Denialist attack on EPA handling of Carlin global warming contrarian document– Pt 1: The document


The global warming disinformation campaign – politicians, media, ideologue politicos – has falsely and disingenuously accused the Environmental Protection Agency (EPA) of suppressing climate science and censoring a climate science whistleblower.  Part 1 in a series:  What to make of the Carlin document?

Comments by Rick Piltz
Background by Alexa Jay


For those who have not been following this incident:

On June 25, the Competitive Enterprise Institute (CEI) released a March 16 document authored by two EPA career employees that questions the science behind EPA’s proposed “endangerment finding” that greenhouse gases in the atmosphere endanger the public health and welfare of current and future generations.  The proposed endangerment finding was published in the Federal Register for a 60-day public comment period that ended June 23.  The endangerment finding is the first step in a process under which EPA could regulate emissions of greenhouse gases under the Clean Air Act. 

The document, entitled “Proposed NCEE Comments on Draft Technical Support Document for Endangerment Analysis for Greenhouse Gas Emissions under the Clean Air Act,” was written by economist Alan Carlin and physicist John Davidson, both employees of the EPA’s National Center for Environmental Economics. 

The Carlin and Davidson March 2009 draft document, “Proposed NCEE Comments on Draft Technical Support Document for Endangerment Analysis for Greenhouse Gas Emissions under the Clean Air Act”

Carlin (now sole author) comments document with June 27 update statement

Carlin personal website

Carlin suggests that, in the Draft Technical Support Document, EPA improperly accepted findings of other bodies including the Intergovernmental Panel on Climate Change and the U.S. Climate Change Science Program “without a careful and critical examination of their own conclusions and documentation,” and that recent developments in climate science have rendered the science used in the report obsolete.

Carlin alleges that his comments on the draft Technical Support Document were suppressed by his superiors, citing his leaked emails as evidence.  In these emails, Carlin asked Al McGartland, the director of the EPA economics office, to forward his comments to the office responsible for managing the development of EPA’s endangerment finding.  McGartland refused, remarking that “the administrator and the administration has decided to move forward on endangerment and your comments do not help the legal or policy case for this decision.” 

As quoted in Environment & Energy Daily, EPA spokeswoman Adora Andy commented on the public release of the e-mails, noting that Carlin is not a scientist and was not part of the working group that dealt with the endangerment issue.  “Nevertheless, several of the opinions and ideas proposed by this individual were submitted to those responsible for developing the proposed endangerment finding.  Additionally, his manager allowed his general views on the subject of climate change to be heard and considered inside and outside of the EPA and presented at conferences and at an agency seminar.”  Carlin was told that he was free to post the report on his own website, which he did, with the disclaimer that the views expressed were his own rather than EPA’s.   

The document and Carlin’s allegations have been touted by members of Congress who have opposed climate change legislation and by policy commentators.  They claim these are evidence that the Obama administration used strong-arm tactics to quiet dissenters and both move forward with its position that greenhouse gases threaten human health and welfare and hustle climate change legislation through the House.  Rep. Joe Barton (R-TX), the ranking member of the House Energy and Commerce Committee, sent a letter to EPA Administrator Lisa Jackson that called into question the “integrity, transparency, and completeness of the EPA’s rulemaking process” for the proposed endangerment finding. Rep. James Sensenbrenner (R-WI), ranking member of the House Select Committee on Energy Independence and Global Warming, along with House Oversight Committee ranking member Darrell Issa (R-CA), sent a letter to Jackson accusing the agency of setting a predetermined course for the report in line with the administration’s political goals.  Sensenbrenner and Issa’s letter calls on EPA to re-open the comment period for its Proposed Endangerment and Cause and Contribute Findings for Greenhouse Gases Under the Clean Air Act, which took place from April 24 to June 23, 2009.  Sen. James Inhofe (R-OK), along with Sen. John Barrasso (R-WY), sent a letter dated June 30 to Jackson calling for an investigation. 

Carlin and Davidson’s chief concerns are as follows: “The current Draft TSD is based largely on the IPCC AR4 report, which is at best three years out of date in a rapidly changing field. There have been important developments in areas that deserve careful attention in this draft.”  They identify these developments as the decline in global temperatures over the past 11 years; the changing consensus on the future of Atlantic hurricane behavior as related to anthropogenic global warming; recent evidence that Greenland has not been rapidly shedding its ice sheet in the manner predicted; the decline in greenhouse gas emissions caused by the current economic recession and its effect on future public health and welfare; a new paper disputing the IPCC’s use of the assumption concerning strongly positive feedback from water vapor; a 2009 paper suggesting that solar variability could account for up to 68% of the increase in Earth’s global temperatures; and the “obvious logical problem posed by steadily increasing US health and welfare measures and the alleged endangerment of health and welfare discussed in this draft TSD during a period of rapid rise in at least CO2 ambient levels.” 

Carlin and Davidson say that “these inconsistencies are so important and sufficiently abstruse that in our view EPA needs to make an independent analysis of the science of global warming rather than adopting the conclusions of the IPCC and CCSP without much more careful and independent EPA staff review than is evidenced by the Draft TSP.”


Chris Mooney did an excellent analysis of this incident on Science Progress on July 1.

Also read Joe Romm’s post on Climate Progress on June 30:

And see TPMMuckraker’s post post following an interview with Carlin.

This cases raises a number of questions, including:

1.  What to make of the Carlin-Davidson comments/report?
2.  What to make of the leaked McGartland-Carlin e-mails?
3.  What to make of the charges by Rep. Barton, Sensenbrenner, and Issa and Sens. Inhofe and Barrasso, and what should EPA and Congress do about it?

