notion of climate variability, which puts the statement more into context.

It is possible that petitioners misinterpreted the IPCC’s statement as suggesting that the IPCC’s projection was on the basis of climate change alone, given the Southeastern Legal Foundation’s assertion, for example, that IPCC was projecting “imminent disaster.” While we agree with PBL that the IPCC’s statement could easily mislead readers without the proper context, we note that, before quoting the IPCC’s projection on rain-fed agriculture, EPA’s TSD includes the statement “Agricultural production, including access to food, in many African countries and regions is projected to be severely compromised by climate variability [emphasis added] and change.” Therefore, EPA provided the proper context for the IPCC’s conclusion.

With respect to the basis for the conclusion itself, the following excerpts from the three countries’ National Communication reports on the issues of climate variability and change, precipitation, and crop yields provide broad support for the Agoumi (2003) statements along with accompanying discussion:

  • The National Communication of Morocco states (Kingdom of Morocco, 2001):

The development of climate scenarios for Morocco according to IPCC methodology reveals the following results: . . .

• A trend towards a decrease in average annual rainfall volume by about 4% in 2020 compared to 2000 levels. . . .
• An increase in the frequency and intensity of droughts in the south and the east of the country.

The first quantitative estimate of possible CC [climate change] impacts on water resources in 2020 points to the fact that there would be an average and general decrease in water resources (in the order of 10 to 15 %...).

The study of CC [climate change] impacts on agriculture (dominated by cereal cultivation) in 2020 unfolds the following results: A decrease in cereal yields by 50% in dry years and 10% in normal years.

As the Southeastern Legal Foundation admits, the numbers from Morocco’s National Communication lend support to the statement in Agoumi (2003) that “studies on the future of vital agriculture in the region have shown the following risks, which are linked to climate change: . . . deficient yields from rain-based agriculture of up to 50 per cent during the 2000–2020 period.”

Richard North’s contention (North, 2010, as referred to by the Southeastern Legal Foundation) that “the data apply to cereal yields only, not crops in general as is implied by the IPCC” is arguable considering that Morocco’s National Communication indicates that agriculture is “dominated by cereal cultivation.” Thus, it is not unreasonable to use cereal cultivation as a proxy for all of agriculture in this cereal-crop-dominated region.

  • The National Communication of Algeria (Ministry of Territory Development and Environment, 2001) states: 1

Because of global warming, we must brace ourselves for chronic climate instability and greater frequency of droughts and floods. Droughts damage soils and floods destroy ground cover and contribute to the erosion of soils. With longer spans of time between dry and wet spells comes an even greater impact due to erosion. The southern regions of the country will be most directly impacted by increased temperatures and will be subject to the numerous consequences of accelerated desertification. The increased risk of drought presents the greatest challenge as a result of climate change. The Intergovernmental Panel on Climate Change (IPCC) expect that the desert regions will extend northward in the Maghreb.

The above text provides a clear qualitative description of the risks climate change pose to agriculture in Algeria. In addition, this information from the National Communication of Algeria provides quantitative output from a model known as CROPWAT, which estimates changes in crop yields using climate change projections obtained from two general circulation models. The National Communication of Algeria reports:

… one can consider an average reduction in the output cereal of about 5.5 to 6.8%, corresponding mainly to instances of climate change [in 2020]( Ministry of Territory Development and Environment, 2001)

When considering these quantitative cereal yield changes, it is very important to note that these percentages refer to changes in cereal yields resulting primarily from climate change alone and not climate variability and change combined. The climate and hence precipitation variability in northern Africa can be quite large. For example, in the report Assessing an IPCC Assessment (PBL, 2010a), PBL states “…the [IPCC] authors made plausible that, due to current climate variability, the yields in Algeria, Morocco and Tunisia have been varying annually, including yield reductions of nearly 70% in individual years, in the period between 2000 and 2006.”

In other words, if these yield reductions resulting from greenhouse gas–induced climate change were superimposed on the yield reductions that might occur during a particularly dry period arising from the region’s characteristic precipitation variability, they would be higher and comparable with the results from the Morocco National Communication.

Finally, the Southeastern Legal Foundation’s reference to the Algeria National Communication’s projections for net increases in cereal projections in 2020 (relative to prior decades) is irrelevant and misleading. These increases are related not to climate variability and change but to changing agricultural practices and technology. Algeria’s National Communication makes clear that the effect of climate change on cereal yields is projected to be negative.

  • The National Communication of Tunisia states (Republic of Tunisia, 2001):

…Tunisia is in a hydrous stress situation close to a shortage, sharpened by a high anthropic pressure. So minor they be, the Climate Changes can so, result in harmful consequences on water resources, on ecosystems depending of water, and on the different economic activities that need large quantities of water such as agriculture and tourism.

By modifying the evaporation and precipitation rate, the global warming will probably affect the hydrous climate balance and therefore the Tunisian water resources. In this way, if the intensification of the evaporation can lead to a possible important increase of the rain falls, it might not be sufficient to offset the decrease of the sweet water resources. Moreover, due to the global warming, the rain situation can be characterized by a bigger frequency of rains resulting from torrential storms and downpours, disappearing generally in streaming waters rather than be absorbed by the soils.

This information in the Tunesian National Communication does not provide any quantitative estimates of climate variability and/or change on rain-fed agriculture, but the clear qualitative implication is that climate changes—both drought and heavy precipitation events—will stress agriculture in Tunisia. We, therefore, find that the Southeastern Legal Foundation’s statement that “Tunisia’s submission concluded the picture was mixed, but they could have an increase in rain and agricultural production” is an overly optimistic interpretation of clearly expressed negative impacts.

Overall, these three National Communications (Morocco, Algeria, and Tunisia) provide qualitative support for the fact the climate change will likely stress rain-fed agriculture in northern Africa, consistent with the portrayal of Agoumi (2003) and the IPCC. The National Communication of Morocco presents quantitative information consistent with what is reported by Agoumi (2003) and the IPCC (and hence the TSD), while the National Communication of Algeria provides quantitative information that is consistent with these sources when factoring in precipitation variability in addition to climate change. The National Communication of Tunisia does not provide quantitative information.

Our view of the literature behind Agoumi (2003) provides considerable evidence that the scientific basis for the IPCC’s conclusion is legitimate. The PBL assessment of the IPCC notes that “…additional explanations could have provided further foundations for the statement, had they been included in [IPCC’s Working Group II] Chapter 9.” We concur, but the Southeastern Legal Foundation conclusion that “…there is no support for the IPCC’s dramatic pronouncement on African crop yields” is significantly overstated.

