One front of the climate alarmist war on fossil fuels, freedom and prosperity is the effort to force companies to state the financial “risks” the climate “crisis” presents. This mischief has taken place not in rulemaking at the Environmental Protection Agency, but rather at the Securities and Exchange Commission and in political lawsuits filed by virtue signaling leftist Democratic State Attorneys General (like Janet Mills she was running for Governor) and green partisan warriors like the Sierra Club and 350.org.
The SEC rule is up for public comment and eminent scientists William Happer (Princeton) and Richard Lindzen (MIT) filed a doozy. Titled “Comment and Declaration on the SEC’s Proposed Rule “The Enhancement and Standardization of Climate-Related Disclosures for Investors,” it is available at Happer-Lindzen-SEC-6-17-22.pdf (co2coalition.org).
A few choice excerpts:
“AS CAREER PHYSICISTS, SCIENCE DEMONSTRATES THERE IS NO CLIMATE RELATED RISK CAUSED BY FOSSIL FUELS AND CO2, THUS NO SCIENTIFIC BASIS FOR THE PROPOSED RULE, AND, IF ADOPTED, DISASTROUS CONSEQUENCES FOR PEOPLE WORLDWIDE AND THE U. S. BECAUSE IT WOULD REDUCE CO2 AND THE USE OF FOSSIL FUELS”
“In our opinion, science demonstrates that there is no climate related risk caused by fossil fuels and CO2 and no climate emergency.
Further, nowhere in the more than 500 pages of the proposed rule is there any reliable scientific evidence that there exists a climate related risk. None. It refers to the International Panel on Climate Change (“IPCC”), the Task Force on Climate-Related Financial Disclosures (“TCFD”) and other outside groups, but never provides any reliable scientific evidence that supports the rule. The science is just assumed. Therefore, there is no reliable scientific basis for the proposed SEC rule.
Further, contrary to what is commonly reported, CO2 is essential to life on earth. Without CO2, there would be no photosynthesis, and thus no plant food and not enough oxygen to breathe. Moreover, without fossil fuels there will be no low-cost energy worldwide and less CO2 for photosynthesis making food.
Eliminating fossil fuels and reducing CO2 emissions will be disastrous for the poor, people worldwide, future generations and the country.
Finally, the cost of the proposed rule is enormous and would have no public benefit. It would increase the reporting burden to companies $6.4 billion, which is 64% more than the $3.9 billion all SEC reporting requirements have cost companies from its beginning in 1934. Id., 87 Fed. Reg., p. 21461. Thus, the rule must not be adopted or, if adopted, ruled invalid by the courts.
I. RELIABLE SCIENTIFIC THEORIES COME FROM VALIDATING THEORETICAL PREDICTIONS WITH OBSERVATIONS, NOT CONSENSUS, PEER REVIEW, GOVERNMENT OPINION OR MANIPULATED DATA
II. SCIENCE DEMONSTRATES THERE IS NO CLIMATE-RELATED RISK CAUSED BY FOSSIL FUELS AND CO2, AND THEREFORE NO RELIABLE SCIENTIFIC EVIDENCE SUPPORTING THE PROPOSED RULE
A. There is No Urgency to Act Now and Thus There is No Need for the Proposed Rule
B. Today’s 415 ppm CO2 Level is Near a Record Low, Not Dangerously High, and Thus Provides No Reliable Scientific Evidence to Support the Proposed Rule
C. 600 Million Years of CO2 and Temperature Data Contradict the Theory that High Levels of CO2 Will Cause Catastrophic Global Warming, Thus Confirming There is No Reliable Scientific Evidence Supporting the Proposed Rule
D. Two Recent Warming Periods Show Increased CO2 Doesn’t Drive Major Temperature Increases, Thus Providing No Reliable Scientific Evidence to Support the Proposed Rule
E. The IPCC CMIP and Other Models Fail to Reliably Predict Temperatures, Thus Confirming There is No Reliable Scientific Evidence Supporting the Proposed Rule
F. The IPCC is Government Controlled and Only Issues Government Dictated Findings, and Thus Can Provide No Reliable Scientific Evidence for the Proposed Rule
G. The Endangerment Findings and National Climate Assessments Rely on IPCC Findings and Thus Provide No Reliable Scientific Evidence to Support the Proposed Rule
H. The Social Cost of Carbon TSD Estimates are Scientifically Invalid and Thus Provide No Reliable Scientific Evidence to Support the Proposed Rule
I. “Net Zero” Worldwide Emissions Would Have a Trivial Impact on Temperatures, Thus Confirming There is No Reliable Scientific Evidence Supporting the Proposed Rule
J. Climate Science is Awash with Manipulated Data, Which Provides No Reliable Scientific Evidence to Support the Proposed Rule
K. NAS’ Valuing Climate Damages is Based on Peer Review and Consensus, Not Scientific Method, and Thus Provides No Reliable Scientific Evidence to Support the Proposed Rule
L. Climate Science Publishing Is Dominated by One-Sided, Paid-For Studies with No Disclosure, and Thus Provides No Reliable Scientific Evidence to Support the Proposed Rule Without Full Disclosure of Funding
M. The Logarithmic Forcing from CO2 Means that Its Contributions to Global Warming is Heavily Saturated, Instantaneously Doubling CO2 Concentrations from 400 ppm to 800 ppm, a 100% Increase, Would Only Diminish the Thermal Radiation to Space by About 1.1%, Thus Confirming There is No Reliable Scientific Evidence Supporting the Proposed Rule
III. IF THE RULE IS ADOPTED THERE WOULD BE DISASTROUS CONSEQUENCES FOR THE POOR, PEOPLE WORLDWIDE, FUTURE GENERATIONS AND THE UNITED STATES BECAUSE IT WOULD REDUCE CO2 AND THE USE OF FOSSIL FUELS
A. CO2 is Essential to Our Food, and Thus to Life on Earth
B. Photosynthesis from Atmospheric CO2 Sustains Most Live on Earth
C. Greenhouse Gases Prevent Us from Freezing to Death
D. Enormous Social Benefits of Fossil Fuels “
The graph demonstrates the absolute failure of climate models to accurately predict the temperature record.
There’s a lot more. Check it out yourself, and tell the climate alarmists to pound sand.
Effective September 1 2022, Jon Reisman is retiring from the University of Maine at Machias after 38 years. Mr. Reisman’s views are his own and he welcomes comments as letters to the editor here, or to him directly via email at [email protected].