Document Rjm3RjmY4MDrqQ0Q3o4OvQ2BV
To: Cc: From: Sent: Subject:
Pruitt, ScottfPruitt.Scott@epa.gov] Jackson, Ryan[jackson.ryan@epa.gov]; Francis Menton[francismenton@icloud.com] Harry MacDougald Tue 10/17/2017 11:57:58 AM Reconsideration of the GHG Endangerment Finding
Dear Administrator Pruitt: Attached please find correspondence relating to reconsideration of the 2009 Greenhouse Gas Endangerment Finding.
Sincerely,
Harry W. MacDougald Caldwell Propst & DeLoach, LLP
Two Ravinia Drive Suite 1600
Atlanta, Georgia 30346 404-843-1956
17cv1906 Sierra Club v. EPA
ED_001523_00001184-00001
HARRY W. MacDOUGALD
Caldwell,
Propst & DeLoach,
ATTORNEYS AT LAW TWO RAVINIA DRIVE
SUITE 1600
Atlanta, Georgia 30346
llp
hmacdougald@cpdlawyers.com www.cpdlawyers.com
TELEPHONE 404-843-1956 FACSIMILE 404-843-2737
October 17, 2017
Via email Pruitt^
ov and Regular Mail
The Honorable Scott Pruitt Administrator Environmental Protection Agency Office of the Administrator, Mail Code 1101A 1200 Pennsylvania Avenue, N.W. Washington, DC 20460
RE: Petition for Reconsideration of Endangerment and Cause or Contribute Findings for Greenhouse Gases Under Section 202(a) of the Clean Air Act
Dear Administrator Pruitt:
As you know, Francis Menton and I represent the Concerned Household Electricity Consumers Council. On their behalf we have filed an administrative petition for reconsideration of the 2009 Endangerment Finding for Greenhouse Gases, and have supplemented it twice.
We further supplement our petition with the attached letter from 64
distinguished scientists. They characterize the 2009 Endangerment Finding as "fundamentally flawed" and urge you to conduct an honest and unbiased reconsideration in accordance with governing law. These scientists are also offering to assist EPA in the reconsideration process. Considering the depth and breadth of expertise in this group, you would do well to accept their offer.
Should you have any questions or comments, please let us know.
Sincerely,
cc Francis Menton (w / enclosure) Ryan Jackson via email Jackson.R an@EPA.- ov (w/ enclosure) Ken Haapala (w/o enclosure) CHECC Membership (w/ enclosure)
17cv1906 Sierra Club v. EPA
ED_001523_00001185-00001
October 16, 2017
The Honorable Scott Pruitt Administrator Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Washington, DC 20460
Dear Administrator Pruitt:
You have pending before you two science-based petitions for reconsideration of the 2009 Endangerment Finding for Greenhouse Gases, one filed by the Concerned Household Electricity Consumers Council, and one filed jointly by the Competitive Enterprise Institute and the Science and Environmental Policy Project.
We the undersigned are individuals who have technical skills and knowledge relevant to climate science and the GHG Endangerment Finding. We each are convinced that the 2009 GHG Endangerment Finding is fundamentally flawed and that an honest, unbiased reconsideration is in order.
If such a reconsideration is granted, each of us will assist in a new Endangerment Finding assessment that is carried out in a fashion that is legally consistent with the relevant statute and case law.
We see this as a very urgent matter and therefore, request that you send your response to one of the signers who is also associated with a petitioner, SEPP.