Comment (2-13):
The Southeastern Legal Foundation provides the following reaction to the African rain-fed agriculture projection, which appeared in the Sunday Times (Leake, 2010a) and comes from former IPCC chair Robert Watson: “Any such projection [pertaining to African crop yields] should be based on peer-reviewed literature from computer modeling of how agricultural yields would respond to climate change. I can see no such data supporting the IPCC report.”

Response (2-13):
Watson may not have appreciated that peer-reviewed modeling studies of climate change impacts on agriculture in parts of Africa are limited. As the IPCC’s AR4 WGI report states (Christensen et al., 2007): “Several climate change projections based on RCM (regional climate model) simulations are available for southern Africa, but are much scarcer for other regions.” Accordingly, as we discuss in Subsection 2.2.4.4 of this RTP document, the IPCC references gray literature in these circumstances. We also note in Response 2-10 that these studies are not central to the TSD or the Endangerment Finding. Finally, though we discuss some additional modeling studies pertinent to Africa in RTP 2-15, those modeling studies (Parry et al., 2005 and Hulme et al., 2001) were conducted at the global and continental scales and contain limited results pertinent to northern Africa specifically.

Comment (2-14):
The Southeastern Legal Foundation states that EPA ignored contrary peer-reviewed literature and submits literature that the Sahel is greening (from National Geographic and several studies) in contrast to “IPCC horror stories” (projecting reductions in rain-fed agriculture).

Response (2-14):
EPA is aware of the literature cited by the petitioner that suggests greening in parts of the Sahara and Sahel (e.g., Seaquisti, et al., 2009; Anyamba, and Tucker, 2005; Hutchinson et al., 2005; Olsson et al., 2005). The issue raised by petitioners is not new and was raised and responded to through the public comment process (see Response 2-73 in Volume 2 of the RTC document). Thus, these objections do not meet the test in Clean Air Act (CAA) Section 307(d)(7)(B) that it be impracticable to raise the objection during the public comment period or the reasons for the objection arose between June 24, 2009, and February 16, 2010. Nonetheless, we have reviewed these arguments and respond once again.

The fact that precipitation has increased recently in this region, as we note in our TSD in Section 4(d), does not mean that a combination of climate variability and change could not substantially reduce rain-fed agriculture in the future. The climate in this region is highly variable and while it has been relatively wet over the past decade or so, severe drought impacted the region for several decades from the 1960s to the 1990s and dry patterns could return to the region. As one of the studies (Nicholson, 2005) cited by the petitioner states: “The fluctuations between ‘wet’ and ‘dry’ in the Sahel/Soudan zones are extreme even on decadal and multi-decadal time scales.” Therefore, if the current wet period reverses to a dry period, the impacts of rain-fed agriculture on the region could be profound, especially when considering the potential enhancement of the drying from human-induced warming (i.e., climate change).

Finally, we note that the literature presented relates to impacts outside the United States, and it did not materially impact the determination of endangerment of public health and welfare in the United States. As noted in Subsection 2.1.1, the Endangerment Finding states (Section III.D): “The Administrator looked first at impacts in the United States itself, and determined that these impacts are reasonably anticipated to endanger the public health and the welfare of the U.S. population. That remains the Administrator’s position, and by itself supports her determination of endangerment.”

Comment (2-15):
The Southeastern Legal Foundation suggests that the IPCC ignored literature that drew different conclusions on the issue of rain-fed agriculture projections in Africa, specifically referring to two studies: Parry et al., 2005 and Hulme et al., 2001. The Southeastern Legal Foundation states: “Both Parry’s own paper and Hulme’s paper were known to and available to Professor Parry [co-chair of IPCC Working Group II] in composing the WGII Report and the Synthesis Report. Yet, Parry’s WGII report ignored his own paper and that of Hulme, which did not predict disaster, and instead relied on one that did, the Agoumi paper, even though it did so incorrectly and improperly and was not peer-reviewed.” The Southeastern Legal Foundation further notes that Hulme et al. (2001) were careful to note uncertainties in understanding African climate change, and implies that the IPCC was not as careful.

Response (2-15):
We have reviewed these papers (Parry et al., 2005, and Hulme et al., 2001) and find that, while not directly comparable with Agoumi (2003), they do not contradict that source. We also find, contrary to the Southeastern Legal Foundation’s assertion, that both of these studies were in fact cited by the IPCC, although not always in the same section or context as Agoumi (2003).

The Parry et al. (2005) study reports the results of a series of research projects that aimed to evaluate the implications of climate change for food production and risk of hunger. The analysis in this study is performed at global and continental scales rather than the regional scale. This is likely why it is not discussed in Chapter 5 of Working Group II’s contribution to the AR4 (Easterling et al., 2007), where Agoumi (2003) is cited in a section focusing on regional impacts in Africa (specifically on Morocco, Algeria, and Tunisia). The Parry et al. (2005) study is cited multiple times in Chapter 5 of Working Group II’s contribution (“Food, Fiber, and Forest Products,” Easterling et al., 2007), which provides a global perspective. Therefore, Parry did not “ignore his own paper” as stated by the Southeastern Legal Foundation.

One of the primary conclusions of Parry et al. is that “the region of greatest risk [of losses in food production, and hunger due to climate change] is Africa.” Parry et al. (2005) provide specific cereal yield projections for the 2020s and 2080s resulting from different GHG emission scenarios. They state for the globe: “By the 2020s, small changes in cereal yield are evident in all scenarios, but these fluctuations are within historical variations.” For the 2080s, Parry et al. (2005) provide projections specific to Africa – but not northern Africa specifically, stating that climate change could reduce cereal yields by up to 30%. Importantly, the changes in cereal yield projected for the 2020s and 2080s are driven by GHG-induced climate change and likely do not fully capture interannual precipitation variability which can result in large yield reductions during dry periods, as the IPCC (Christensen et al., 2007) states: “…there is less confidence in the ability of the AOGCMs (atmosphere-ocean general circulation models) to generate interannual variability in the SSTs (sea surface temperatures) of the type known to affect African rainfall, as evidenced by the fact that very few AOGCMs produce droughts comparable in magnitude to the Sahel droughts of the 1970s and 1980s.” Given the different scopes of the two analyses, it is misleading to state that the Parry et al. projections are inconsistent with the Agoumi (2003) yield projections.

