The "Social Cost Of Carbon" Becomes A Little Less Fraudulent

Back in 2015 -- when the Obama EPA put out regulations, euphemistically called the "Clean Power Plan," intended to extirpate fossil fuels from the generation of electricity in the United States -- they justified that initiative with a concoction called the "Social Cost of Carbon."  Here is something titled the "Regulatory Impact Analysis for the Clean Power Plan Final Rule," dated October 23, 2015, that was the document that accompanied the CPP and attempted to prove that it was a net financial positive.  Basically the idea was to use phony climate models to predict catastrophe some time in the very distant future; then put some arbitrary monetary cost on the catastrophe; and then discount that cost back to the present at a low interest rate to claim a present-value "saving" from forcibly transforming electricity generation today.  If we force you to shut your perfectly good power plant today, then Manhattan won't flood in the year 2106!  That'll "save" $1 trillion!  Count it as a $200 billion "saving" today!  Or something like that.

Anyway, I would definitely not recommend reading that 2015 RIA.  It's well over 200 pages of bureaucratic double-speak.  The bottom line was that they calculated this so-called Social Cost of Carbon thing at around $51 per ton of CO2 emissions.  At about 7 billion tons of CO2 emissions in the U.S. per year, that would make around $350 billion of annual SCC.  So just think about how much we could "save" by forcing you to freeze in the dark!  In a post in June 2016 titled "Annals Of Government Fraud: The 'Social Cost Of Carbon,'" I had a good time making fun of the absurdity.  Here are some excerpts from that post:

Suppose that you even believe some of the worst case scenarios projected by the most alarmist of the climate models, and you are then given the task of doing a cost-benefit analysis for the use of fossil fuels by mankind. . . .  I hope that your . . . reaction would be, this is not even remotely close.  On any conceivable scale of measurement, the benefits to mankind from the use of fossil fuels have to outweigh the negatives by a factor of hundreds if not thousands.  The benefits so wildly exceed the costs that the whole effort to try to quantify and weigh the two can't really even be justified.  Even if you hugely minimize the benefits and exaggerate the costs, there couldn't possibly be any way to make the use of fossil fuels by mankind into a net negative.  Indeed, if you need a reasonable proxy for the positive benefits of carbon-based energy, a pretty good start would be 100% of GDP.  For the U.S. that's around $17 trillion per year.  After all, without carbon-based energy GDP would be a very small fraction of what it is.  Maybe you could knock off a couple of tril for the part produced by nuclear and hydro, the infinitesimal part produced by wind and solar, and the even more infinitesimal part that you could produce by your own backbreaking human labor in the absence of an energy boost from something else.  So a good estimate of what we might call the Social Benefit of Carbon, or alternatively the Negative Social Cost of Carbon, would be around $15 trillion per year. 

That's how you would approach the problem if you were honest, or if you had even a smidgeon of integrity.  But remember, this is the government, and their power is at stake.

Now fast forward to the new Trump administration.  You probably know that a couple of weeks ago the restaffed EPA announced the impending repeal of the CPP.  What you may not know is that the announcement of the proposed repeal was accompanied and supported by a new Regulatory Impact Analysis that, among other things, re-analyzed this "Social Cost of Carbon" gizmo.  Here is a link to the new RIA.  By the way, it's not a lot shorter than the previous version.

What's remarkable to me about the new RIA is that it fails to take direct aim at the core absurdity of the prior RIA, namely the whole idea that use of fossil fuels -- what we used to call "fire" -- by mankind could possibly be a net negative in any conceivable rational calculation.  Instead, what the new RIA does is to make just a couple of relatively minor tweaks to the prior version.  An article from yesterday's S&P Global pinpoints the tweaks:

The new value has been narrowed to only consider the domestic impacts of carbon, while the Obama administration's version also took into account the global impacts. . . . And in contrast to the Obama administration, which assumed a 3% discount rate, the new value assumes a 7% discount rate. . . .  