Thank you,
Kenneth Haapala, President Science and Environmental Policy Project P.O. Box 1126 Springfield, VA 22151 One of the Petitioners
Supporting Petitions - Expertise in Climate Science and Related Fields
Dr. Ralph B. Alexander Former Associate Professor, Wayne State University, Detroit Author, "Global Warming False Alarm" Ph.D., Physics, University of Oxford B.S., Physics, University of Western Australia El Dorado Hills, CA
1
17cv1906 Sierra Club v. EPA
ED_001523_00001186-00001
William D. Balgord, Ph.D. President, Environmental & Resources Technology, Inc. Ph.D. geochemistry, Pennsylvania State University M.A., geology, University of Missouri B.S., chemistry, Millsaps College
Dr. Tim Ball Ph.D., Historical Climatology MA, University of Manitoba BA, University of Winnipeg Victoria, Canada
James R. Barrante, Ph.D. Emeritus Professor of Physical Chemistry Southern Connecticut State University Author: "Global Warming for Dim Wits"
Joe Bastardi BS Meteorology Penn State University Chief Long Range Forecaster, Accuweather Advisor on climate and weather issues for media and industry Co-founder and Chief Meteorologist, Weatherbell Analytics LLC
David J. Benard Co-inventor of the Chemical Oxygen-Iodine Laser Ph.D., Physics, University of Illinois Newbury Park, CA
Dr. Edwin X Berry Climate Physics, LLC Certified Consulting Meteorologist PhD, Physics, University of Nevada MA, Physics, Dartmouth College BS, Engineering, California Institute of Technology Bigfork, Montana
John Blethen, Retired Following climate science closely since the 1970s. Ph.D., Physics, Stanford University
David Boleneus Consulting geologist, geophysicist, and wheat grower (current) U.S. Geological Survey research geologist (retired) MS Geology, Louisiana State University Thesis: Calcium carbonate precipitation in tropical oceans BS Geology, Eastern Washington University
2
17cv1906 Sierra Club v. EPA
ED_001523_00001186-00002
Vice Admiral Edward S. Briggs United States Navy (Retired)
David J. Bufalo, P.E. Retired Licensed Professional Engineer, Missouri and Colorado BS Civil Engineering, Missouri University of Science and Technology Denver, Colorado
Dr. Roger Burtner Principle, Remote Sensing Exploration Retired Senior Research Associate, Chevron Oil Field Research Company Ph.D., Geology, Harvard, M.S., Geology, Stanford University B.S., Geology, Franklin & Marshall College Fullerton, CA
Dr. Alan Carlin Retired Senior Analyst and manager, US Environmental Protection Agency, Washington, DC. Author, Environmentalism Gone Mad, Stairway Press, 2015. Ph.D., Economics, Massachusetts Institute of Technology, Cambridge, MA. BS, Physics, California Institute of Technology, Pasadena, CA.
John Coleman Retired, Former Professional Member of the American Meteorological Society Broadcast Meteorologist of the Year in 1982, Founder of The Weather Channel Meteorologist on Television for 61 years including Good Morning America BS Journalism, University of Illinois Las Vegas, Nevada
William F. Condon, Ph. D. Professor Emeritus and Past Chair of Chemistry, Southern Connecticut State University
Joseph S. D'Aleo Certified Consulting Meteorologist, AMS Fellow Chair AMS Committee on Weather Analysis and Forecasting ABD, Air Resources, New York University BS, MS Meteorology, University of Wisconsin
Dr. Harold H. Doiron Retired VP-Engineering Analysis and Test Division, InDyne, Inc. Ex-NASA JSC, Aerospace Consultant B.S. Physics, University of Louisiana - Lafayette M.S., Ph.D., Mechanical Engineering, University of Houston
Terry W. Donze Geophysicist for 46 years, Author - Climate Realism: Alarmism Exposed, Xulon Press BS - Geological Engineering, Missouri Univ, of Science and Technology
3
17cv1906 Sierra Club v. EPA
ED_001523_00001186-00003
John Droz, jr. Physicist Founder of Alliance for Wise Energy Decisions (AWED) Morehead City, NC
Dr. Don J. Easterbrook Emeritus Professor of Geology, Western Washington University Author, editor of 10 books, over 150 journal publications Ph.D., Geology, University of Washington, Seattle M.S., Geology, University of Washington, Seattle B.S., Geology, University of Washington, Seattle
Robert W. Endlich, Lt Col USAF, (Ret) Advanced Weather Officer, Chi Epsilon Pi, Meteorology Honor Society M.S., Meteorology, The Pennsylvania State University Basic Meteorology, Texas A&M University B.A, Geology, Rutgers University Las Cruces, NM
Dr. Neil Frank Former Director, National Hurricane Center Ph.D. Meteorology, Florida state University Fulshear, Texas
Dr. Gordon J. Fulks Gordon Fulks and Associates PhD Physics, The University of Chicago Laboratory for Astrophysics and Space Research MS Physics, The University of Chicago BS Physics, The University of Chicago Corbett, Oregon
Melin O. Glerup BS and MS Geological Engineer and Petroleum Geologist Retired Texaco, Inc. Executive and Consulting Geologist Member of two Climate Study Groups (last 12 years) and geologist for 47 years San Tan Valley, AZ
Steve Goreham Executive Director, Climate Science Coalition Author, Outside the Green Box: Rethinking Sustainable Development, New Lenox Books BS and MS, Electrical Engineering, University of Illinois, Urbana MBA, University of Chicago