The Hulme et al. (2001) study, which reviews observed (1900–2000) and possible future (2000–2100) continent-wide changes in temperature and rainfall over Africa, is also not ignored by the IPCC, contrary to the assertion of the petitioner. In fact, it is cited twice in IPCC’s Working Group II Chapter 9 on Africa (Boko et al., 2007):

  • Hulme et al. (2001) is cited in a statement about the complexity of African climatology: “Other factors that complicate African climatology include dust aerosol concentrations and sea-surface temperature anomalies, which are particularly important in the Sahel region (Hulme et al., 2001; Prospero and Lamb, 2003) and southern Africa (Reason, 2002), deforestation in the equatorial region (Semazzi and Song, 2001; Bounoua et al., 2002)…”
  • Hulme et al. (2001) is also cited in a statement pertaining to uncertainties in precipitation projections in the western Sahel (Boko et al., 2007): “For the western Sahel (10 to 18°N, 17.5°W to 20°E), there are still discrepancies between the models: some projecting a significant drying (e.g., Hulme et al., 2001; Jenkins et al., 2005) and others simulating a progressive wetting with an expansion of vegetation into the Sahara (Brovkin, 2002; Maynard et al., 2002; Claussen et al., 2003; Wang et al., 2004; Haarsma et al., 2005; Kamga et al., 2005; Hoerling et al., 2006).”

These examples demonstrate that the IPCC both cited Hulme et al. (2001) and transparently discussed the complexity of Africa’s climate and the uncertainty in African climate projections. This treatment is appropriate and reasonable, contrary to the petitioner’s implication.

Even in light of the complexities and uncertainties, Hulme et al. (2001) state that a “warming climate will nevertheless place additional stresses on water resources [in Africa], whether or not future rainfall is significantly altered” and they project reduced precipitation over Tunisia. Hulme et al. (2001) do not, however, provide projections for changes in cereal yields (from changes in rain-fed agriculture), so their results cannot be compared directly with Agoumi (2003) or its supporting documents (discussed in Response 2-12).

Overall, the IPCC does not ignore either the Parry et al. (2005) or Hulme et al. (2001) studies. The findings of these studies, while not directly comparable with Agoumi (2003), are broadly consistent. Hulme et al. (2001) project increased drying over northern Africa while Parry et al. (2005) project an increased risk of reduced cereal yields over all of Africa. The petitioner’s claim that IPCC was not careful or acted inappropriately in this regard is not confirmed by careful review of the material.
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Eli can retire

Thursday, July 29, 2010

Eli can retire Part XV - Bart blushes

Hi gang, the EPA has made sure that Eli will never have to go back to work, dumping another load on the petitioners for reconsideration. Remember the great scandal about only 26% of the Netherlands being below sea level while the WGII report said 55%, wonder where that came from?
-------------------------------
2.1.2 Accuracy of Statement on Percent of the Netherlands Below Sea Level

Comment (2-1):
Peabody Energy and the State of Texas contend that the IPCC erroneously stated (in Working Group II’s contribution to the AR4) that 55% of the Netherlands is below sea level, whereas the actual number is much lower according to Dutch materials (26%).

Response (2-1):
The statistic quoted in the IPCC AR4 is inaccurate. When this error was identified, PBL (2010b) published a correction:

In the 2007 IPCC report by the Working Group 2 (Climate change 2007: Impacts, Adaptation and Vulnerability) a mistake has entered the text that was supplied by the Netherlands Environmental Assessment Agency, regarding the risks of flooding for the Netherlands. In the chapter on Europe, on page 547, it says that 55 per cent of the Netherlands is below sea level (‘The Netherlands is an example of a country highly susceptible to both sea level rise and river flooding because 55% of its territory is below sea level’). This should have read that 55 per cent of the Netherlands is at risk of flooding; 26 per cent of the country is below sea level, and 29 per cent is susceptible to river flooding. Examples of the latter are the near floodings, in the mid-1990s, of areas along the rivers Meuse and Waal – areas that are well above sea level.
The IPCC agrees that this statistic is incorrect in the AR4, and also notes that the same mistake was made by other reputable groups (Reuters, 2010). For example, the IPCC—in a written statement provided to Reuters—indicated that a report from the Dutch Ministry of Transport had stated “‘about 60%’ of the country is below sea level,” and referred to a European Commission study saying “about half” (Reuters, 2010). As noted by the IPCC statement, the error was not made by authors of the AR4, but originated with PBL, which supplied the text. To correct the mistake, the IPCC published an official erratum (IPCC, 2010d):
2) Page 547. Section 12.2.3. Line 20: Delete “below sea level” and replace with “at risk flooding”.
The IPCC was further quoted as saying (Reuters, 2010): “The sea level statistic was used for background information only, and the updated information remains consistent with the overall conclusions.”

In its independent report Assessing an IPCC Assessment (PBL, 2010a), PBL, which was responsible for the error, states:
We acknowledge that this error was not the fault of the IPCC (Coordinating) Lead Authors or Co-Chairs. The error was made by a Contributing Author from the PBL, and the (Coordinating) Lead Authors [of the IPCC] are not to blame for relying on Dutch information provided by a Dutch agency.
--------------------------------------------

Oh yes, what did this all mean, the EPA says nothing much

EPA concludes that this error is minor and inconsequential to the Administrator’s Endangerment Finding. EPA does not refer to or rely on this statistic in the Endangerment Finding or supporting documents, and this information does not pertain to endangerment of public health and welfare in the United States in any meaningful way. It does not call into question the integrity of the IPCC, and it has no impact on the scientific support for EPA’s Endangerment Finding. Furthermore, as the error pertains to a statistic outside the United States, it is not relevant to the Endangerment Finding. As noted in Subsection 2.1.1, the Endangerment Finding states (Section III.D): “The Administrator looked first at impacts in the United States itself, and determined that these impacts are reasonably anticipated to endanger the public health and the welfare of the U.S. population. That remains the Administrator’s position, and by itself supports her determination of endangerment.”

Sunday, May 02, 2010

Eli can Retire Part XI - A bunch of denial denied

Eli is really lazy, he is letting Cthulhu do the looking up for goodies in the US EPA responses to challenges to its Endangerment Finding for increasing CO2 concentrations.

Comment (2-19):
Some commenters write that CO2 is a weak GHG compared to other gases (0425, 0498, 0639.1, 1187.1, 1217.1, 2759, 10595); they note that CH4’s potency is 1000 times greater (0425) or that water is 95% of total greenhouse effect (10158, several others), implying that CO2 emissions can not have a large effect on the earth’s climate.

