**\"Mike Fox\" \<mike@foxreport.org\>**

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  09/18/2008 11:44 AM
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Subject

Testimony for EPA-HQ-OAR-2008-0318

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September 18, 2008

Gentlemen:

I am submitting this testimony in opposition to the "Advanced Notice of
Proposed Rulemaking for Greenhouse Gases Under the Clean Air Act",

Document number EPA-HQ-OAR-2008-0318-0117

Docket number [EPA-HQ-OAR-2008-0318]{.underline}.

For the sake of completeness and minimal loss of context, I am
requesting that the entire texts of my links be included in my comments.

**Introduction**

The scientific case against man-made global warming has collapsed. A
number of recent analyses of the International Panel on Climate Change
(IPCC), its science, its computer models, its review processes including
the dubious selections of reviewers, have been shown to be mortally
flawed. As Christopher Monckton recently observed:

"No serious scientist, therefore, can any longer take any of the IPCC's
conclusions seriously for a single moment longer. As Lord Lawson of
Blaby has long argued, the IPCC should now be abolished. It cannot serve
any useful purpose in future, because it has dishonestly lent its
support not merely to the falsification of scientific results but to the
persistent maintenance of that falsification. The IPCC is finished."
([http://tinyurl.com/6d279c]{.underline}).

To be very clear, my message is that the EPA should never, now or ever,
be proposing mitigation of man-made CO2 on a body of "scientific"
literature which is so flawed, unreplicated, indefensible, and
dishonest.

Monckton has provided much more essential and detailed analyses of the
scientific malpractices of the IPCC and its acolytes which are presented
later in this document.

**Deming Testimony**

There have been demonstrable activities to suppress the climate data
over the past 1000 years. For example in the Dec. 6, 2006 Senate
testimony of Dr. David Deming (shown here
[http://tinyurl.com/yf9q8t]{.underline}), described a situation where a
global warming scientist, apparently thought that Deming was an ally.
Deming stated "I had another interesting experience around the time my
paper in Science was published. I received an astonishing email from a
major researcher in the area of climate change. He said, [\"We have to
get rid of the Medieval Warm Period]{.underline}.\" The eagerness to
omit or neglect or destroy actual climate data is reprehensible, and
utterly unscientific and unprofessional.

The obvious reasons for the request to suppress data are that the
Medieval Warming Period (MWP) was warmer than the temperatures of today.
Such evidence of earlier warming periods makes it much more difficult to
convince an unaware public that today's warming is man-made, when the
climate history is filled with such warming periods. Many eras in the
past have shown warmer periods and greater CO2 levels than they are
today without any human impacts. It gets worse, far, far worse.

**The Hockeystick Fraud**

The Hockeystick is a name given to a graph of reconstructed temperature
data ( [Mann, Michael E.]{.underline}; [Bradley, Raymond S.]{.underline}
& Hughes, Malcolm K. (1998), \"[Global-scale temperature patterns and
climate forcing over the past six centuries]{.underline}\" (PDF),
*[Nature]{.underline}* **392**: 779-787).

The "handle" of the hockeystick graph is intended to portray rather
flat, constant global temperatures extending from about 1000 AD to about
1900. At this time the global temperatures turn sharply upward
indicating the "blade" of the hockeystick.

The overall message is/was that after about a 900 year period of
constant temperatures, the global temperatures rose sharply upward
beginning around 1900, allegedly. This is often assumed to be the
beginning of the industrial age, and therefore the presumed beginning of
significant man-made CO2 emissions. This is incorrect.

In fact the natural warming period we are currently in did not begin in
1900. It began at the deepest part of the Little Ice Age when the colder
global temperatures began to reverse and then increase. In an excellent
paper describing the retreats of glaciers, J. Oerlemans
([http://tinyurl.com/5eeya5]{.underline})** **showed that the glaciers
from around the world began retreating nominally in 1750, 150 years
before 1900. Thus, the warming began in this period as well, not in 1900
so often claimed.

This Hockeystick graph has been featured prominently and globally in a
major scientific journal, referenced above. It has been given pivotal
importance in several of the IPCC assessment reports, and featured
prominently in Al Gore's documentary "An Inconvenient Truth", which now
is discredited too. See here ([http://tinyurl.com/36pzfe]{.underline}),
here ([http://preview.tinyurl.com/2cpsyd]{.underline}), and here
([http://tinyurl.com/huf6d]{.underline}).

