June 4, 2009


Via Fax: (202) 566-1741

The Honorable Lisa Jackson

Environmental Protection Agency

1200 Pennsylvania Avenue, NW

Washington, D.C. 20460


Dear Administrator Jackson:


Re: Docket ID No. EPA-HQ-OAR-2009-0171


Secure America’s Future Economy is an all-volunteer, nonpartisan organization, formed in 1996, which advocates smaller, more focused, less costly government.


In general, we consider the “Proposed Endangerment and Cause or Contribute Findings for Greenhouse Gases under Section 202(a) of the Clean Air Act; Proposed Rule,” as published in the Federal Register on April 24, 2009, to be unwarranted and unwise. 


We respectfully request that your agency take the following comments into account for purposes of any further proceedings on this subject.


1.      Your description of the alleged global warming threat includes many questionable or exaggerated claims. Given that global warming stopped about ten years ago, for example, it is hard to credit the statement on page 18896 that “eight of the ten warmest years on record have occurred since 2001.”


Source: 2/25/09 testimony of William Happer, the Cyrus Fogg Bracket Professor of Physics at Princeton University, before the Senate Committee on Environment and Public Works.  Professor Happer testified, among other things, that (a) “warming has ceased” in the last ten years, (b) warnings of frightening consequences from a buildup of atmospheric CO2 are “wildly exaggerated,” and (c) on balance, more CO2 in the atmosphere “is probably good for mankind.”




The “eight of the warmest years on record” statement is also belied by the fact that  “the Earth was as warm as or warmer than it is today” in both Roman and medieval times – without any catastrophic consequences.


Source: A Global Warming Primer, National Center for Policy Analysis, circa 2007, which in turn is based on “a review of available scientific research.”




2.      Your findings were predetermined by the decision (noted on page 18894) to base them on the major assessment reports of the IPCC and the CCSP.  Both of these organizations are institutionally invested in concluding that global warming is a grave problem requiring government-mandated intervention.


Furthermore, the asserted protection of a “transparent peer-review process” is illusory.  We understand that critical comments on the assessment reports of the IPCC and the CCSP by subject matter experts have been systematically ignored. 


Source: Cato Scholar Comments on IPCC’s Synthesis Report, Patrick J. Michaels, a climatologist with links to the University of Virginia, Marshall Institute, and Cato Institute, and also a contributing author and reviewer for the IPCC, 11/19/07.


Unlike the sober scientific assessment that the IPCC published last May – which the Synthesis Report was supposed to summarize – the new document is, to say the least, novel. The May document actually reduced median estimates of sea-level rise from previous reports, and projected temperature increases in coming decades that are quite similar to what has been observed in the last three decades, about one degree (F). The new report, instead, projects up to 6 degrees. Also, it conveniently ignores the fact that there has been very little net warming in the last ten years.




Source: Record Low For Climate Science, Patrick J. Michaels, Cato Institute, 8/31/08.


 I found two changes in the thousands of pages of the last (2007) IPCC report - after I sent in a 30,000-word point-by-point review.  I'll be lucky to get even that much attention after my equally long critique of a new CCSP report, Global Climate Change Impacts in the United States. The sum of my analysis: This is the worst document in this genre I have ever seen.




Source: Proved: There is No Climate Crisis, Robert Ferguson, Science & Public Policy Institute, 7/15/08.


WASHINGTON (7-15-08) - Mathematical proof that there is no “climate crisis” appears today in a major, peer-reviewed paper in Physics and Society, a learned journal of the 4,600-strong American Physical Society, SPPI reports.

Christopher Monckton, who once advised Margaret Thatcher, demonstrates via 30 equations that computer models used by the UN’s climate panel (IPCC) were pre-programmed with overstated values for the three variables whose product is “climate sensitivity” (temperature increase in response to greenhouse-gas increase), resulting in a 500-2000% overstatement of CO2’s effect on temperature in the IPCC’s latest climate assessment report, published in 2007.



3.      In lieu of relying primarily on the major assessment reports of the IPCC and the CCSP, we urge that you reconsider your previous decision (page 18894) and conduct “a new assessment of the scientific literature.”  Such an approach would enable you to take the full range of scientific opinion into account, including the findings presented in the June 2009 report of the NIPCC.


Source: “Consensus”?  What “Consensus”?  Among Climate Scientists, The Debate Is Not Over, Viscount Monckton of Benchley, Science & Public Policy Institute, July 2007.


. . . the evidence in the peer-reviewed literature conclusively demonstrates that, to the extent that there is a “consensus”, that “consensus” does not endorse the notion of “catastrophic” climate change.




Source: Climate Change Reconsidered: The Report of the Nongovernmental International Panel on Climate Change [NIPCC], Craig Idso and S. Fred Singer, The Heartland Institute, June 2009.


On the most important issue, the IPCC’s claim that “most of the observed increase in global average temperatures since the mid-twentieth century is very likely due to the observed increase in anthropogenic greenhouse gas concentrations [emphasis in the original],” NIPCC reaches the opposite conclusion – namely, that natural causes are very likely to be the dominant cause.  Note: We do not say anthropogenic greenhouse gases (GHG) cannot produce some warming or has not in the past.  Our conclusion is that the evidence shows they are not playing a substantial role.





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Thank you for your anticipated consideration of these comments and action based thereon.





                                                                                                   William Whipple III




115 Dungarvan Drive

Middletown, DE 19709

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