Other commenters write that CO2 is a weak GHG because it is limited as to how much radiation it can absorb. For example, a commenter asks why Mars is not warm despite a 95% CO2 atmosphere (2895), and another states that doubling CO2 would only have a small (0.4°C) effect (2759). One commenter states that as CO2 concentrations increase, the forcing does not increase—CO2 “has a forcing limit of 325 ppm” (0582). Another cites Plimer, who states that it has a maximum threshold (11454), and another states that CO2 does not absorb infrared (286).

Others point out that CO2 is less than 0.05% of the atmosphere (0153, 0455, 0498, 2885, 3214.1), and therefore presumably has a very small effect. A commenter (3722) claims that because of logarithmic forcing, 75% of the warming due to CO2 doubling should have already happened, therefore future warming due to CO2 will be small. A commenter (1009.1) notes that increased CO2 will not lead to much increase in temperature because of the logarithmic relationship and saturation.

Response (2-19):
Although it is true that CO2 has a smaller warming effect per kilogram or per molecule than a gas like CH4, it plays a larger role in the warming of the atmosphere. For example, Table 2.14 of Forster et al. (2007) lists radiative effects per ppb, lifetimes, and global warming potentials for a number of gases. CH4 is 73 times as potent as CO2 per kilogram in the atmosphere, 26 times as potent per molecule, or 25 times as potent using the Global Warming Potential metric. However, the concentration by volume of CH4 is 210 times less than that of CO2, and the emissions in kilograms of CH4 are about two orders of magnitude less. Thus, the TSD does not characterize various GHGs as “weak” or “strong,” and we do not find such characterizations useful. Note also that we are unclear the source for the claim that CH4’s potency is 1,000 times greater than CO2’s. We are not aware of such an estimate.

We also find no support for the assertion that water is responsible for 90% or 95% of the greenhouse effect in the scientific literature. Calculations by Kiehl and Trenberth (1997) suggest that water contributes about 60% of the greenhouse effect in clear sky conditions and 75% in cloudy conditions (including the cloud contribution). CO2 contributes about 26% of the greenhouse effect in clear sky 14 conditions, and 15% in cloudy conditions. Because the mass of water in the atmosphere is much larger than the mass of CO2, this implies that per ton or per molecule, CO2 is actually a much more effective GHG than water vapor.

The total effect of increasing CO2 concentrations can be best addressed by actually calculating the radiative forcing resulting from changes in those concentrations. Section 4(a) of the TSD discusses changes in radiative forcing due to increases in CO2 concentrations in the context of other changes in radiative forcing over the last 250 years. This also puts in context how a gas that composes 0.04% of the atmosphere can actually have a large radiative effect.

We disagree with assertions by commenters about a number of the radiative characteristics of CO2. We do agree that the forcing due to increases in CO2 concentrations is roughly logarithmic (Forster et al., 2007). This logarithmic relationship holds over a wide range of concentrations; commenters provided no peerreviewed literature to support the contentions that CO2 has a forcing limit of 325 ppm, a maximum threshold, or no infrared absorption, and we find that these assertions are not consistent with the scientific literature (Forster et al., 2007). Current forcing is almost half (not 75%) of the expected doubling due to the logarithmic relationship cited by one commenter, and because of the inertia of the climate system not all the warming has been realized, so it is not possible to extrapolate future temperature change merely by doubling the past 50 years of change. Comments on future temperature projections are covered in detail in
Volume 4.

Regarding Mars, see the response in Section 3.2.3 of Volume 3 of the Response to Comments document.

For these reasons, we have found no support for the commenters’ conclusions that CO2 does not have a large effect on the Earth’s climate. They provided no literature to support their assertions, and we have determined that our discussion of these issues in Section 4(a) of the TSD is reasonable and scientifically sound.
Carrots to the first to figure out where the 75% of the warming due to CO2 doubling should have already happened comes from

Comments?

Friday, April 30, 2010

Where are the tone trolls when you need them

Coby Beck brings word from the Charlottesville Hook that the VA Attorney General, Ken Cuccinelli, has told UVa to turn over every piece of paper Michael Mann ever touched when he was there, including that used in the nether regions. Chip Knappenberger, to give him credit, points out that this is not a good thing,

Sorry, but I can’t agree with Dr. Battig or Dr. Singer on this one.

Cuccinelli is taking things too far. Way too far. This has all the trappings of a witch hunt, plain and simple.

It does not strike me as being much of a stretch that it is not far along this path before scientists at Virginia’s public universities become political appointees, with whoever is in charge deciding which science is acceptable, and prosecuting the rest. Say good-bye to science in Virginia. Who is going to sign up to do it?

UPDATE: Steve McIntyre comes in on Chip's side of the register, condemning the Cooch

but old S. Fred goes nuclear

There is a good chance that Virginia’s Attorney-General Ken Cuccinelli will come up with the “smoking gun” — where other socalled investigations have only produced one whitewash after another.

We know from the leaked e-mails of Climategate that Prof.Michael Mann was involved in the international conspiracy to “hide the decline” [in global temperatures], using what chief conspirator Dr.Phil Jones refers to as “Mike [Mann]’s trick.” Now at last we may find out just how this was done.

A lot is at stake here. If the recent warming is based on faked data, then all attempts to influence the climate by controlling the emissions of the so-called “pollutant” carbon dioxide are useless –and very costly. This includes the UN Climate Treaty, the Kyoto Protocol, the Waxman-Markey Cap & Trade (Tax) bill, the EPA “Endangerment Finding” based on the UN’s IPCC conclusion, and the upcoming Kerry-Lieberman-Graham bill in the US Senate.

There go all the windfarms, both onshore and offshore, the wasteful ethanol projects, and the hydrogen economy. Maybe Al Gore will cough up some of his ill-gotten $500 million, gained from scaring the public, from carbon trading, carbon footprints, and all the other scams.

So – good luck, Ken Cuccinelli. We are with you all the way.

S. Fred Singer, PhD
Professor Emeritus of Environmental Sciences, University of Virginia
Chairman, Virginia Scientists and Engineers for Energy and Environment

Eli, being the ever hopeful bunny assumes that Prof. Curry will make a large donation to covering Prof. Mann's legal fees.

Sunday, April 18, 2010

Eli can retire Part X - The grim reaper is a hot head

The US EPA responses to challenges to its Endangerment Finding for increasing CO2 concentrations blows hot and cold.