It is useful to list some of the approval processes which led to this
global deception. The authors, scientists themselves, obviously approved
of their own creation. The peer reviewers assigned by the science
journal approved it, the editors of the science journal who reviewed,
checked, and approved it, and the reviewers of the IPCC reports, the
editors of the IPCC documents. The producers of Gore's documentary
approved it, presumably Mr. Gore himself, and the thousands of school
teachers around the world who required millions of students to view and
analyze it. The extent of global fear inspired by the educational
systems around the world is incalculable.

We now know that the Hockeystick graph is fraudulent
([http://www.climateaudit.org/]{.underline}). How should we treat those
who approved it? What should the EPA do now proposing to adopt rule
making for CO2 mitigation. To do so they must embrace the underlying
fraudulent science, and the terrible harm it will bring.

**EPA action seems simple: do not proceed with the rule making for green
house gas mitigation. Have the courage not to mitigate man-made CO2 and
avoid joining with the scientific deceptions.**

Close analyses of the hockeystick scandal are essential for policy
makers, educators, media, and many scientific institutions and their PhD
staffers. All of them played a role in creating and/or spreading the
deceptions. It has shaken the pillars of institutional science to its
foundation and undermined the public trust science once had. We are
either dealing with willful scientific deceptions or woeful and lazy
scientific mediocrity from PhDs themselves. Clearly, as a group they are
not to be trusted with science or policy making.

The world owes a great debt to many scientists (dismissed as skeptics)
who have recognized the deceptions, applied rigorous scientific review,
and have worked to share their findings with policy makers,
stakeholders, and the public. Some of that world's debt must go to Ross
McKittrick, Steve McIntyre, and Christopher Monckton. They have the
analytical and statistical skills; the infinite bulldog tenacity to stay
engaged with the deceivers, who simultaneously were being very
uncooperative (another sign of unscientific behavior).

The great statistical work done by these three may just have helped the
world avoid trillions in expenditures for unnecessary green house gas
mitigation measures, not to mention the avoidance of energy rationing
and taxation set forth by carbon dioxide cap and trade policy proposals
as a result of the IPCC's conclusions.

**The EPA should be mindful and grateful for these efforts for several
reasons. The first is that the EPA should not being seen as promoting or
embracing fraudulent science lest it lose its credibility as an agency
designed to protect and enhance the quality of our environment and
natural resources. And the second is that the sophisticated highly
technical detective work to separate fraudulent environmental science
founded in political agendas, has largely been done for them.**

The high levels of sophisticated climate deceptions are stunning, but
fortunately for us, these 3 have unraveled the sordid tale and when,
what, and how they did it. The "why" may never be known.

The website of McIntyre and McKitrick (M&M) is at
([http://tinyurl.com/awwva]{.underline}). M&M have been analyzing the
hockeystick affair for years, and much of the analysis is posted here.
Major hockeystick graph work by Christopher Monckton is at
([http://tinyurl.com/6d279c]{.underline}).

For the outside observer, none of this multi-year detailed, high level
scientific detective work would have been necessary, if they (M&M and
Monckton) had been dealing with honest and ethical scientists. Such
defensive, name-calling belligerence from scientists and their political
mentors were unheard of in the 20^th^ century. In the pursuit of the
best hypotheses such scientists would happily turn over their data,
computers, algorithms, and analyses. The purpose was always and
obviously to develop the best hypothesis possible to enhance the quality
of science, human life, and its environs. But not with today's global
warming crowd. As we have now learned they have had a lot to hide, a lot
of sophisticated deceptions to hide.

As Dr. Deming's conversation with a warming advocate shows (above),
there was a deliberate effort to "get rid of the Medieval Warming
Period". The Hockeystick analyses shed more light on the scientific
deception and fraudulence to misrepresent the cyclic warming and cooling
of the earth over time. The highly sophisticated, computerized, complex,
algorithms which gave rise to the reconstructed temperature history of
the last 1000 years, is for all intents and purposes, scientific
malpractice. It was not a mistake or an error in judgment.

We now know there is much more to the deceptions. The Medieval Warming
Period (MWP) was removed with the computer work by a litany of
scientific malpractices spelled out in detail by Christopher Monckton's
analyses. At the same time the Little Ice Age (LIA) was removed from the
record as well. The Little Ice Age occurred over a number centuries
centered around 1680 to 1700. To deny the existence of the Little Ice
Age as these modelers do, is to deny the huge historical record of those
centuries filled with misery, cold, snow, ice, crop failures,
starvation, and famine.

Monckton's recent study of the Hockeystick fiasco shows much of the
deception in detail [http://tinyurl.com/6d279c]{.underline}). It is an
excellent study of scientific corruption on an international scale.

