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CRE Petitions EPA to Modify EPA's Global Warming Website to Correct the Misleading and Incorrect Presentation of Information to the Public A petition for rulemaking, filed by the International Center for Technology Assessment (CTA), is currently pending at EPA seeking rulemaking to limit emissions of "greenhouse gases" (GHGs) from new motor vehicles pursuant to § 202(a)(1) of the Clean Air Act (CAA). The CTA petition alleges that certain statements found on EPA's Global Warming Website constitute "formal findings" by EPA that compel the Administrator to issue the regulations requested by CTA. The CTA petition is the catalyst for CRE's petition to EPA to modify the EPA Global Warming Website. CRE believes that much of the information on EPA's Global Warming Website is of poor quality, largely in that it is misleading to the public because the information is not presented in appropriate scientific context. Consequently, the public is likely to misunderstand it. CRE requested EPA to take three simple actions that will minimize, expeditiously, the potential for public misunderstanding concerning the scientific reliability of certain information on the EPA Global Warming Website. That Website is among the most visible and controversial of all of EPA's public information products and thus is an ideal candidate for a "test case" to assert the EPA's commitment to implement information management "best practices" as set forth in OMB Circular A-130, Management of Federal Information Resources. A recent letter from John Spotila, Administrator of the Office of Information and Regulatory Affairs at OMB, to Congresswoman Jo Ann Emerson, reinforced the point that Federal agency Chief Information Officers have authority under Circular A-130 to correct data errors and remedy poor quality data. Relying on OMB's statements, CRE requested EPA to:
CRE Explains Why EPA Must Deny and Dismiss the Pending Petition for Rulemaking Submitted by the International Center for Technology Assessment, to Regulate "Greenhouse Gases" from Motor Vehicles A petition for rulemaking, filed by the International Center for Technology Assessment (CTA), is currently pending at EPA seeking rulemaking to limit emissions of "greenhouse gases" (GHGs) from new motor vehicles pursuant to § 202(a)(1) of the Clean Air Act (CAA). The CTA petition alleges that certain statements found on EPA's Global Warming Website constitute "formal findings" by EPA that compel the Administrator to issue the regulations requested by CTA. In CRE's view, the CTA petition misinterprets or mischaracterizes certain statements on EPA's Global Warming Website as fact or as a "formal finding" that a projected or potential environmental impact is "reasonably anticipated to endanger the public health or welfare" within the meaning of § 202(a)(1) of the CAA. The CTA petition is fundamentally flawed because both EPA and the Intergovernmental Panel on Climate Change (IPCC) have stated explicitly that many significant scientific uncertainties unavoidably apply to projections about future climate change and its impacts, particularly at a regional rather than global scale. The degree and extent of uncertainty that are acknowledged by EPA and the IPCC with respect to numerous crucial scientific factors in the global climate change debate preclude EPA from making a rational decision, i.e., a "formal finding" (legal determination) for purposes of § 202(a)(1) of the CAA that GHGs from new motor vehicles "may reasonably be anticipated to endanger public health or welfare" due to their alleged global warming propensity. Therefore, EPA must deny and dismiss the CTA petition.
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