Comment (5-24):
Several commenters (e.g., 3347.3, 11453.1, 3187.3) note that the April 2009 TSD indicated that cold-related deaths presently exceed heat-related deaths in the United States and that this provides evidence that a warming climate will have beneficial effects on temperature-related mortality. Commenters note that on page 70 of the April 2009 TSD, EPA states that 5,983 heat-related deaths were reported in the United States between 1979 and 2002. In the same timeframe, 16,555 people died of extreme cold. A commenter (3187.3) provides a paper by Goklany (2007), which indicates that death from extreme cold exceed death from extreme heat.

Response (5-24):
We have revised the TSD’s estimates of heat-related deaths based on the latest findings of the assessment literature (Karl et al., 2009). Based on these results, other supporting evidence presented in the TSD, and additional evidence cited below, we have determined that the available literature strongly supports the conclusion that extreme heat is, on an average annual base, the leading cause of weather-related death in the United States. We agree that the April 2009 TSD contained statistics that could be interpreted as suggesting that cold-related mortality has recently been higher in the United States than heat-related mortality. The cold-related mortality statistics in the TSD from Ebi et al. (2008) are similar to those cited by Goklany (2007). However, the methods and data for estimating heat-related mortality were recently updated and these revised values are presented in Karl et al. (2009).

The more recent heat-related mortality numbers from Karl et al. (2009) reflect results from the Centers for Disease Control and Prevention (CDC). CDC (2006) reports more than 3,400 deaths from 1999 to 2003 for which exposure to extreme heat was listed as either a contributing factor or the underlying cause of death. This result of roughly 680 heat-related deaths per year is almost identical to the 689 deaths per year from cold exposure reported by Ebi et al. (2008) and summarized in the TSD. CDC (2006) suggests that even the revised heat-related mortality numbers may underestimate total heat-related mortality, noting: “Because heat-related illnesses can exacerbate existing medical conditions and death from heat exposure can be preceded by various symptoms, heat-related deaths can be difficult to identify when illness onset or death is not witnessed by a clinician. In addition, the criteria used to determine heat-related causes of death vary among states. This can lead to underreporting heat-related deaths or to reporting heat as a factor contributing to death rather than the underlying cause.” This issue has long been recognized in attempting to estimate the mortality impact of extreme heat using information from death certificates (American Medical Association Council on Scientific Affairs, 1997). As noted in a subsequent response (5-29), cold-related deaths are likely also underestimated. One complication with these death certificate–based estimates of extreme cold and heat is they are not limited to periods that would be considered heat waves or cold snaps in the location where the death occurs. Therefore, while these results are based in a consistent methodology and data source, they have an uncertain overlap with the occurrence of the weather events of primary interest to the TSD, cold snaps and heat waves. As a result, these data alone do not provide strong evidence the heat-related mortality is presently greater than cold-related mortality.

However, we note that alternative and much higher estimates of heat-related mortality come from analyses of daily urban summertime mortality patterns in Kalkstein and Greene (1997) and Davis et al. (2003a), which use a different methodology to compute heat-related deaths compared to CDC (2006). These studies first define extreme heat events by identifying threshold conditions for an event in a location and then calculate the number of extreme heat–attributable deaths based on differences in daily deaths on extreme heat days compared to longer-term averages. In these studies, heat’s mortality impact is quantified in terms of the excess deaths that result during the extreme heat conditions. By evaluating changes in daily deaths attributable to all causes, this approach also effectively eliminates differences or restriction in using certain causes of death as potential sources of bias in estimating the extreme heat’s mortality impact. This method is also more consistent with the view that heat waves are effectively identified through exceptional weather conditions that result in increases in daily mortality (e.g., Confalonieri et al., 2007; U.S. EPA, 2006a). Although differences in the time series, definitions of urban populations, and other analytical methods prevent an exact comparison of the results in these two studies, both studies (Kalkstein and Greene, 1997; Davis et al., 2003a) estimate that there are approximately 1,700–1,800 excess deaths per year during extreme heat events based on an evaluation of a subset of approximately 40 U.S. metropolitan areas (see U.S. EPA, 2006a). These estimates of extreme heat’s mortality impact are much higher than the corresponding death certificate–based estimates for heat as well as the Ebi et al. (2008) estimate for cold-related mortality summarized in the TSD.

We also note that Davis et al. (2004) find that the net impact of the observed temperature increase from 1964 to 1998 (considering both reduced temperature mortality in winter and increased temperature mortality in summer) was an extra 2.9 deaths (per standard million) per city per year in 28 major U.S. cities. This indicates that extreme heat has been the larger cause of mortality in the recently observed record when temperatures have warmed.
Furthermore, we note that the USGCRP assessment (Karl et al., 2009) specifically refers to a recent study by Borden and Cutter (2008), which concludes heat is the most deadly natural hazard in the United States. It also cites Medina-Ramon and Schwartz (2007), which found that in 50 U.S. cities between 1989 and 2000, extreme heat increased death rates 5.7% while extreme cold increased death rates by only 1.6%. These results are summarized in the TSD.

Though we are aware of a recent study by Andersen and Bell (2009) that finds a similar mortality risk for extremely hot and cold days based on the synthesis of results from 107 U.S. communities (contrasting with Medina-Ramon and Schwartz), Andersen and Bell are clear that cold temperatures more indirectly affect mortality than heat. In addition to the longer lag times for exposure incorporated for the effects of extreme cold (up to 25 days, compared a one-day lag for heat), they note that infectious diseases, which are more common in industrialized countries during colder weather (when people spend more time indoors and in proximity) could account for a substantial portion of the cold-related effect.

Summarizing, both recent studies and the assessment literature provide strong evidence that heat-related mortality presently exceeds cold-related mortality in the United States


Comments?

Thursday, April 15, 2010

Eli can retire Part IX - PPP, MER, GDP AEIOU

From the US EPA responses to challenges to its Endangerment Finding for increasing CO2 concentrations, something economical

Comment (4-44):
A commenter (4632) objects to the emission scenarios produced by the IPCC because of critiques by Castles and Henderson (2003a, 2003b, 2005) that highlight the use of market exchange rates (not purchasing power parity) and the implausible assumption that poor nations will equalize per capita emissions with rich nations.