**Every EPA employee tasked with regulating air quality should read and
understand Monckton's study, the work of M&M, and their implications.
One of the largest implications is that no CO2 mitigation efforts are
scientifically justified, by any federal agency, the EPA, or any of the
individual state and environmental agencies.**

Instead of honorably acknowledging the corruption, the deceptions, and
data manipulations, an organized effort claimed that if there had been
any warming 1000 years ago, it was not global, merely regional.
Monckton's study includes 22 chart and graphs from the scientific
literature demonstrating that the MWP was indeed global, with evidence
of warming from all parts of the world. Vikings in Greenland were
growing crops and livestock in a much warmer land during the MWP.
([http://tinyurl.com/dd6bv]{.underline}).

The following 900 hundred words are taken directly from the conclusions
of Monckton's Hockeystick study
([http://tinyurl.com/6d279c]{.underline}).

"The continuing affair of the "hockey-stick" graph is a microcosm of the
profound collapse of the rigor, objectivity, and honesty that were once
hallmarks of the scientific community. The need to look to the State for
very nearly all science funding has inflicted upon the scientific
community a dull, dishonest uniformity, so that the deliberate
falsification of results to support the current official orthodoxy has
become commonplace, particularly where the climate question is
concerned.

It was bad enough that one of those behind the "hockey stick" affair
should have told a fellow researcher, "We need to get rid of the
medieval warm period." It was worse that the authors of the bogus graph
attempted to do just that:

1\. by ignoring, undervaluing or even suppressing proxies for
northern-hemisphere temperature that did not suit the result they
wanted;

2\. by falsely stating that they had used data they had in fact replaced
with "estimates" of their own that gave them a less inconvenient answer;

3\. by overvaluing by many orders of magnitude the contribution of
datasets that suited the result they wanted.

It was worse still that the IPCC, several leading journals and numerous
former co-authors of the three fabricators of the hockey stick should
have continued to cling to it as though it were Gospel, even though it
has been justifiably and utterly discredited in the scientific
literature. Instead they went through an elaborate pantomime of
rewriting and publishing previously-rejected papers with the connivance
of a dishonest journal editor, so that an entirely fictitious scientific
support for the false graph could be falsely claimed by the IPCC in its
current *Fourth Assessment Report.*

The IPCC might have regained some of the scientific credibility that it
lost by its publication of the 2001 graph if, in its 2007 assessment
report, it had had the integrity, honesty, and common sense to apologise
for the failure of its *soi-disant *"peer-review" process to identify
the multiple and serious scientific errors that led to the publication
of the graph.

As it is, the IPCC, rather than apologizing, has chosen to participate
in the falsification of subsequent results purporting to uphold the
original graph, and altogether to ignore papers such as those whose
graphs are shown here (In original analysis\--linked above), confirming
the well-established historical record of the existence of the medieval
warm period.

To repeat, no serious scientist, therefore, can any longer take any of
the IPCC's conclusions seriously for a single moment longer. As Lord
Lawson of Blaby has long argued, the IPCC should now be abolished. It
cannot serve any useful purpose in future, because it has dishonestly
lent its support not merely to the falsification of scientific results
but to the persistent maintenance of that falsification. The IPCC is
finished.

Was there a medieval warm period? Yes.

Was that period warmer worldwide than the present? Yes.

Are today's global temperatures exceptional? No.

Have the past ten thousand years been generally warmer than the present?
Yes: much warmer.

Is there, therefore, the slightest reason for the childish panic that
the environmental extremist movement and its servant the IPCC have
attempted to whip up? No.

Should any government devote a single further penny to the climate
scare? No.

Even if humankind is contributing significantly to warmer weather (which
is highly unlikely), adaptation to warmer weather as *and if *necessary
would be orders of magnitude cheaper than the measures to reduce carbon
emissions that the world's extremist politicians are now so eagerly but
purposelessly advocating.

The real cost of the flagrant abuses of the scientific method
surrounding the question of climate that are so well illustrated by the
affair of the "hockey stick" is a terrible, unseen cost in human lives.

The biofuel scam that arose directly out of the climate scare has taken
one-third of US agricultural land out of food production in just two
years. Similar economic disasters have occurred worldwide, not because
of "global warming" but because of the catastrophically bad
policy-making that the "global warming" scare has engendered among
politicians too ignorant of science and too lazy to do other than swim
with the rising tide of pseudo-scientific nonsense.

The environmental extremists have already killed 50 million children
through malaria ([http://tinyurl.com/5m7w4b]{.underline}) by their
promotion of the now-canceled ban on the use of DDT. For decades DDT was
the only effective agent against the *anopheles *mosquito that spreads
the infective parasite. They are still threatening harm to millions more
in poverty through their latest scientifically-baseless scare -- the
"global warming" panic pandemic. This added misery will be achieved by
denying those in poverty access to energy, electricity, clean water,
food, shelter, and a healthy economy.

