NEPA Guidance for CO2 Emissions Is Bad Policy Based on Bad Science

Published March 31, 2015

Climate Change Weekly #165

Marlo Lewis, senior fellow with the Competitive Enterprise Institute, drafted a powerful rebuke of the Council on Environmental Quality’s recent draft guidance to require a National Environmental Policy Act (NEPA) review of potential climate change effects caused by increased levels of greenhouse gas emissions from federal projects and projects requiring federal permits.

Representatives from 14 research and policy organizations, including The Heartland Institute, and one university signed on to Lewis’s comments.

NEPA, passed in 1970, requires federal agencies to consider the environmental effects of any major federal, state, or local project involving federal funding, work performed by the federal government, or permits issued by a federal agency. It also established the Council on Environmental Quality (CEQ), which sets guidelines concerning the proper way for federal agencies to conduct and report environmental impact analyses.

The draft guidance would require major projects to account for greenhouse gas emissions and potential climate impacts. Lewis’s brief argues climate policy should not be made via NEPA.

Lewis and the co-signers, including myself, see the draft guidance as a case of bad policy based on bad science.

CEQ’s draft guidance is based on the Environmental Protection Agency’s (EPA) acceptance of the Intergovernmental Panel on Climate Change’s (IPCC) 2007 assessment that claimed humans are causing catastrophic global warming. As Lewis points out, the IPCC report missed the “18-year-plus warming ‘pause;’ the growing divergence between climate model predictions and observations; studies finding lower climate sensitivity; studies finding no global trends in the behavior of tropical storms, floods, and droughts; and studies rendering climate catastrophe scenarios implausible for the 21st century.”

Lewis says requiring environmental impact assessments for potential climate effects of all major projects will result in Keystone XL-like delays and controversy becoming the new norm for federal or federally funded projects, tying up necessary and/or economically desirable infrastructure and other projects for years. In this scenario, only radical environmentalists and other leftists who wish to destroy capitalism win.

Importantly, CEQ’s decision to follow EPA’s endangerment finding ignores these facts:

  • Our predominantly fossil-fueled civilization did not take a safe climate and make it dangerous. Rather, households and industries empowered with cheap, plentiful, reliable fossil energy took a naturally dangerous climate and made it dramatically safer.
  • Because affordable energy and economic growth are keys to human mastery of climate-related risks, blocking energy-related-development projects will do more harm than good to public health and welfare.

Lewis’s letter concludes the NEPA review is an inappropriate framework for making climate policy. All the important evidence suggests project-related greenhouse gas emissions should not be a factor when determining whether agencies grant or deny permits for individual projects and, as a result, CEQ should withdraw the guidance.

As is often the case when Lewis pens something, I wish I had written it myself. I was flattered to be asked to sign on.

— H. Sterling Burnett

SOURCE: Letter by Marlo Lewis, Ph.D., to the Council on Environmental Quality


Fossil fuels will save the world … Pollution’s small temperature effect … Climate change, it’s about science not money … Severe weather predictions wrong again! … Americans not alarmed about climate change … Climate alarmist paradigm collapsing


The arguments made by environmentalists for jettisoning the use of fossil fuels in recent years have been severely flawed. As British science journalist Lord Matt Ridley points out, claims we are running out of oil ran aground on shale rock when the fracking revolution picked up steam in the past decade. Despite promises and enormous subsidies, renewables are still unable to match the price or reliability of fossil energy in the global energy marketplace, and it is becoming increasingly apparent Earth’s climate sensitivity is much lower than projected by past climate models. In the end, we have plenty fossil fuel, which is a good thing since, as Ridley points out, using fossil fuels actually preserves wildlife and wild places while vastly improving the lives of the world’s peoples – especially the poorest among us.

SOURCE: The Wall Street Journal


A new study in the Journal of Climate by Bjorn Stevens of Germany’s Max Planck Institute of Meteorology shows aerosols, estimated by the Intergovernmental Panel on Climate Change (IPCC) to have a cooling effect on Earth – dampening or cancelling out rising temperatures caused by manmade carbon dioxide emissions – have a smaller cooling effect than assumed in past climate models.

SOURCES: Climate Audit and Bishop Hill


Attacks on the integrity of global warming skeptics are nothing new. Fortunately, as University of Pennsylvania professor J. Scott Armstrong writes in the Washington Times, science provides a procedure for resolving concerns about bias: replication. The sharing of assumptions, methods, and data necessary for independent testing and replication eliminates the need to speculate concerning bias whether due to ideology, funding, or for any other reason.