Laurence I. Gould, PhD Professor of Physics, University of Hartford Past Chair (2004) New England Section of the American Physical Society
4
17cv1906 Sierra Club v. EPA
ED_001523_00001186-00004
Dr. William Happer Professor of Physics Emeritus, Princeton University Ph.D., Physics, Princeton University, 1964 BS, Physics, University of North Carolina, Chapel Hill, 1960
Dr. Howard C. Hayden Prof. Emeritus of Physics, UConn Ph.D., Physics, University of Denver M.S., Physics, University of Denver B.S., Physics, University of Denver Pueblo West, CO
Admiral Thomas B. Hayward (ret) Chief of Naval Operations
Joe Hennessey Consulting Meteorologist, Sacramento, California Provided meteorological advice, data analyses, wind farm planning and WindPro modelling to National Power which had over 2,000 MW of projects in Australia and Hawaii. MS Atmospheric Science, Oregon State University BS Meteorology, University of Utah, BS Mathematics, Marquette University
Dr. Richard A. Keen (Emeritus) Instructor of Atmospheric and Oceanic Sciences, University of Colorado, Boulder PhD, Geography/Climatology, University of Colorado
William W. Little, Ph.D. Professor of Geology at Brigham Young University, Idaho Owner of W.W. Little Geological Consulting Ph.D. in geology, University of Colorado, Boulder M.S. in geology, Brigham Young University B.S. in geology, Brigham Young University Rexburg, ID
Dr. David R. Legates Professor of Geography, University of Delaware, CCM, American Meteorological Society Ph.D., Climatology, University of Delaware M.S., Geography, University of Delaware B.A., Mathematics & Geography, University of Delaware
Jay Lehr Science Director, The Heartland Institute, Author/editor 30 books on science Ph.D., University of Arizona Environmental Science B.S.E. Princeton University Ostrander Ohio
5
17cv1906 Sierra Club v. EPA
ED_001523_00001186-00005
Richard E. McFarland Retired recursive computing expert 40 years NASA, ARC SimLab Graduate studies in Math, Stanford BA Physics, UC Berkeley Banning, CA
Dr. Troy Milliken Chemistry Professor, Holmes Community College Ph.D., Polymer Chemistry, University of Massachusetts BS, Polymer Science, Penn State University Jackson, MS
H. Michael "Mike" Mogil How the Weatherworks NCIM Past President (2015-2017) Certified Consulting Meteorologist Certified Broadcast Meteorologist
Cliff Ollier Emeritus Professor, Geologist University of Western Australia B.Sc., M.Sc., D.Sc., Bristol
James M. Peacock Charter Member of The Right Climate Stuff Research Team NASA JSC Aerospace Engineer (Apollo Missions) USAF R&D, Air Force Special Weapons Center B.S. in M.E. Texas A & M University
Ron W. Pritchett Professional Geological Scientist (AIPG) #7063 Lone Tree, CO
Tom Quirk Nuclear physicist, board member of electricity, gas and transport businesses MSC Melbourne, D Phil MA Oxford, fellow of three Oxford colleges SMP Harvard Business School Melbourne Victoria, Australia
Dr. Arthur G. Randol III Co-Founder, VA Scientists and Engineers for Energy and Environment Ph.D., Nuclear Engineering Sciences, University of Florida M.S.E., Nuclear Engineering Sciences, University of Florida B.S., Mechanical Engineering-Nuclear Option, University of Notre Dame
6
17cv1906 Sierra Club v. EPA
ED_001523_00001186-00006
Dr. Chad Rodekohr Professor of Physics, Presbyterian College Ph.D. Mechanical Engineering, Auburn University M.S. Physics, Auburn University B.S Aviation Management, Auburn University Clinton, South Carolina
Richard L. Sauer, PE, MASCE, Col, Ret, USAR M.S. in Environmental Engineering, UC Berkeley B.S., Civil Engineering, University of Notre Dame S/C Environmental Systems Engineer, NASA, Retired, TRCS Member League City, TX
Dr. Thomas P. Sheahen Ph.D., Physics, M.I.T. B.S., Physics, M.I.T.
Dr. Willie Soon Independent Scientist, 26+ years' experience in Sun and Climate Science research Ph.D., University of Southern California, Aerospace Engineering, "Nonequilibrium kinetics in high-temperature gases"
John Turner B.Sc.; Dip. Ed.; M.Ed. (Hons); Grad. Dip. Ed. Studies Australia
Dr. James P. Wallace III Jim Wallace & Associates LLC Ph.D., Economics, Minor in Engineering, Brown University M.S., Mechanical Engineering, Brown University B.S., Aeronautical Engineering, Brown University
George T. Wolff, Ph.D. Principal Scientist, Air Improvement Resource, Inc. Former Chair of the Clean Air Scientific Advisory Committee Ph.D., (Environmental Sciences), Rutgers University M.S., (Meteorology), New York University B.S., (Chemical Engineering), New Jersey Institute of Technology Macatawa, MI
Dr. Kenneth C. Young Faculty member, Department of Atmospheric Sciences, University of Arizona Ph.D., Geophysical Sciences, University of Chicago M.S., Geophysical Sciences, University of Chicago B.S., Chemistry, Arizona State University Petrolia, CA
7
17cv1906 Sierra Club v. EPA
ED_001523_00001186-00007
Supporting Petitions - Expertise in Energy or Public Health and Welfare, and Related Fields
Jerome C. Arnett, Jr., M.D. Pulmonologist in private practice Doctor of Medicine, WVU School of Medicine Board Certified, Internal Medicine Board Certified, Pulmonary Diseases Helvetia, W. Va.