Food riots are occurring throughout the world among the poorest of the
poor in many countries: but the desperation, starvation, disease, and
death that accompany the sudden famines that the biofuel-driven doubling
of world food prices has engendered are scarcely reported by our news
media. As Monckton states in his full analysis, people in Haiti are
eating mud pies made of earth, water, a tiny knob of butter, and a pinch
of salt; or they sell the mud pies to less fortunate neighbours at 3 US
cents each. Thus are the wages of pseudo-science and its dominos.

**The Wegman Committee**

Finally, the final report of a panel of three independent statisticians,

chaired by the eminent statistics professor, Edward Wegman, chairman of
the

U.S. National Academy of Sciences Committee on Theoretical and Applied

Statistics, has resoundingly upheld the M&M criticisms of the famous
\"hockey stick\" graph. See here
([http://tinyurl.com/awwva]{.underline}).** **

**The Primitive Computer Models**

Christopher Monckton and M&M have specifically and in incredible detail
analyzed the technical and political fiascos behind the famous computer
models as well. Monckton's computer model analysis is linked here
([http://tinyurl.com/6edjzo]{.underline}), M&M are here
([http://tinyurl.com/awwva]{.underline}).** **

**These should be required reading for all EPA officials with the
slightest interest in good science and good energy policy.**

My 1700 word review of Monckton's Computer Model Studies is linked here
([http://tinyurl.com/6f7cz7]{.underline}), and does not begin to give
this analysis justice.

Some of the climate computer model flaws Monckton's discovered are
listed below. They are devastating to the man-made global warming
hypothesis and the computer modeling. These have profound implications
for policy makers and the energy and economic future of our country. How
the EPA or any other state or federal agency would base their CO2
mitigation rulemaking and regulations on such flawed science is
inconceivable.

For the sake of sound mitigation and energy policies, we had better
learn these of these flaws below:

**Point 1**: There are... serial, serious failures of the computer
models of climate

....the computer models upon which the UN's climate panel unwisely
founds its entire case have failed and failed and failed again to
predict major events in the real climate.

a\. The models have not projected the current multidecadal stasis in
"global warming":

b\. no rise in temperatures since 1998; falling temperatures since late
2001; temperatures not expected to set a new record until 2015
(Keenlyside et al., 2008).

c\. nor (until trained ex post facto) did they predict the fall in
temperatures from 1940-1975;

d\. nor 50 years' cooling in Antarctica (Doran et al., 2002) and the
Arctic (Soon, 2005);

e\. nor the absence of ocean warming since 2003 (Lyman et al., 2006;
Gouretski & Koltermann, 2007);

f\. nor the behavior of the great ocean oscillations (Lindzen, 2007),

g\. nor the magnitude nor duration of multi-century events such as the
Mediaeval Warm Period or the Little Ice Age;

h\. nor the decline since 2000 in atmospheric methane concentration
(IPCC, 2007);

i\. nor the active 2004 hurricane season;

j\. nor the inactive subsequent seasons;

k\. nor the UK flooding of 2007 (the Met Office had forecast a summer of
prolonged droughts only six weeks previously);

l\. nor the solar Grand Maximum of the past 70 years, during which the
Sun was more active, for longer, than at almost any similar period in
the past 11,400 years (Hathaway, 2004; Solanki et al., 2005);

m\. nor the consequent surface "global warming" on Mars, Jupiter,
Neptune's largest moon, and even distant Pluto;

n\. nor the eerily-continuing 2006 solar minimum;

o\. nor the consequent, precipitate decline of \~0.8 °C in surface
temperature from January 2007 to May 2008 that has canceled out almost
all of the observed warming of the 20th century. (Complete references
are listed in the full linked document).

As Monckton states, the computer models are demonstrable failures.

**Point 2:** The IPCC's method of evaluating climate sensitivity is
inadequate and error-laden Monckton showed that the IPCC's method of
evaluating climate sensitivity can be reproduced by nothing more
complicated than a few equations which, if the IPCC's values for certain
key parameters are input to them, generate the IPCC's central estimate
of climate sensitivity to a high precision. Nowhere else has this method
been so clearly or concisely expounded before.