Both of those two tweaks are eminently justifiable, although perhaps they could be debated.  But with just those two tweaks, the SCC suddenly goes from $51 per ton of emissions to -- $1!  And at a lousy $1 per ton, you will quickly see that virtually any cost that you are going to incur to shut down existing power plants and build new wind turbines or solar collectors is going to far exceed any supposed "benefits" from the reduced carbon emissions.  A chart at page 21 of the new RIA gives "avoided compliance costs" from undoing the CPP for the year 2030 of $14.4 billion, while "forgone domestic climate benefits" are only a lousy $400 million, leading to a net benefit from getting rid of the CPP of $14 billion.

I guess this is OK as far as it goes, but the central absurdity -- really, "fraud" is probably a more accurate word -- of the whole Social Cost of Carbon construct remains.  For God's sake look at the big picture, guys!  You haven't even started to consider the most important points.  For example:

• You have ridiculously low estimates for how much it will cost to replace existing fossil fuel power plants with so-called "renewables" like wind and solar.  Where do you possibly get the idea that you can just build wind turbines or solar panels of equivalent capacity (or even a multiple of the capacity) of your dispatchable coal or natural gas plants and get an equivalent amount of usable power for a functional electrical grid?  How much excess capacity will you have to build?  How much back-up fossil fuel power capacity will you need to keep around for times of dark and calm?  What are you going to do with all the excess power when the wind and sun are at full strength?  What are the costs for these things?
• How much storage will you need?  Where are the hundreds of billions of dollars that you will need for batteries if you think you can obviate or forbid the fossil fuel backup?
• What about the environmental costs of wind and solar energy?  What have you included for the millions of birds that get chopped by wind turbines or fried by solar collectors?  What are the costs for the millions of acres that get occupied by these hideous things?  How about the health effects from the powerful low-frequency vibrations put out by wind turbines?  What about the environmental impacts of disposing of millions of these massive things when their useful lives run out in maybe 15 years (or less)?
• And what have you included for the environmental benefits of increased CO2 in the atmosphere, particularly, particularly improved plant growth from the fertilization effect?

And all of these questions only relate to the Social Cost of Carbon as it applies to the electrical sector.  The majority of the use of fossil fuels does not occur in the electrical sector, but rather in areas like transportation (automobiles, planes), industry (farms, manufacturing) and home heating.  

When you start considering those things, you quickly realize that my prior statement that the majority of the whole economy depends on fossil fuels is not far off the mark.  First, let's stop calling it the Social Cost of Carbon, and recognize that it is the opposite, the Social Benefit of Carbon.  What is a realistic estimate of the Social Benefit of Carbon for the U.S.?  If you figure that about two-thirds of the economy depends on fossil fuels with no reasonable alternative on the horizon, that's around $14 trillion per year.  Annual emissions of CO2 are around 7 billion tons per year.  Dividing, you get about $2000 per ton, Social Benefit of Carbon.  Sounds about right to me.

So the new Social Cost of Carbon is a little improved, a little less fraudulent than it used to be.  But come on, can't we do a real and honest estimate and recognize the huge benefits here?        

How's de Blasio Doing? -- Income Inequality

With the mayoral election coming up in New York in just a couple of weeks, it's time to look in a little on how our super-progressive Mayor Bill de Blasio has done during his first four year term.  For today's issue, let's consider income inequality.

If you were around for the last election in 2013, you will not be able to help remembering that income inequality was de Blasio's big issue.  In the famous and oft-repeated turn of phrase, income inequality was said to be "the defining challenge of our time."  In this post on November 11, 2013 -- immediately after de Blasio was elected -- I included quotes on the subject both from his campaign and from his election-night victory speech.  For example, from the victory speech:

That inequality, that feeling of a few doing very well while so many slip further behind — that is the defining challenge of our time. …. But the challenge today is different. The creeping specter of inequality must be confronted, and will not weaken our resolve.

And, to be fair to de Blasio, it wasn't just him.  Plenty of others on the progressive side of things were also regularly mouthing the same line, not the least among them being then-recently-re-elected President Barack Obama.  For example, in this speech delivered on December 4, 2013, Obama used the same formulation that had been repeated endlessly by de Blasio:

[There is a] relentless, decades-long trend that I want to spend some time talking about today.  And that is a dangerous and growing inequality and lack of upward mobility that has jeopardized middle-class America’s basic bargain -- that if you work hard, you have a chance to get ahead.  I believe this is the defining challenge of our time. . . .  

