The EPA Steps In To Regulate Greenhouse Gases In Case Of Cap And Trade Failure

Goldman's tentacles are smart, and know all about contingency planning. With so much of the firm's future strategy contingent on Cap And Trade derived profits, the firm is hedging for a downside case scenario. The attached presentation by the Environmental Protection Agency is just the fall back plan. UEA debate notwithstanding, the EPA, after "careful consideration of the full weight of scientific evidence and a thorough review of numerous public comments received on the Proposed Findings published April 24, 2009" has found that "six greenhouse gases taken in combination endanger both the public health and the public welfare of current and future generations." Truly an opportune timing for the EPA to come up with this report, seeing how suddenly scientific evidence does not really mean as much as it used to...oh, one month ago. And not to mention that whole Goldman/Cap And Trade backlash of course.

Here are the "definitive" conclusions from the report:

CO2 is dangerous (p.8):

Pursuant to CAA section 202(a), the Administrator finds that greenhouse gases in the atmosphere may reasonably be anticipated both to endanger public health and to endanger public welfare. Specifically, the Administrator is defining the "air pollution" referred to in CAA section 202(a) to be the mix of six long-lived and directly-emitted greenhouse gases: carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6). In this document, these six greenhouse gases are referred to as “well-mixed greenhouse gases” in this document (with more precise meanings of “long lived” and “well mixed” provided in Section IV.A)

The whole totally blown out of proportion topic of data destruction (p.46):

Our response regarding the request to reopen the comment period due to concerns about alleged destruction of raw global surface data is discussed more fully in the Response to Comments document, Volume 11. The commenter did not provide any compelling reason to conclude that the absence of these data would materially affect the trends in the temperature records or conclusions drawn about them in the assessment literature and reflected in the TSD. The Hadley Centre/Climate Research Unit (CRU) temperature record (referred to as HadCRUT) is just one of three global surface temperature records that EPA and the assessment literature refer to and cite. National Oceanic and Atmospheric Administration (NOAA) and National Aeronautics and Space Administration (NASA) also produce temperature records, and all three temperature records have been extensively peer reviewed. Analyses of the three global temperature records produce essentially the same long-term trends as noted in the Climate Change Science Program (CCSP) (2006) report "Temperature Trends in the Lower Atmosphere," IPCC (2007), and NOAA's study5 "State of the Climate in 2008". Furthermore, the commenter did not demonstrate that the allegedly destroyed data would materially alter the HadCRUT record or meaningfully hinder its replication. The raw data, a small part of which has not been public (for reasons described at:, are available in a quality-controlled (or homogenized, value-added) format and the methodology for developing the quality-controlled data is described in the peer reviewed literature (as documented at"

On the proposed regulation to date (p. 22-23):

"On September 15, 2009, EPA and the Department of Transportation’s National Highway Safety Administration (NHTSA) proposed a National Program that would dramatically reduce greenhouse gas emissions and improve fuel economy for new cars and trucks sold in the United States. The combined EPA and NHTSA standards that make up this proposed National Program would apply to passenger cars, light-duty trucks, and medium-duty passenger vehicles, covering model years 2012 through 2016. They proposed to require these vehicles to meet an estimated combined average emissions level of 250 grams of carbon dioxide per mile, equivalent to 35.5 miles per gallon (MPG) if the automobile industry were to meet this carbon dioxide level solely through fuel economy improvements. Together, these proposed standards would cut carbon dioxide emissions by an estimated 950 million metric tons and 1.8 billion barrels of oil over the lifetime of the vehicles sold under the program (model years 2012-2016). The proposed rulemaking can be viewed at (74 FR 49454, September 28, 2009)."

As a reminder Congress can use the Congressional Review Act to overrrule regulations, and if they end up violating procedures to protect small businesses, indian tribes, etc., injured parties may have rights to object. Wink, wink.

Full EPA document: