In their comment, William Happer, professor of physics, emeritus, Princeton University, and Richard Lindzen, professor of Earth, atmospheric and planetary sciences, emeritus, make both a legal and a scientific case that the EPA’s proposed new rule is based on ideologically driven polices with no basis in legitimate climate science. In a document that appears to be the prelude to filing a lawsuit to block the EPA from implementing the proposed regulation, Happer and Lindzen lay out a science-based case arguing that the new EPA rules designed to limit the use of hydrocarbon fuels in the nation’s power plants could end up reducing the world’s food supply so dramatically that billions of people worldwide would be at risk of death by starvation.
Happer and Lindzen begin their comment by citing Supreme Court precedent that suggests their comment could easily be the basis for a legal challenge in federal court to block the EPA from implementing the proposed new rule. Happer and Lindzen organized their comments around two specific cases.
First, in Daubert v. Merrell Pharmaceuticals, Inc., 509 U.S. 579, 593 (1993), the Supreme Court ruled that “‘scientific knowledge’…must be derived by the scientific method.” Second, in Motor Vehicle Manufacturers Ass’n of the United States, Inc. v. State Farm Mutual Automobile Ins. Co., 463 U.S. 29, 43 (1983), the Court held that an agency rule is “arbitrary and capricious if the agency…entirely failed to consider an important aspect of the problem” and “the relevant data.”
In their comment, Happer and Lindzen demonstrated that the EPA (1) failed to consider critically important aspects and data concerning CO2 fossil fuels and climate change, and (2) relied on numerous studies that violate the scientific method. They concluded: “As a result, the Proposed Rule, which would eliminate fossil fuel electric plants that provide 61 percent of electricity in the United States, will be disastrous for the country, for no scientifically justifiable reason.”
To support their claim, Happer and Lindzen argued that the EPA had failed to consider the following “important aspects of climate change and relevant data.”Carbon dioxide is essential to life, creating via the process of photosynthesis the food we eat and the oxygen we breathe. Without carbon dioxide, there would be no human life or other life on earth.
- Increased levels of carbon dioxide in the atmosphere create more food for people worldwide, including more food for people in drought-stricken areas. To illustrate, increases in carbon dioxide over the past two centuries since the Industrial Revolution, from about 280 parts per million (ppm) to about 420 ppm, caused an approximate 20% increase in the food available to people worldwide, as well as increased greening of the planet and a benign warming in temperature.
- Fossil fuels are indispensable in creating nitrogen fertilizer and pesticides that feed nearly half the world; their combustion releases carbon dioxide and thus increases plant growth via increased CO2 fertilization effect, creating more food worldwide; and they provide the most reliable, efficient and low-cost energy for many uses, including the production of 61% of the nation’s electricity.
- The number of people worldwide who are moderately or severely food insecure is 2.3 billion, including over 900 million who face severe food insecurity. Each ton of carbon dioxide emissions eliminated reduces the amount of food available worldwide. “Net zero” would reduce carbon emissions by over 40 gigatons (Gt) every year, and consequently would proportionally reduce the amount of food produced. Without the “use of inorganic [nitrogen] fertilizers” derived from fossil fuels, the world simply “will not achieve the food supply needed to support 8.5 to 10 billion people,” resulting in widespread starvation.
- All of the models that predict catastrophic global warming fail the key test of the scientific method: they grossly overpredict the warming versus actual data.
- 600 million years of data prove that today’s CO2 level of 420 parts per million (ppm) is very low, not high.
- 600 million years of data show that higher levels of CO2 do not cause or even correlate with higher temperatures.
Another defect Happer and Lindzen noted was that the EPA, in promulgating the new rule, relied heavily on IPCC data. Yet, unknown to most, IPCC rules require that IPCC governments control what IPCC reports as “scientific” findings on CO2, fossil fuels, and anthropogenic climate change, not scientists. IPCC governments meet behind closed doors and control what is published in...