E. Calvin Beisner, Ph.D., Founder and National Spokesman The Cornwall Alliance for the Stewardship of Creation Author of numerous books regarding Climate Policy and the Poor. Expert witness on the ethics and economics of climate and energy policy, U.S. Senate Environment & Public Works Committee, 2006, and Energy & Environment Subcommittee, U.S. House of Representatives Committee on Energy & Commerce, 2009 Ph.D., History, University of St. Andrews, 2003 M.A., Economic Ethics, International College, 1983 B.A., Religion and Philosophy, University of Southern California, 1978
Dr. Roger H. Bezdek President, MISI, Washington, D.C. Founding Member, Cavendish Energy LLC, Fort Worth, Texas. Previously served as Senior Advisor in the Office of the Secretary of the U.S. Treasury Research Director at the U.S. Department of Energy. Author of four books and over 100 published papers on the economics of climate change and related issues. Ph.D., Economics, University of Illinois at Urbana-Champaign
Donn Dears Retired, General Electric Company senior executive, expert on energy issues Author, Clexit, Nothing to Fear, and Carbon Folly Graduate, GE's three-year Manufacturing Management Program Multiple general manager assignments including, GM of Engineering Department providing technical support to worldwide network of GE facilities. USN Veteran Korean War BS, with honors, United States Merchant Marine Academy The Villages, Florida
John Dale Dunn, MD, JD Lecturer, retired Clinical Instructor, Department of Emergency Medicine, Carl R Damall Army Medical Center. Clinical Instructor Uniform Services University of the Health Sciences, Bethesda, Maryland. Policy advisor, American Council on Science and Health of New York City and Heartland Institute of Chicago. Member, Louisiana and Texas Bar; Medical Officer, Sheriff, Brown County, Texas.
8
17cv1906 Sierra Club v. EPA
ED_001523_00001186-00008
James E. Enstrom Interests include important effects of ozone and PM 2.5 MPH, Epidemiology, University of California, Los Angeles M.S. and Ph.D., Physics, Stanford University B.S., Physics, Harvey Mudd College
Thomas D. Hennigan Associate Professor of Ecology and Organism Biology M.P.S. Environmental Science and Forest Biology, SUNY, Syracuse, NY B.S. Natural Resources Management, University of Alaska, Fairbanks, AK
Paul D. Hoffman Publicist, Hope Springs Media Former Deputy Assistant Secretary of the Interior for Fish and Wildlife and Parks Led the US Delegation to the World Heritage Committee, 2002-06 B.A., Economics/Biology, University of California at San Diego, Revelle College
Dr. Craig D. Idso Chairman, Center for the Study of Carbon Dioxide and Global Change Co-Editor, Nongovernmental International Panel on Climate Change (NIPCC) Ph.D. Geography, Arizona State University, Tempe, AZ M.S. Agronomy, University of Nebraska, Lincoln, NE B.S. Geography, Arizona State University, Tempe, AZ
Steve Milloy Publisher, JunkScience.com LLM, Securities Regulation, Georgetown University Law Center JD, University of Baltimore School of Law MHS, Biostatistics, Johns Hopkins University School of Public Health B.A., Natural Sciences, Johns Hopkins University
Franklin E. (Ed) Payne, M.D. Associate Professor of Family Medicine (retired) Medical College of Georgia, Augusta University Augusta, GA
Cornelis J. F. Smit, Founder and CEO (now retired), Environmental Health Services (Aust) Pty. Ltd Co-founder and Director, The Galileo Movement B.Sc., University of Melbourne, Certified Industrial Hygienist (AIHA) Noosaville, Qld., Australia
17cv1906 Sierra Club v. EPA
ED_001523_00001186-00009
H. Leighton Steward Geologist, environmentalist, author, and retired energy industry executive. Regional EPA Administrator's Award for environmental excellence. Chairman of the Board of The Institute for the Study of Earth and Man at SMU Past Chairman of the National Wetlands Coalition Twice Chairman of the Audubon Nature Institute. Serves on the boards of the M. D. Anderson Cancer Center, EOG Resources, The Buffalo Bill Historical Center, and the Southwest Research Institute.
Dr. S. Stanley Young Worked in the pharmaceutical industry on all phases of pre-clinical research. Member of the American Council on Science and Health Board of Scientific Advisors. Authored or co-authored over 50 papers including six "best paper" awards. Fellow of the American Statistical Association, American Association for the Advancement of Science. Adjunct professor of statistics at North Carolina State University, the University of Waterloo and the University of British Columbia where he co-directs thesis work. B.S., MES and a Ph.D., North Carolina State University.
17cv1906 Sierra Club v. EPA
ED_001523_00001186-00010