Of course, being ever the contrarian, I went over all the policies that de Blasio was proposing to address income inequality, and expressed extreme skepticism that any of them would have the desired effect.  Higher taxes on high earners; universal "pre-K" education; higher minimum wage; more construction of "affordable housing" -- none of these had any real potential to move the published statistics by which income inequality is generally measured.  Only one prospective policy offered any real hope:

In the end, there's really only one thing de Blasio can do to reduce measured income inequality, and that is to drive the high earners away. . . .  Is that really where de Blasio wants to go?

Now, four years in, where are we?  First, on the policy side:  Most but not all of de Blasio's main proposals got enacted.  The main exception was the proposal for higher taxes on high earners, which got blocked by the state legislature and the governor.  (But the usual measures of income inequality are calculated on a pre-tax basis, so higher taxes on high earners would definitely not move the income inequality numbers.)  Meanwhile, universal pre-K went through, a higher minimum wage was passed, and at least some "affordable housing" got built.  Of course, if you understand how the measure of inequality are put together, none of these had any real potential to move the numbers either.  (For example, the implicit rent subsidy of "affordable housing" does not count as "income" in measuring income inequality; and recipients of pre-K education will not see their incomes raised (if ever) until they enter the labor force in the late 2030s.)

So, have the measures of income inequality in fact moved?  Alex Armlovich of the Manhattan Institute is out with a new study that analyzes the numbers for 2014 (when de Blasio took office) through 2016 (latest numbers available).  Result:  no change!

New York City mayor Bill de Blasio assumed office in January 2014, promising to “take dead aim at the Tale of Two Cities ... [and] put an end to economic and social inequalities that threaten to unravel the city we love.” As the de Blasio administration nears the end of its four-year term, income inequality in 2016, the most recent year for which data are available, stood at the same level it was when former mayor Michael Bloomberg left office. During the interim, income inequality has fluctuated—at one point becoming even greater than it was when de Blasio entered office—and only more recently reverted to the Bloomberg-era level. 

And the results are even worse for de Blasio's policies than even that summary would indicate.  The fluctuations in the metrics had almost entirely to do with changes in pay among high earners, and thus nothing to do with de Blasio's programs directed to the low earners:

A transitory increase in compensation for finance professionals (as a group, the city’s highest paid) led the gap between New York’s rich and poor to increase in 2014 and 2015. In 2016, a modest decline in the concentration of compensation in that sector reduced income inequality to about the same level as when Mayor de Blasio took office. 

The good news is that de Blasio is talking a lot less about income inequality this time around.  Undoubtedly, he'd like to avoid as much as possible getting confronted with the statistics that prove that his policies have thus far been more or less completely ineffective in achieving the stated goal, even as they make things worse for all by raising the expense of government, complicating the process of housing development, and so forth.     

Update On Scientists' Letter To EPA

My post on Tuesday announced a letter by some sixty-five top scientists to Scott Pruitt, EPA Administrator, calling on Pruitt to reopen and reconsider the so-called Endangerment Finding relating to CO2 and other "greenhouse gases."  Since Tuesday, I understand that another approximately twenty similarly-qualified scientists have added their signatures to the letter, bringing the total of signatories into the eighties.  I will be posting the names and qualifications of these additional signers as they become available.

We understand that many more scientists would have been pleased to sign the letter had they known about it.  It's not too late!  If you are a scientist with appropriate qualifications, and would like to add your name to this effort, you can do so by sending your name and appropriate information about yourself (in the format used for the other signatories in the letter at this link) to the following email address:  THSResearch@aol.com. 

Many thanks to all who participate!  

The Third World Is Coming Around Fast On The Climate Scam

It was back in the early days of this blog, in 2013, that I started writing about the incomprehensible and immoral efforts of international and U.N. bureaucrats to keep the poor of the world poor by denying them access to cheap and reliable electricity.  Here is a post from November 2013 titled "The Looking Glass World Of The U.N. Climate Bureaucracy."   That post reported on a conference that had just been held by the U.N. under the auspices of its "Framework Convention on Climate Change."  