Response (4-44):
Both IPCC (2007) and CCSP (2007b) address the issue of using market exchange rate (MER) versus purchasing power parity (PPP) approaches in determining future gross domestic product (GDP) growth rates, in response to the critiques by Castles and Henderson (2003a, 2003b, 2005). The IPCC (Fisher et al., 2007) states the following:

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In the debate on the use of exchange rates, market exchange rates (MER) or purchasing power parities (PPP), evidence from the limited number of new PPP-based studies indicates that the choice of metric for gross domestic product (GDP), MER or PPP, does not appreciably affect the projected emissions, when metrics are used consistently. The differences, if any, are small compared to the uncertainties caused by assumptions on other parameters, e.g. technological change (high agreement, much evidence).
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The IPCC adds the caveat that, unlike emissions, the numerical expression of GDP does depend on conversion methods. CCSP (2007b) notes that while MER is used to set the base year of the models in that assessment, “growth prospects and other parameters for the world’s economies were assessed relative to their own historical performance” in order to avoid potential issues arising from interactions between the MER/PPP issue and assumptions regarding convergence.

While we find that both the IPCC and CCSP approaches yield credible estimates of future emissions that have been well supported by the literature, the robustness of conclusions based on emission projections developed through different means adds even more confidence that the TSD is appropriately summarizing the best existing science
Comments?

Wednesday, April 14, 2010

Denialists denied again

The Independent Inquiry headed by Lord Oxborough on the Climate Research Unit has reported. The wild charges (hi there Steve:) against the CRU were emphatically rejected by the Inquiry. To the right, Nelson well expresses our views on this failed denialist jihad. Like Tamino, Eli fears he will age waiting for apologies.

UPDATE: Eli will put up a separate post on this later but Rabett Run has many visitors at the moment. Besides the sporting aspect there is a great reason to shove these reports virgorously down the throats of some who will not be mentioned. Besides their uncalled for denigration of honorable scientists and excellent science, the alphabet soup of denialist think tanks has based their petition the US EPA for reconsideration of the CO2 Endangerment Finding on the CRU Emails. The various official inquiries reporting back on how vicious and vacuous the jihad has been strip the petitions and petitioners of standing. The more HaHa we generate leaves them standing naked in the public square. Believe Eli, an unclothed Tony Watts, is an ugly thing. (not that yrs truly is svelte, mind you, but he is cute, ask Ms. Rabett)

The charge of the Committee was

The Panel was set up by the University in consultation with the Royal Society to assess the integrity of the research published by the Climatic Research Unit in the light of various external assertions. The Unit is a very small academic entity within the School of Environmental Sciences. It has three full time and one part time academic staff members and about a dozen research associates, PhD students and support staff. The essence of the criticism that the Panel was asked to address was that climatic data had been dishonestly selected, manipulated and/or presented to arrive at pre-determined conclusions that were not compatible with a fair interpretation of the original data.
Keith Briffa (dendochronology), Phil Jones (surface temperature reconstructions) and their colleagues had been accused of data murder and rape by the usual suspects. The Inquiry finds these accusations to be infamous lies.

The Inquiry first recognizes something important about tree rings
Chronologies (transposed composites of raw tree data) are always work in progress. They are subject to change when additional trees are added; new ways of data cleaning may arise (e.g. homogeneity adjustments), new measurement methods are used (e.g. of measuring ring density), new statistical methods for treating the data may be developed (e.g. new ways of allowing for biological growth trends).
Much of the criticism came from the fly-in-amber school of science, where nothing ever changes, where initial publications must be perfect. The Inquiry report remarks that the nature of the dendro beast (and indeed, most other science) implies choices in data selection guided by experience, expertise and statistics. They ding the CRU for not having sufficient statistical expertise, but conclude
8. After reading publications and interviewing the senior staff of CRU in depth, we are satisfied that the CRU tree-ring work has been carried out with integrity, and that allegations of deliberate misrepresentation and unjustified selection of data are not valid. In the event CRU scientists were able to give convincing answers to our detailed questions about data choice, data handling and statistical methodology. The Unit freely admits that many data analyses they made in the past are superseded and they would not do things that way today.
The Inquiry demurs,
9. We have not exhaustively reviewed the external criticism of the dendroclimatological work,
Wise folk, wading into the Climate Audit swamp requires at least six months of cleaning under the nails afterwards, and they continue with extreme British understatement
but it seems that some of these criticisms show a rather selective and uncharitable approach to information made available by CRU. They seem also to reflect a lack of awareness of the ongoing and dynamic nature of chronologies, and of the difficult circumstances under which university research is sometimes conducted. Funding and labour pressures and the need to publish have meant that pressing ahead with new work has been at the expense of what was regarded as non-essential record keeping. From our perspective it seems that the CRU sins were of omission rather than commission.
The last bit is the one you are going to see at Climate Audit
Although we deplore the tone of much of the criticism that has been directed at CRU, we believe that this questioning of the methods and data used in dendroclimatology will ultimately have a beneficial effect and improve working practices
without the first line which will be left in the quote mine.

On to Phil Jones and the CRUTEMP surface temperature reconstructions.
4. Like the work on tree rings this work is strongly dependent on statistical analysis and our comments are essentially the same. Although there are certainly different ways of handling the data, some of which might be superior, as far as we can judge the methods which CRU has employed are fair and satisfactory. . . .

All of the published work was accompanied by detailed descriptions of uncertainties and accompanied by appropriate caveats. The same was true in face to face discussions.
5. We believe that CRU did a public service of great value by carrying out much time-consuming meticulous work on temperature records at a time when it was unfashionable and attracted the interest of a rather small section of the scientific community.
Reaching an overall conclusion about the CRU's work
1. We saw no evidence of any deliberate scientific malpractice in any of the work of the Climatic Research Unit and had it been there we believe that it is likely that we would have detected it. Rather we found a small group of dedicated, if slightly disorganised, researchers who were ill-prepared for being the focus of public attention. As with many small research groups their internal procedures were rather informal.
The Inquiry picks up on James Annan's point that governments are insisting on charging for data they create while demanding that it be free to all. And, horrors, they come pretty close to recommending that FOI laws be modified to prevent their vexious use
4. A host of important unresolved questions also arises from the application of Freedom of Information legislation in an academic context. We agree with the CRU view that the authority for releasing unpublished raw data to third parties should stay with those who collected it.
George Monbiot will call it white wash

Eli thanks Tracy and http://nelsonhaha.com for the appropriate comment

Monday, April 12, 2010

Eli can retire Part VIII - The EPA reads Rabett Run

Well, well, well, Eli discovers that the EPA reads everything, including Rabett Run. We are honored. From the US EPA responses to challenges to its Endangerment Finding for increasing CO2 concentrations

