Comments of The American Farm Bureau Federation, Deseret Power Electric Cooperative and Sunflower Electric Power Corporation on EPA’s Proposed Endangerment Finding

The American Farm Bureau Federation, Deseret Power Electric Cooperative, and Sunflower Electric Power Corporation argue that the Endangerment Finding and supporting technical documents are arbitrary and capricious and violate the Information Quality Act because they present an incomplete and imbalanced science discussion, ignoring “literally hundreds of peer-reviewed scientific articles that are at odds with major portions of EPA’s conclusions.” They request that EPA reexamine its science and issue a new Endangerment Finding for public comment.

The filing is supported by scientific literature reviews by Dr. Craig Idso, chairman of the Center for the Study of Carbon Dioxide and Global Change, and Professor Patrick Michaels of the University of Virginia. Dr. Idso is co-author, along with Dr. S. Fred Singer, Ph.D., of Climate Change Reconsidered: The 2009 Report of the Nongovernmental International Panel on Climate Change (NIPCC), published by The Heartland Institute on June 2, 2009.