The 2013 UN FCCC conference was an opportunity for every third-world corruptocrat to play on the guilt of guilty first worlders by blaming all flukes of the weather on the driving of SUVs and then demanding some kind of "climate reparations" payments to enrich the governing elites of the poor countries while doing absolutely nothing about either the climate or poverty.  For example, a New York Times article linked in my piece quoted one John Kioli ("chairman of the Kenya Climate Change Working Group") as follows:

John Kioli . . . called climate change his country’s “biggest enemy.” Kenya, which straddles the Equator, faces some of the biggest challenges from rising temperatures. . . .  Developed countries, Mr. Kioli said, have a moral obligation to shoulder the cost, considering the amount of pollution they have emitted since the Industrial Revolution. “If developed countries are reasonable enough, they are able to understand that they have some responsibility,” he said.

Without doubt, there is plenty of that kind of thinking and approach still around today, particularly at the insanely corrupt U.N.  But something rather big has changed since 2013, which is that rapidly increasing numbers of people, and even government officials, in the developing world have come to the realization that the poor people are entitled to get access to cheap and reliable electricity, and that the only way they are going to get it is by using fossil fuels, mostly coal.  More and more of these people are not afraid to speak out.

Last week in Washington, D.C., there was the big joint annual meeting of the World Bank and the IMF.  The meeting coincided with the release by the Global Warming Policy Foundation of the piece by Rupert Darwall (covered by me here) that excoriated the World Bank for its anti-development stance of refusing to finance anything having to do with fossil fuels.  The Washington Post reported on the Washington meeting in an October 14 piece headlined "Global finance leaders warn against complacency."   Don't bother reading that article.  You won't be surprised to learn that the Washington Post doesn't even mention the various demands at the meeting by developing world officials that the Bank and IMF stop fighting the development of fossil fuel resources.  Remember that WaPo functions today mainly as a means to suppress all news that might actually be important.  By the way, I can't even find an article in the New York Times covering the World Bank/IMF meeting.

So let us turn instead to The Zimbabwean (isn't the internet wonderful?), which offers an article today headlined "Africa, US question World Bank policy on poor."   

[I]f [the huge] Kariba [dam in Zimbabwe] was built today, the World Bank wouldn’t fund it. Same with the Three Gorges Dam in China, oil wells in Saudi or the coal-fired power stations that account for 60 per cent of Africa’s kilowatts.  At the bank’s annual summit last week, hosted by its president Dr Jim Yong Kim, these policies loomed into focus as more than 11,500 delegates, including six from Zimbabwe, converged on Washington.  Where else might you find Donald Trump and Robert Mugabe on the same side, along with India, China, Australia, Ghana, Nigeria and a clutch of others calling for change? . . .  Some say the bank has been hijacked by an army of lobbyists who want to shut down anything not powered by wind or sunshine.  In 2013 the bank adopted an outright ban on funding for coal except where there was no alternative.

After discussing Darwall's paper (which calls the World Bank the "anti-development bank" for its war against fossil fuel electricity), the Zimbabwean then turns to a delegate from India for a series of quotes:

Indian government minister Piyush Goyal, for example, could have been speaking for Zimbabwe or any developing country when he said, "The people of India want a certain way of life. They want jobs for their children, schools and colleges, hospitals with uninterrupted power.”  Solar, he complained, only worked when the sun is shining.  “We need a very large amount of baseload power and this can only come from coal.  They’re saying to us, 'we’re sorry but you Indians can only have power for eight hours a day. The rest of the time you must live in darkness.'"  More than 300,000,000 Indians are not on the grid, a hot topic at elections.

The heretics are on the loose!  Of course, the President of the World Bank pushed back:

For his part, Dr Kim spoke passionately about the falling cost of renewables. Using his numbers, green electricity is cheaper than watts from coal, gas, the turbines of Lake Kariba, even the continent’s only nuclear plant in South Africa.

Seems like Dr. Kim's arithmetic skills are about on a par with those of the New York Times.  

More on the subject comes from James Delingpole, writing in the UK's Spectator, "How the World Bank keeps poor nations poor."   Delingpole focuses on Nigeria -- Africa's most populous country -- and describes some of the miseries it faces from lack of reliable electricity:

Blackouts and brownouts are common, as they are throughout sub-Saharan Africa, and the costs to the economy are enormous. The local mobile phone company MTM, with 62 million subscribers, spends 70 per cent of its operating expenditure on diesel to keep its network powered up.

And then there is this, from Kemi Adeosun, Nigeria's Minister of Finance:

"We want to build a coal power plant because we are a country blessed with coal, yet we have a power problem. So it doesn’t take a genius to work out that it will make sense to build a coal power plant. However, we are being blocked because it is not green. This is not fair, because they have an entire western industrialisation that was built on coal-fired energy.”

India (1.3 billion people), Nigeria (almost 200 million people) -- pretty soon we're going to have a critical mass here.

Meanwhile, the next big meeting of the UN FCCC is next month, November 6 - 17, in Bonn, Germany.  Don't expect the leaders of that clique to back off their efforts to force the poor to use only power that costs a fortune and doesn't work.  But with the U.S. no longer promising to buy the silence of the poor-country elites with a gusher of cash, you definitely can expect that more and more developing countries will speak out on their intention to use coal and other fossil fuel resources.  Ultimately, who's going to stop them?

UPDATE, October 23:  A line that originally appeared in this post, stating that Rupert Darwall is the former research director of the World Bank, was in error and has been deleted.  The former research director of the WB is Deepak Lal.  Lal wrote a foreword to Darwall's GWPF paper.     

The Quality Of Thinking About Climate And Economics At Pravda

On Monday the New York Times gave over its full unsigned editorial space to a single item, titled "5 Climate Truths Mr. Trump Doesn't Get."   In the full-page-length piece dripping with scorn, Pravda informs us how our ignoramus President just "doesn't get it" when it comes to energy policy.  It's not only that he's destroying the planet, but he also doesn't understand anything about basic economics:

Donald Trump promised he would be “an unbelievable positive” for the [coal] miners. Now he’s trying to deliver by repealing the Obama-era Clean Power Plan and proposing to subsidize coal-fired power plants. These moves are, in fact, unbelievable: Not only are they a setback in the fight against climate change, but they also make no economic sense, since the cost of renewable energy is falling sharply.

So let's check out a few of their arguments.  Do they make any good points?

I'll start with their fifth point, which deals with advances in batteries that supposedly are going to make "renewables" like wind and solar power more "productive and reliable":

Wind turbines and solar panels cannot produce electricity at all times in all weather conditions. But there have been great technical strides that have improved their performance. . . .  What’s more, batteries have become much cheaper, making it less expensive to store electricity when it’s windy or sunny for times when it is not. The average cost of lithium-ion batteries fell 73 percent, to $273 per kilowatt-hour, between 2010 and 2016. . . .  

They then provide a chart showing costs of lithium-ion batteries per kilowatt hour dropping from close to $1000 in 2010 to only $273 today.  Wow!  That's cheap!  Or, at least, that is clearly the impression that you are intended to come away with.

So then, New York Times, can you kindly give us a calculation of how much it would cost for some random place -- say, New York City -- to buy enough batteries to cover a worst-case period of cloudy-and-calm-for-days-on-end-in-the-winter when we have an electric system that consists of nothing but wind, solar and batteries?  Of course not.  As always, you have to ask whether the failure to provide this information means that they have done the calculation and are concealing it as part of an intentional deception, or whether the basic arithmetic of the calculation is beyond their abilities.  Whichever it is, it's not good for them.  But fear not, the Manhattan Contrarian specializes in basic arithmetic.