Comment (3-45):
A number of commenters believe that anthropogenic global warming is impossible, many citing arguments made by Gerlich and Tscheuschner (2009). Several commenters (e.g., 0430) note that the greenhouse effect is not like a real greenhouse. Several claim that it is thermodynamically impossible because heat cannot be transferred from a cool substance to a warmer substance (0430, 2210.5): for example, blankets cannot make you warmer than body temperature (1707, 0183.1,). Another thermodynamic argument for the impossibility of the greenhouse effect was proposed by two commenters (2210.3, 4509) citing Gerlich and Tscheuschner (2009) who states that the greenhouse effect as commonly formulated violates the Second Law of Thermodynamics. Another commenter (0711.1) requests evidence of any peer reviewed climate change paper that does not rely on computer simulation. Another theory (2887.1) holds that long-wave radiation will cause increased evaporation of the surface ocean, negating any heat increase. One commenter (0535) submitted a non-peer reviewed paper providing a different explanation for the net energy budget of the Earth, with no role for warming by CO2.

Response (3-45):

The evidence for the atmospheric greenhouse effect is well supported by the scientific literature.

The objections raised by a number of commenters to the basic thermodynamics are without grounds. We are well aware that the greenhouse effect is not at all like a real greenhouse. However, the analogy of a blanket is a little bit better: and indeed, sufficiently insulating blankets can cause overheating. GHGs (blankets) will, by reducing the rate of heat loss, raise the surface temperature of the Earth (body) until a new thermodynamic balance is achieved between incoming solar radiation (internal body heating) and outgoing thermal radiation (in the case of a blanket, including convection and non-radiative processes). This process works regardless of whether the atmosphere (blanket) is cooler than the surface (body). We are aware of the paper by Gerlich and Tscheuschner, and we have determined that the conclusions of the paper are inconsistent with the well-supported literature regarding the mechanism of the greenhouse effect. For example, as a disproof of the greenhouse effect, the paper by Gerlich and Tscheuschner presents the example of a pot of water, noting that the bottom of the pot will be cooler if it is filled with water than if it is empty. Contrary to the assertion in the paper, the primary thermal effect of adding water to the pot is not a reduction in heat transfer, but rather an increase of thermal mass. We assert that a more appropriate example for the paper to have examined would have been the addition of a lid to a pot of water, which reduces the rate of heat loss, and leads to an increase of heating of the water compared to a case with no lid. The paper by Gerlich and Tscheuschner is also inconsistent with the scientific literature with regards to the interpretation of radiative balance diagrams and the assertion that there is no “mean temperature” of the Earth, in contrast to the hundreds of peer-reviewed publications and many assessment reports which use both concepts.
You read it first at Rabett Run
This, of course, neglects the latent heat carried away from the pot and thus the heating element by evaporation of the water in the pot. Since it is well known that people who are physics obsessed are often forgetful, we postulate that the housewife forgets that she has put the pot on the range, and all the water boils away. At that point, when all the water has evaporated, measurements show that the heating element rises to a higher temperature than it was before the tea pot was placed on it.
and, of course, there are the famous Rabett blanket posts

EPA Rocks!!

Saturday, April 10, 2010

Eli can retire Part VII - The EPA plays so's your old man

Well, well, well, Eil discovers that the EPA reads everything, and laughs at some of them. From the US EPA responses to challenges to its Endangerment Finding for increasing CO2 concentrations

Comment (1-12):
Several commenters (1924, 2898.1, 3214.1, 3330.1, 3389, 3446.2, 3560.1, 3679.1, 3748.1, 3969.1, and 4172) argue that EPA should base its endangerment finding on the recent Nongovernmental International Panel on Climate Change (NIPCC) report entitled Climate Change Reconsidered, instead of IPCC and CCSP reports.

Response (1-12):
EPA has reviewed and considered the NIPCC report and found that it lacks the rigorous procedures and transparency required to serve as a foundation for the endangerment analysis. A review of the NIPCC Web site indicates that the NIPCC report was developed by “two co-authors” and “35 contributors and reviewers” from “14 countries (http://www.nipccreport.org/index.html). The organization does not appear to have established any procedures for author selection and provides no evidence that a transparent and open public or expert review was conducted. Thus, the NIPCC’s approach stands in sharp contrast to the clear, transparent, and open procedures of the IPCC, CCSP, USGCRP, and NRC. Relying on the work of the major assessment reports is a sound and reasonable approach. See Section III.A. of the Findings, “The Science on Which the Decisions Are Based,” for our response to comments on the use of the assessment literature and previous responses in this section regarding our treatment of new and additional scientific literature provided through the public comment process.

Although EPA sees no reason to base the endangerment analysis on the NIPCC, we did thoroughly review the report and the associated references. For EPA’s responses to comments and literature provided on specific climate science issues in the TSD, including the work of the NIPCC, please refer to the appropriate Response to Comment volumes.
Don't wanna mess with those guys

Thursday, April 08, 2010

Eli can retire Part VI - Going where the sun don't shine

Ms. Rabett told Eli to get off his tired old well the bunnies know what, and go where the sun don't shine. So the Rabett dialed up the US EPA responses to challenges to its Endangerment Finding for increasing CO2 concentrations and considered the matter of solar influences

Comment (3-35):
A number of commenters (e.g., 0670) argue that the sun is the primary driver of global temperature changes. Several commenters (3323.1, 4003, 4041.1, 4932.1, and 5158) referred to a new 2009 paper by Scafetta and Willson suggesting that the IPCC used faulty solar data in dismissing the direct effect of solar variability on global temperatures. Commenters also cite other research by Scafetta and others that suggests that solar variability could account for up to 68% of the increase in Earth’s global temperatures. One commenter (1616.1) attributes 0.14°C of the warming since 1950 to increased solar irradiance, and another 25% of warming since 1979, as in Scafetta and West (2006) (3596.1). Another commenter (7031) states that the correlation between solar variations such as sunspots and global climate has been pointed out by several scientists, such as Scafetta and West (2008). A number of specific climate-related regional phenomena have been related by commenters (e.g., 3596.1) to solar variability, such as sea surface temperature, floods, droughts, monsoons, and North Atlantic drift ice.

