Thursday, November 20, 2008

How Bad Laws Get Enacted

By Alan Caruba

The way the Greens have imposed their agenda on America has largely been through deception, an often multi-layered effort to create the appearance of an environmental reality that does not exist.

A classic example of that is the current effort of the Environmental Protection Agency to regulate so-called greenhouse gas emissions, primarily carbon dioxide (CO2) that is wrongly presented as the cause of a non-existent global warming.

Other than oxygen, there is no other gas more essential to life on Earth than CO2. Regulating it is absurd!

The Heartland Institute, a non-profit, free market think tank, has just filed its first comment on the Environmental Protection Agency's Advance Notice of Proposed Rulemaking (ANPR) on "Regulating Greenhouse Gas Emissions under the Clean Air Act" which was published in the Federal Register on July 30, 2008. The deadline for public comments is November 28, 2008.

The complete Heartland comment is available online:

Among the objections The Heartland Institute noted was that the ANPR and its supporting documentation violate the Information Quality Act and "EPA Guidelines.”

“Much of the scientific evidence put forth by EPA staff in the proposed ANPR and its Technical Support Document (TSD) has taken the melodramatic form of climate alarmism without the appropriate balance of scientific and economic rationale that should have bearing on any environmental policy established by the Environmental Protection Agency.”

“There is a significant omission of climate science data published after 2006 and no coherent review of the debate in scientific literature. There is little evidence in the EPA Endangerment TSD to indicate that the climate is warming. The data provided are inaccurate and biased.”

And that, ladies and gents, is how you pass off bad science as good science.

The Heartland Institute evaluation further noted that the EPA cannot rely on incomplete draft documents to regulate greenhouse gas emissions.

“The draft of the EPA Endangerment TSD is based upon the National Oceanic and Atmospheric Administration (NOAA) Synthesis Report that was published for comment on July 17, 2008 and subsequently withdrawn. Only eight of the 21 underlying Synthesis and Assessment Products (SAP) had been finalized. NOAA withdrew its Synthesis Report after numerous complaints about the deficits it contained under the Information Quality Act. No further SAPs have been published, so what the ANPR includes by way of scientific documents is a draft based on a draft.”

Need it be said that the EPA relies on a U.N. Intergovernmental Panel on Climate Change report that suggests there is an anthropogenic (human) cause for global warming, but it does not cite any reports suggesting global warming may be due to natural causes?

“There are no studies of the relationships between shifting ice sheets and atmospheric temperatures."

"The IPCC report ignores the role of solar activity upon global temperatures. There is no discussion of the dynamic relationship between water vapor and global temperature.
These factors must be taken into consideration when determining the cause of increases in global temperatures and certainly when developing a national policy to establish a form of government climate control. Such a regulation would be pointless if the cause of global warming is not anthropogenic emissions.”

"The ANPR data are deficient because they rely upon the IPCC documents that link manmade greenhouse gas emissions to climate change based upon now-discredited computer modeling."

This is how this proposed regulation is being offered for comment and the Heartland Institute did not shrink from commenting “In short, the draft of the ANPR is a large regulation looking for a scientific basis."

"It provides sweeping powers across political and legal jurisdictions without a full hearing of the scientific, legal, or economic consequences of its implementation. EPA should not proceed without the full consent of Congress and a scientifically measurable guideline for success or failure of its outcomes.”

The lack of any real science behind most of what passes for environmental legislation and regulation is the factor that most distinguishes it.

This proposed regulation has no basis in fact, no support except from the usual flawed and often deliberately misleading “computer models” that the IPCC and others conjure up at a keystroke.

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