So let's do the calculation.  From the New York ISO (Independent System Operator) we get load data for recent days for New York City.  The load varies over the course of a day, but averages about 5000 MW.  (This is actually a low time of year, due to mild temperatures.  Loads are higher in the summer, due to air conditioning, and in the winter, due to heat.)  Multiply by 24 to get the number of MWH used in a day:  about 120,000.  Multiply by another thousand to get the number of KWH used in a day:  about 120,000,000.  Multiply by $273 to get the cost of enough batteries to store the 120,000,000 KWH to cover one calm and dark day:  $32.76 billion.  (Whoa!)  Now, how many dark/calm days could you get in a row?  Five?  Now we're talking $163.8 billion, just for batteries for New York City.  (That's about double the total annual budget for the NYC government, which is about $80 billion.)  Reader Dennis Rushworth reported last week in a comment that on an island called El Hierro -- one of the Canary Islands that are part of Spain -- they are trying to establish an electrical system using only wind and storage -- and they just had a calm period of 11 days!  Rushworth provides this link to the actual data from El Hierro, but it's in Spanish so I can't read it.  Anyway, at these "greatly reduced" prices for batteries that the Times is crowing about, eleven day's storage for New York City would go for something like $370 billion!  And New York City is only about one-fortieth of the U.S. by population.  Multiply by 40 to get the price for the whole U.S.:  around $15 trillion.  Hey, it's less than annual GDP (although not by much -- U.S. annual GDP is running around $18.5 trillion.)  No problem!  So what if we have to give up literally everything else in our lives from housing to food to clothing in order to buy nothing but zillions of batteries stacked higher than the Empire State Building?  We're saving the planet!

Anyway, once you start doing these calculations, you quickly realize that this couldn't possibly make sense until the cost of the batteries falls by at least another order of magnitude (factor of ten) or, more likely, two orders of magnitude.  Good luck trying, but I think the chance of that happening any time soon is about zero.  And then, of course, plenty of other questions occur to me (although they never seem to occur to anyone at Pravda), such as:  Does the capacity remotely exist to produce batteries in the kinds of quantities that could power entire cities and states for a week?  If you tried to buy so many batteries, would supply shortages of raw materials cause prices to soar?  Does the engineering knowledge exist to turn all these batteries into a functional system?  And so forth.

Dare we now consider another of the points made by the Times in this editorial?  How about point 4:  "Wind and solar are becoming cheaper every year":

In some countries like India, the United Arab Emirates, Mexico and Chile, auction prices for renewable energy have fallen so much that they are “comparable or lower than generation cost of newly built gas and coal power plants,” according to the agency, which researches the energy sector for 29 member countries, including the United States. Based on current trends, the agency forecasts that the cost of land-based wind turbines and utility-size solar projects will fall an additional 15 percent and 25 percent, respectively, in the next five years.        

That's interesting.  So then kindly explain why you are so upset by the Trump administration revoking the Clean Power Plan.  The point of the CPP is to force utilities to close plants burning coal and other fossil fuels.  If wind and solar are cheaper (without subsidies), then there would be no need for force, because the utilities will obviously turn to those sources and close the more expensive plants without any need for coercion.  What are we missing?  The answer is, we are missing that nobody will build wind and solar facilities without subsidies because they are known to be far more expensive despite what you are saying; and on top of that, wind and solar can't work on their own without either massive backup from fossil fuel plants and/or hundreds of billions of dollars worth of batteries, which costs are just being omitted when Pravda tells us that wind and solar costs are "comparable" to those of fossil fuel plants.  Where are those things mentioned in this editorial?  Nowhere.

The other points in the Pravda editorial are of comparable quality and deceptiveness.

So, maybe President Trump hasn't ever thought about this and just has decent instincts, or maybe he is a lot more intelligent than Pravda is giving him credit for.  That's not necessarily saying all that much.  You don't really have to be particularly intelligent to be a lot more intelligent than the New York Times on these subjects.

Sixty-Five Scientists Demand Reconsideration Of EPA's Endangerment Finding

Today a large group of some sixty-five top scientists sent a letter to EPA Administrator Scott Pruitt demanding that he initiate a process to reconsider the so-called Endangerment Finding of 2009.

