EPA Response to the Public Comments

The EPA has produced a written response (11 Volumes - one pdf file each) to the comments it requested in 2009.

I have a particular interest in this because my papers are included. In the response, various comments are referred to by their submission numbers - mine are 10071, 10071.1, 10071.2, 10071.3, 10071.4. Unfortunately, there does not appear that there is a way to search the site for responses to a specific public comment. As a result, it was necessary to open and search each volume. Out of 11 volumes (pdf files), when searching for 10071, I was able to find only the 4 entries below. This is unfortunate since I was hoping to get a comment on my paper (10071.3) which presents an alternate understanding of the function of Greenhouse gases.

Note: I found out about the EPA responses through a link on climateaudit.org (posted on Jan 30, 2010).

Volume 1 | Volume 2 | Volume 3

Volume 1

In Volume 1: General Approach to the Science and Other Technical Issues, page 54 (pdf 58), my comments were mis-characterized. What I actually said was As a result, the reference to my document (10071.2 - The summary of what I said at the May 18, 2009, public hearing) should have been included in the first group, but not in the second.

This is a summary of their response.

I think that this is reasonable, though, in light of the recent "climategate" scandal, I think they missed the point.

Volume 2

In Volume 2: Validity of Observed and Measured Data, page 10 (pdf 15), discusses the firn. Obviously, I still disagree with their assessment, but at least they tried to understand the problem.

Volume 3

In Volume 3: Attribution of Observed Climate Change, page 36 (pdf 41) Well, I tried to use Model-E, I finally had to give up because of multiple design problems. It would simply crash after an hour or so. A search of the Model-E files for the phrases returned no matches. As a result, I reject this EPA response.

The last paragraph in internally inconsistent. They probably meant to include a "not".

However, I have recently written a program to analyze the HITRAN data .. you might not believe this, but most of the action is in the lowest 10 meters. (Yes ten meters.)

The EPA statement that

would make sense if this was the only uncertainty is the models. Since that is obviously not true, that statement indicates a significant misuse of "confidence interval".

On page 39 (pdf 44)

EPA-HQ-OAR-2009-0171-2818 refers to the transcript for the May 18, 2009, public hearing in Arlington.

Author: Robert Clemenzi
URL: http:// questionable-science.com / Global_Warming / EPA_Comments / EPA_Response.html