(Article by Paul Driessen republished from TownHall.com)
EPA turned CO2 into a “dangerous pollutant” and ruled that fossil fuels must be eradicated. The agency subsequently used its EF to justify tens of billions of dollars in climate research, anti-fossil fuel regulations, and wind and solar subsidies; President Obama’s signing of the Paris climate treaty; and proposals to spend trillions of dollars a year on Green New Deal (GND) programs.
And yet, despite multiple demands that this be done, there has never been any formal, public review of the EF conclusion or of the secretive process EPA employed to ensure the result of its “analysis” could only be “endangerment” – and no awkward questions or public hearings would get in the way.
Review, transparency and accountability may finally be on the way, however, in the form of potential Executive Branch actions. If they occur – and they certainly should – both are likely to find that there is no valid scientific basis for the EF, and EPA violated important federal procedural rules in rendering its predetermined EF outcome. (One could even say the EF was obtained primarily because of prosecutorial misconduct, a kangaroo court proceeding, and scientific fraud.) Failure to examine and reverse the EF would mean it hangs like Damocles’ sword over the USA, awaiting the next climate-focused president.
To the consternation and outrage of climate alarmists, keep-fossil-fuels-in-the-ground radicals, and predictable politicians and pundits, President Trump may soon appoint a Presidential Committee on Climate Change, to review “dangerous manmade climate change” reports by federal agencies.
Meanwhile, the Competitive Enterprise Institute has filed a formal petition with EPA, asking that the agency stop utilizing and relying on the EF – and instead subject the finding to a proper “high level” peer review, as required by the Information Quality Act. The reasoning presented in CEI’s succinct and persuasive petition is compelling. Its main points are these.
* EPA’s Endangerment Finding and the Technical Support Document (TSD) that supposedly justifies it did not meet Information Quality Act (IQA) requirements for how the work should have been done.
* The agency’s evaluation of the then-current climate change and related science was clearly a “highly influential scientific assessment” (HISA), which triggered important IQA and OMB rules governing rulemakings that have “a potential impact of more than $500 million in any year” … or present “novel, controversial or precedent-setting” changes … or would likely raise “significant interagency interest.”
* EPA’s “Clean Power Plan” to shut down coal-fired power plants alone would cost $2.5 billion in annual compliance costs, EPA admitted. Its motor vehicle rules would cost tens of billions. The Paris agreement and GND would add trillions per year in costs to the US economy. All are based on the EF. And all were certainly controversial and generated significant interest by multiple other government agencies.
* EPA deliberately downplayed the significance of its review and decision, ignored the IQA and OMB requirements, and refused to allow citizens, independent energy, climate and health experts, or even scientific and professional societies to nominate potential reviewers or participate in the EF analysis.
* Instead, the agency utilized an entirely internal review process, designed and conducted entirely by its own federal employees. Those employees had substantial conflicts of interest, because they were reviewing their own scientific work; would be writing, implementing and enforcing regulations based on that work; and had jobs and professional status that might be affected by the outcome of their review.
[The review team even summarily dismissed one of EPA’s most senior energy and economic experts, because his probing analyses and comments “do not help the legal or policy case” for the EF decision.]
* EPA never allowed the general public or scientific, energy, health or economic experts to review its draft scientific assessment; never sponsored any public meetings; and never let its internal peer reviewers see any of the public comments that outside experts and organizations submitted to the agency.
* In fact, none of the EPA peer review panel’s questions and responses have ever been made public.
Each of these actions violated specific IQA and OMB peer review guidelines. Indeed, two years after the Endangerment Finding was issued, even EPA’s own Inspector General found that that agency had violated rules governing all of these matters. And yet even then nothing was done to correct them.
Read more at: TownHall.com
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