Regular readers of this blog will recognize the EF as one of the most egregious and preposterous bureaucratic power grabs of all time.  By the EF, EPA purported to "determine" that carbon dioxide -- a colorless, odorless gas that has no known adverse health effects at any concentration you will ever experience and that is the basis for all life on earth -- is a "danger" to human health and welfare.  The so-called science underlying the EF is and always was a joke.  See, for example my post "The 'Science' Underlying Climate Alarmism Turns Up Missing" from September 2016 (and multiple similar posts).  Nevertheless, the EF was used by the Obama administration as the basis for, among other things, its Clean Power Plan, seeking to force the closure of all coal-fired power plants (and ultimately the closure of all power plants involving any fossil fuel).  Just today, a group of about seventeen "blue" states and their environmentalist co-parties filed a brief in the D.C. Circuit (behind pay wall) seeking to compel the Trump administration to reinstate the CPP or something like it, on the grounds that the EF requires the government to regulate emissions of carbon dioxide.  

Here is a link to today's letter.  And here is the full text:

You have pending before you two science-based petitions for reconsideration of the 2009 Endangerment Finding for Greenhouse Gases, one filed by the Concerned Household Electricity Consumers Council, and one filed jointly by the Competitive Enterprise Institute and the Science and Environmental Policy Project.

We the undersigned are individuals who have technical skills and knowledge relevant to climate science and the GHG Endangerment Finding. We each are convinced that the 2009 GHG Endangerment Finding is fundamentally flawed and that an honest, unbiased reconsideration is in order.

If such a reconsideration is granted, each of us will assist in a new Endangerment Finding assessment that is carried out in a fashion that is legally consistent with the relevant statute and case law.

We see this as a very urgent matter and therefore, request that you send your response to one of the signers who is also associated with a petitioner, SEPP. 

Readers here will also recognize that I am serving as a lawyer for one of the Petitioners (the Concerned Household Electricity Consumers Council) seeking reconsideration of the EF.  Our group issued a press release this morning simultaneous with the release of the scientists' letter to Administrator Pruitt.  Key points from our press release:

The Concerned Household Electricity Consumers Council fully endorses the recommendations of these scientists because recent research has definitively validated that: once certain natural factor (i.e., solar, volcanic and oceanic/ENSO activity) impacts on temperature data are accounted for, there is no “natural factor adjusted” warming remaining to be attributed to rising atmospheric CO2 levels. That is, these natural factor impacts fully explain the trends in all relevant temperature data sets over the last 50 or more years. At this point, there is no statistically valid proof that past increases in atmospheric CO2 concentrations have caused what have been officially reported as rising, or even record setting, global average surface temperatures (GAST) . . .  Moreover, additional research findings demonstrate that adjustments by government agencies to the GAST record render that record totally inconsistent with published credible temperature data sets and useless for any policy purpose. . . .  

This scientifically illiterate regulation [based on the EF] will raise U.S. energy prices thereby reducing economic growth and jobs as well as our National Security. . . .  The Electricity Consumers Council therefore, based on this new scientific evidence, must insist that the EPA grant the “very urgent” request of these scientists “that an honest, unbiased reconsideration is in order.”

I won't attempt to list here who all the letter's signers are, but if you go to the link you will see that they are a who's who of the top scientific people active on these issues.  To the extent that credentials count for anything in today's corrupted world, many of them have top degrees and top professorships at top institutions.  

Now, perhaps you have seen the claim that "97% of scientists agree" that human-caused global warming is a crisis, or something like that.  I guess that would have to mean that the alarmist team will shortly produce a responsive letter signed by in excess of 2000 comparably-qualified scientists.  Don't bank on it.  No such group exists.  Yes, there is a substantial government-funded clique of lightweights and charlatans that spend their lives manipulating the world temperature records and putting out fake press releases of "hottest year ever!"  Undoubtedly they can exceed our group in numbers (government dollars buy a lot of loyalty and corruption).  But no such group that could be assembled could remotely match our group of sixty-five for bona fide scientific heft.  If they try to assemble such a group, the contrast of the real scientists versus the lightweights will be immediately apparent.    

And by the way, the signing process for our scientists' letter is still open, and we expect the number of signers to increase over time.  Let the games begin!