Replication can also reveal whether researchers have properly disclosed their data. Armstrong has experienced an instance where government-funded researchers making alarmist claims refused to share their data. “[I]n preparing my testimony for [Sen. Barbara] Boxer’s [D-CA] 2008 U.S. Senate hearings on polar bear populations, I requested data from government-funded research that led to a dire forecast,” Armstrong said. “My request was refused.”

Rather than attack skeptics’ funding, Armstrong invites people to examine the evidence directly. He says researchers should attempt to replicate or falsify findings by testing hypotheses running counter to or tending to confirm the human-caused catastrophic climate change paradigm rather than engage in unscientific smear campaigns.

SOURCE: Washington Times


Data from the National Oceanic and Atmospheric Administration’s Storm Prediction Center (SPC) are confounding climate alarmists’ predictions of increasingly erratic and extreme weather due to global warming. Until the March 25 tornadoes in Oklahoma, SPC had issued only four tornado watches and no severe thunderstorm watches in 2015. Even with the March 25 storms, this is less than 10 percent of the average number of tornado watches issued by mid-March, 52. Approximately 20 tornadoes have been reported in 2015 compared to a 10-year average of 130 for the same period. Greg Carbin, SPC’s warning coordination meteorologist said, “We are in uncharted territory with respect to lack of severe weather. This has never happened in the record of SPC watches dating back to 1970.”

SOURCE: Watts Up With That


Americans’ concerns about manmade climate change are waning. Climate change finished dead last in a recent Gallup poll that asked respondents to identify the issues they were concerned about most. Indeed, despite greater media and political attention being paid to climate change than ever before, the poll found less than one-third of Americans worry about climate change “a great deal.” This is a significant drop compared to a similar poll conducted in 2007 that found more than 40 percent of Americans worried about climate change.

Gallup’s Jeffrey Jones reports, “Importantly, even as global warming has received greater attention as an environmental problem from politicians and the media in recent years, Americans’ worry about it is no higher now than when Gallup first asked about it in 1989.” Jones notes people are more upbeat about the environment in general at the present time than they have been in the past few years, and the shift the environmental movement made from a focus on local, immediate environmental problems to global, future climate issues may be the reason for declining fears. “The nature of the environmental agenda may indirectly be influencing Americans’ concern. The primary focus of the environmental movement has shifted toward long-term threats like global warming – issues about which Americans tend to worry less than about more immediate threats like pollution.”

SOURCES: Washington Times and Gallup


A paper by David Middleton argues the dominant paradigm concerning climate changes Earth has experienced over the past 150 years is collapsing. The reason, Middleton says, is Earth has not warmed for at least the past 18 years despite rising carbon dioxide levels, with the best explanation being the climate is far less sensitive to changes in carbon dioxide than the scientific consensus has assumed in previous models.

Middleton also discusses the alleged consensus supporting the manmade climate change theory, which stemmed from researchers undertaking “abstract reviews” using a keyword search that recorded relatively insignificant mentions of man-caused global warming as an endorsement of the theory in its entirety. The belief in a possible human influence on climate is not tantamount to endorsing the view humans are the dominant driver of climate change, much less that additional warming will cause a disaster. Additionally, Middleton says the abstract reviews threw out studies that took no position on the human impact on climate, thus excluding two-thirds of the articles mentioning climate change.

Middleton explains one group of scientists has been particularly resistant to the siren song of human-caused warming: geologists. He writes,

Petroleum geologists tend to be sedimentary geologists and sedimentary geology is essentially a combination of paleogeography and paleoclimatology. Depositional environments are defined by physical geography and climate. We literally do practice in a different world, the past. Geologists intuitively see Earth processes as cyclical and also tend to look at things from the perspective of “deep time.” For those of us working the Gulf of Mexico, we “go to work” in a world defined by glacioeustatic and halokinetic processes and, quite frankly, most of us don’t see anything anomalous in recent climate changes.

So, it should come as little surprise that geoscientists have consistently been far more likely to think that modern climate changes have been driven by overwhelmingly natural processes …

As the author views it, lack of support for the human-caused climate change paradigm from geologists, combined with the persistent lack of predictive abilities displayed by climate models and the growing awareness of the relative insensitivity of Earth’s climate to carbon dioxide provide “[c]lear evidence that the dogmatic insistence of scientific unanimity is at best highly contrived and at worst fraudulent.”

SOURCE: Watts Up With That?

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