1.  What to make of the Carlin document?

NASA Goddard Institute for Space Studies climatologist Gavin Schmidt reviewed the scientific validity of the Carlin-Davidson document in a June 26 post on RealClimate. Schmidt, who, unlike Carlin, is a climate scientist, eviscerates and dismisses it.  This is a must-read. 

Schmidt’s 900-word post is incisive, with some snarky wit aimed at a target that is, in this case, deserving, for their channeling of global warming contrarians and denialists.  Schmidt concludes with this:

Finally, they end up with the oddest claim in the submission: That because human welfare has increased over the twentieth century at a time when CO2 was increasing, this somehow implies that no amount of CO2 increases can ever cause a danger to human society. This is just boneheadly stupid.

So in summary, what we have is a ragbag collection of un-peer reviewed web pages, an unhealthy dose of sunstroke, a dash of astrology and more cherries than you can poke a cocktail stick at. Seriously, if that’s the best they can do, the EPA’s ruling is on pretty safe ground.

If I were the authors, I’d suppress this myself, and then go for a long hike on the Appalachian Trail….

Carlin and Davidson attempt, without any showing that they have a grasp of its contents, essentially to dismiss the comprehensive IPCC 2007 4-volume scientific assessment report.  The IPCC assessment underwent four rounds of international scientific and governmental review.  They also dismiss the 21 synthesis reports produced for the U.S. Climate Change Science Program (CCSP) in 2007-2009, as being allegedly so outdated and inaccurate that they are irrelevant as a basis for developing conclusions about anthropogenic climate change and its likely harmful consequences. This is preposterous.

They assert that, instead of relying on these “outside” sources, EPA should have performed its own independent scientific assessment of climate change.  As if EPA should have, in-house, the capability to supplant the massive IPCC synthesis prepared by hundreds of the world’s leading scientists and reviewed by the international community of experts.  And as if the CCSP were something other than the federal government’s own climate research program, in which EPA and 12 other agencies participate.  EPA served as the lead or a participating agency on a number of the 21 synthesis reports. 

In place of the massive mainstream scientific literature, they put forward what the science news blog in the eminent journal Nature refers to as “mostly a re-hash of old, scientifically dubious arguments” – drawn heavily from cherry-picked, non-peer-reviewed literature by authors whose views have been addressed and rejected by most of their colleagues in the community

This attempt to toss out the IPCC was predictably seized upon by denialists in Congress, who are ever-eager to turn their backs on the mainstream science community and the overwhelming weight of its findings and conclusions.  Instead they elevate outlier science and pseudo-science to suit their political game plan.  The comprehensive reports produced by the IPCC (as well as reports by other leading organizations, in particular the National Academy of Sciences), along with subsequent research by IPCC- and Academy-caliber scientists, and communication based on such authoritative sources, are precisely the kind of work that policymakers, journalists, activists, and the general public, should rely on.  EPA economists who are showing the appropriate level of professionalism will do this and not just make up an alternative reality as to what should be considered credible.  On this alone, Carlin and Davidson deserved to be slapped down by their management for proposing to put forward, as official comments of the EPA National Center for Environmental Economics, a position that would seriously undermine the credibility and integrity of their office. 

A July 3 post on the DeSmogBlog site – an important source of information and commentary on the global warming disinformation campaign – pointed out that substantial chunks of the Carlin-Davidson document are lifted directly, in some cases without attribution – i.e., one could say plagiarized – from well-known contrarian and pseudo-science sources:

The report…has been posted on the websites of the Heartland Institute, the Competitive Enterprise Institute, and several other think tanks with a record of using any excuse to deny climate change science….

The person listed as the author of the report, Alan Carlin, is not a scientist, but an economist who works for National Center for Environmental Economics. But Carlin also had some help.

Several years ago, Ken Gregory of the Astroturf group Friends of Science compiled an eye-glazing compendium of pseudo science questioning climate change. Real Climate points out that Carlin has imported sections of this verbatim, crediting Gregory 20 times in the report.

Carlin also referenced Christopher Monckton and S. Fred Singer, a politician and a lapsed scientist, both of them darlings of the denial industry.

But what about un-referenced sources? Plugging Carlin’s report into Plagiarism revealed a whole series of unreferenced sections lifted verbatim from one of the deans of the denial industry, Patrick Michaels, Senior Fellow at the Cato Institute….

Plagiarism is a serious academic offence, particularly if it involves obviously biased sources. It is therefore ironic that Carlin’s unsolicited 85 page report, on a subject well outside his area of expertise, is devoted to criticizing the scientific community for their shoddy work.

This week an indignant Senator James Inhofe demanded an inquiry into this strange report. Maybe that’s not such a bad idea.

John Holdren, then of Harvard University and now the President’s Science Adviser, once said about Pat Michaels to the Senate Republican Policy Committee, “Michaels is another of the handful of US climate-change contrarians… He has published little if anything of distinction in the professional literature, being noted rather for his shrill op-ed pieces and indiscriminate denunciations of virtually every finding of mainstream climate science.”

See our earlier posts here and here.

The fairly new Deep Climate site has done a series of three posts (here, here, and here) that further develop a picture of the Carlin document with some caustic commentary.  Deep Climate is a welcome effort that looks at “the organizations that propagate climate science disinformation and the public relations professionals who have worked behind the scenes to ensure maximum impact of that disinformation.” 


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