And, once the IPCC's method is clearly seen for what it is, it is at
once apparent that their method suffers from a series of major defects
that render it useless for its purpose. The laboratory experiments that
form the basis for estimates of forcings do not translate easily to the
real atmosphere, so that the IPCC's claimed "Levels of Scientific
Understanding" for the forcings are exaggerated; its estimates of the
feedbacks that account for two-thirds of total forcing are subject to
enormous uncertainties not fairly reflected in the tight error-bars it
assigns to them; the feedback-sum is unreasonably close to the point of
instability in the Bode feedback equation (important in the study of
circuitry \[and climate\] feedbacks), which has in any event been
incorrectly used for amplification in a chaotic system, when it was
designed only for systems whose initial state was linear.

The IPCC's value for the no-feedbacks climate sensitivity parameter is
the highest in the mainstream literature, and is inconsistent with the
value derivable from the 2001 report; the value of this and other
parameters are not explicitly stated; etc., etc.

**Point 3:** The IPCC's value for climate sensitivity depends upon only
four scientific papers Climate sensitivity is the central -- properly
speaking, the only -- question in the debate about the extent to which
"global warming" will happen. Monckton's presentation of the IPCC's
method of calculating how much the world will warm in response to a
doubling of CO2 concentration shows that the IPCC's values for the three
key parameters whose product is climate sensitivity are taken not from
2,500 papers in the literature but from just four papers.

Had a wider, more representative selection of papers been relied upon, a
far lower climate sensitivity would have resulted.

**Point 4:** Uncertainty in evaluating climate sensitivity is far
greater than the IPCC admits. The IPCC baselessly states that it is 90%
sure we (humans) caused most of the observed warming of the past
half-century (or, more particularly, the warming in the 23 years between
1975 and 1998: the remaining 27 years were in periods of cooling).
However, the uncertainties in the evaluation of climate sensitivity are
so great that any conclusion of this kind is meaningless. None of the
three key parameters whose product is climate sensitivity can be
directly measured; attempts to infer their values by observation are
thwarted by the inadequacies and uncertainties of the observations
depended upon; and, in short, the IPCC's conclusions as to climate
sensitivity are little better than guesswork.

**Point 5:** The published literature can be used to demonstrate lower
climate sensitivity. The second part of Monckton's paper examines the
literature on climate sensitivity. A surprisingly small proportion of
all papers on climate change consider this central question. The vast
majority concentrate on assuming that the IPCC's climate-sensitivity
estimate is right and then using it to predict consequences (though, as
Schulte, 2008, has shown, none find that the consequences are likely to
be catastrophic). Monckton demonstrates, using papers from the
literature, that it is at least as plausible to find a climate
sensitivity of \<0.6 C as it is to find the IPCC's 3.3C ( a factor of
5\-\-- such a large uncertainty does not inspire confidence).

**Point 6:** Even if climate sensitivity is high, adaptation is more
cost-effective than mitigation Monckton concluded as follows: "Even if
temperature had risen above natural variability, the recent solar Grand
Maximum may have been chiefly responsible. Even if the sun were not
chiefly to blame for the past half-century's warming, the IPCC has not
demonstrated that, since CO2 occupies only one-ten-thousandth part more
of the atmosphere that it did in 1750, it has contributed more than a
small fraction of the warming."

Monckton's analysis here is a major contribution to understanding a
difficult subject. He has broken through the dense modeling processes,
not to mention the ad hominem attacks, in such a way that many more can
understand its weaknesses.

It is time to break the relationship between energy policy and computer
forecasting. It is time for the EPA to understand and appreciate the
flaws of the existing hypothesis. The evidence for man-made CO2 being
the cause of warming or of the recent cooling does not exist. As such it
is time for the EPA to drop the efforts of mitigating man-made CO2 when
such mitigation so clearly is doomed to failure.

The models are not sources of climate information so badly needed to
formulate rational energy policy without the threats of economic
suicide. In fact they have been fertile grounds for mischief, very
dangerous mischief. The economic and energy future of our nation should
not rest so completely on such primitive, whimsical modeling.

**Leaders of the EPA **

Based upon these highly technical and thoroughly researched subjects
within the manmade global warming issues, we have clearly demonstrated
scientific corruption and exaggerations on the highest levels. As it
stands at present, there is no demonstrable evidence showing that
man-made CO2 is contributing in any measurable way to the current period
of modest global warming. In fact we appear to be entering a period of
no warming at all, and for the last 7 years modest cooling. A hypothesis
which predicts CO2 causes warming, cannot explain recent cooling period
while CO2 increases. The hypothesis is falsified, and no man-made CO2
mitigation is necessary.

**We request that the EPA not proceed with rule-making for CO2
mitigation**.

Michael R. Fox Ph.D.

mike@foxreport.org