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The WWF and the EPA Endangerment Finding

Steve McIntyre
Climate Audit
Tuesday, January 26th, 2010

One of the more interesting knock-ons of the opportunistic IPCC reliance on WWF and similar “authorities” is that it may compromise the ability of the U.S. EPA to argue that IPCC peer review meets the statutory standards required of EPA peer review.

In this respect, I refer to the Climate Audit submission to EPA last June, which considered this specific issue in considerable detail. See submission here, covering post here and first post on the topic here.

Here is an excerpt from the introduction to my submission:

2. The EPA elected to rely “heavily” on “existing” scientific assessments carried out by external parties. EPA guidelines and policies establish procedures which EPA is required to comply with, prior to utilizing scientific assessments carried out by external parties, including international bodies. These procedures include the submission of the scientific assessment by the external party to EPA together with its peer review record and the evaluation of the submission by EPA officials to evaluate the scientific content and the external party’s peer review process. The TSD failed to state that EPA complied with these procedures and there is considerable evidence that EPA did not do so.

3. Although the Intergovernmental Panel on Climate Change (IPCC) has a peer review process, their peer review process does not comply with the OMB and EPA policies for highly influential scientific assessments in many important respects, including, without limitation, non-compliance in the provision of data to reviewers and transparency. Had the EPA actually carried out the examination of IPCC peer review policy that is required prior to EPA use, it would undoubtedly have identified these and other shortcomings.

In the submission, I reviewed relevant EPA policies on peer review and showed that IPCC peer review did not comply with statutory requirements for EPA peer review. This was based on my knowledge of IPCC peer review at that time, which was primarily the handling of chapter 6 of WG1.

The peer review process for WG2 appears to be even worse. David Rose in yesterday’s Daily Mail reported that IPCC Coordinating Lead Author Lal knew the glacier claim did not rest on peer-reviewed research, but put it in anyway to “encourage” governments to take “concrete action”:

Dr Murari Lal also said he was well aware the statement, in the 2007 report by the Intergovernmental Panel on Climate Change (IPCC), did not rest on peer-reviewed scientific research.

In an interview with The Mail on Sunday, Dr Lal, the co-ordinating lead author of the report’s chapter on Asia, said: ‘It related to several countries in this region and their water sources. We thought that if we can highlight it, it will impact policy-makers and politicians and encourage them to take some concrete action.

‘It had importance for the region, so we thought we should put it in.’

Not the sort of statement that provides much reassurance for EPA officials.

Rose goes on to describe incidents in which IPCC ignored review comments on the glaciers:

For example, Hayley Fowler of Newcastle University, suggested that their draft did not mention that Himalayan glaciers in the Karakoram range are growing rapidly, citing a paper published in the influential journal Nature.

In their response, the IPCC authors said, bizarrely, that they were ‘unable to get hold of the suggested references’, but would ‘consider’ this in their final version. They failed to do so.

The Japanese government commented that the draft did not clarify what it meant by stating that the likelihood of the glaciers disappearing by 2035 was ‘very high’. ‘What is the confidence level?’ it asked.

The authors’ response said ‘appropriate revisions and editing made’. But the final version was identical to their draft.

Under IPCC procedures, it is the obligation of Review Editors to ensure that review comments are adequately responded to by authors. The failure of IPCC Review Editors to discharge their obligations has been a long-standing issue at Climate Audit. Although all review comments are supposed to be archived and although IPCC is supposed to have an “open and transparent” process, IPCC did not archive review comments from Review Editors and refused to provide review comments from WG1 chapter 6 Review Editor John Mitchell of the UK Met Office. David Holland tried to obtain Mitchell’s review comments through FOI, but his efforts have thus far been unsuccessful. (The Met Office further soured matters by making untrue statements in their efforts to evade the FOI request.) Some interesting comments from Mitchell turned up in the Climategate Letters.

The IPCC Review Editors for WG2 chapter 10 were Daniel Murdiyarso (Indonesia) and Shuzo Nishioka (Japan). It would be interesting to see how they discharged their responsibilities.

This lack of due diligence is not limited to IPCC. Gerry North, chairman of the NRC Report on Surface Temperature Reconstructions, (which is cited in the EPA Technical Support Document) stated in a seminar at his university that they “didn’t do any research”, that they got 12 “people around the table” and “just kind of winged it.” He said “that’s what you do in that kind of expert panel”. A clip of North’s remarks is online here.

That an IPCC Coordinating Lead Author should describe their process in the terms reported in Rose’s article should be of considerable concern to those EPA officials, who stated that IPCC peer review complies with statutory requirements for EPA peer review as the evidence mounts that it didn’t.

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