Comments from The Heartland Institute Submitted to EPA Regarding the Advanced Notice of Proposed Rulemaking for Greenhouse Gases Under the Clean Air Act

Published November 28, 2008

The hard science of global warming is extremely complex, involves many scientific disciplines, and is in its infancy. As noted atmospheric scientist Professor Richard Lindzen of the Massachusetts Institute of Technology recently wrote, climatology is “a small weak field.” As such, he added, “it has traditionally been a subfield within such disciplines as meteorology, oceanography, geography, geochemistry, etc. These fields, themselves are small and immature.” Against a small, weak, and immature scientific background, regulation is unwarranted, irrational, arbitrary and capricious.

Unlike global warming alarmism, the NIPCC Report does not rely on “consensus” that the science is “settled,” nor should it. As Dr. Singer and Dennis Avery wrote, “Galileo may have been the only man of his day who believed the Earth revolved around the sun,but he was right.”

The NIPCC expresses plausible scientifically-sound alternative explanations about anthropogenic global warming with full citation of authorities. It candidly identifies areas where more research is required. After all, as Professor Lindzen wrote, “Science has traditionally been held to involve the creative opposition of theory and observation

wherein each tests the other in such a manner as to converge on a better understanding of the natural world.” Much more study is needed before EPA can make any scientifically sound judgment about the role, if any, of carbon dioxide and the other five greenhouse gases in causing global warming.

For the foregoing reasons, EPA should decline to proceed any further with greenhouse gas regulation under the Clean Air Act.