Response (3-35):
We have reviewed the comments and the literature submitted and have determined that changes in solar irradiance are not a sufficient explanation for recent climate change. The contention that direct solar variability can explain recent warming is not supported by the bulk of the scientific literature. As the TSD notes, the IPCC Fourth Assessment Report estimates that changes in solar irradiance since 1750 are estimated to cause a radiative forcing of +0.12 (+0.06 to +0.30) W/m2, or approximately 5% of the combined radiative forcing due to the cumulative (1750–2005) increase in atmospheric concentrations of CO2, CH4, and N2O (2.30 W/m2 with an uncertainty range of +2.07 to +2.53 W/m2). The natural 11-year cycle of solar irradiance has a magnitude of less than 2 W/m2 at the distance of the Earth—which, once corrected for albedo and distribution over the surface area of the planet, is a magnitude of less than 0.35 W/m2.

In addition, Karl et al. (2009) state that “if most of the observed temperature change had been due to an increase in solar output rather than an increase in GHGs, Earth’s atmosphere would have warmed throughout its full vertical extent, including the stratosphere. The observed pattern of atmospheric temperature changes, with its pronounced cooling in the stratosphere, is therefore inconsistent with the hypothesis that changes in the Sun can explain the warming of recent decades. Moreover, direct satellite measurements of solar output show slight decreases during the recent period of warming.” A number of other recent studies also show results that contrast with the interpretation that solar variability is driving recent warming. Both Lockwood and Fröhlich (2008) and Lean and Rind (2009) show that the solar contribution to warming in recent decades has been small or negative, consistent with the IPCC attribution of most of the warming in recent decades to anthropogenic GHGs.

The attribution of components historical climate change to solar activity involves a number of issues. The first is the actual reconstruction of historical solar activity: even for the last three decades there is some controversy, as is evident in the differences between Scafetta and Willson (2009), which uses a total solar irradiance composite from the Active Cavity Radiometer Irradiance Monitor (ACRIM) analysis of satellite data, and Lockwood and Fröhlich (2008), which uses a composite based on the Physikalisch- Meteorologisches Observatorium Davos (PMOD) analysis of satellite data. These two composites don’t even agree on the sign of the solar irradiance trend over this time period.

Lockwood and Frolich analyze both datasets and find that the ACRIM dataset is inconsistent with methods of historical reconstructions that have shown correlations between historical solar activity and climate. Krivova, Solanki, and Wenzler (2009) also find no evidence of an increase in total solar irradiance (TSI) from 1986 and 1996 using an analysis based on magnetograms. Scafetta and Willson, on the other hand, claim that the PMOD approach requires a correction of the data from the earth radiation budget (ERB) system on the NIMBUS7 satellite, and this correction has been rejected by one of the scientists on the NIMBUS team (D.V. Hoyt, personal communication to Scafetta, 2008). Neither dataset shows an increase of solar irradiance between the minima of 1986 and 2008, which would be required in order to explain warming over that period.

Therefore, reconstructions of recent solar variability do not agree, but in one case show no trend, and in the case of the Lockwood and Fröhlich reconstruction the solar contribution during this period would have been a cooling, not warming, influence.

The second issue is that in order for solar irradiance to be a major driver of recent warming, there must be an amplification effect that is active for solar irradiance that is not active for forcing due to GHGs. Studies such as Scafetta (2009) often rely on a significantly different factor for solar irradiance than is used for GHG climate sensitivity. Additionally, the Scafetta study relies on a “slow lag” solar response and the timescale chosen has itself been the subject of dispute. The climate sensitivity for this slow lag response used by Scafetta is 0.46° K/Wm-2. Note that this is compared to the total solar irradiance: therefore, the effective sensitivity to the average solar irradiance according to Scafetta would be (4*0.46)/0.7 = 2.6° K/Wm-2. This can be compared to a climate sensitivity range of 2 to 4.5, or about 0.5° K/Wm-2 to 1.2° K/Wm-2. Additionally, Scafetta claims that solar variability accounts for most of the recent warming and that GHG sensitivity is on the low end of the range: this means that Scafetta is effectively claiming that sensitivity to solar variability is on the order of five times the sensitivity to forcing by GHGs, without a good mechanism to explain this extreme difference. Although it is not impossible that there are differences between solar and GHG induced changes, the evidence for an amplification of the magnitude needed to explain recent warming is weak. For example, while Meehl et al. (2009) find an amplification of the solar cycle variability is needed to explain certain patterns of tropical Pacific climate response, the authors note: “This response also cannot be used to explain recent global warming because the 11-year solar cycle has not shown a measurable trend over the past 30 years.”

Moreover, the sensitivity needed is nowhere near as large as the Scafetta sensitivity, and the behavior explained is geographically localized, which is different from a global increase in sensitivity. Therefore, the evidence for an amplification of the magnitude needed to explain recent warming is weak.

Some other authors also show some correlations between solar variability and regional trends. Eichler et al. (2009) find a strong correlation between solar activity (as reconstructed by carbon-14 and beryllium-10 proxies) and temperatures in the Siberian Altai region. However, the authors note that “underlying physical processes are still not yet understood” in terms of amplifying a weak solar signal (in terms of radiative forcing) in order to see larger effects, and also that “[i]n large spatial scale hemispheric or global reconstructions the solar signal may therefore even vanish” because the “main effect of solar forcing is presumably on location, routes, and stability of atmospheric pressure systems, which all act on regional scales.” The conclusion of the Eichler work is that while solar activity was a main driver for temperature variations in the Altai region preindustrially, during the industrial period they found that only CO2 concentrations show a significant correlation with the temperature record. They did find agreement with the northern hemisphere (NH) temperature reconstruction of Scafetta and West (2007) in that they found that only up to approximately 50% of the observed global warming in the last 100 years can be explained by the sun. Note that this conclusion provides 50% as an upper limit to the explanatory power of solar variability, and this is for the full century. Therefore, for the last 50 years, this conclusion is still consistent with the IPCC (2007b) statement that “[m]ost of the observed increase in global average temperatures since the mid-20th century is very likely due to the observed increase in anthropogenic greenhouse gas concentrations.”

Therefore, to summarize: attempting to attribute late-20th century temperature change mainly to solar variability requires choosing a specific solar dataset, assuming a simplified model with different “fast” and “slow lag” responses based on timescales from a controversial paper, and assuming that the climate system is several times more sensitive to changes in solar irradiance (or other, non-radiative changes in the sun) than it is to changes in GHG forcing. All three of these assumptions are counter to the conclusions of the IPCC and CCSP assessments and not viewed as established conclusions in the literature. While science in this area will continue to evolve, our review did not uncover any compelling alternatives to the science represented in the assessment literature, and summarized in the TSD.
Ho Ho Hummmm.