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Comments on Draft Technical Support Document forEndangerment Analysis for Greenhouse Gas Emissionsunder the Clean Air Act
 
By Alan CarlinNCEE/OPEIBased on TSD Draft of March 9, 2009March 16, 2009
 
 
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Important Note on the Origins of These Comments
These comments were prepared during the week of March 9-16, 2009 and arebased on the March 9 version of the draft EPA Technical Support document for theendangerment analysis for Greenhouse Gases under the Clean Air Act. On March 17, theDirector of the National Center for Environmental Economics (NCEE) in the EPA Officeof Policy, Economics, and Innovation communicated his decision not to forward thesecomments along the chain-of-command that would have resulted in their transmission tothe Office of Air and Radiation, the authors of the draft TSD.These comments (dated March 16) represent the last version prepared prior to theclose of the internal EPA comment period as modified on June 27 to correct some of thenon-substantive problems that could not be corrected at the time. No substantive changehas been made from the version actually submitted on March 16. The following exampleillustrates the type of changes made on June 27. Prior to March 16 the draft commentswere prepared as draft comments by NCEE with Alan Carlin and John Davidson listed asauthors. In response to internal NCEE comments this was changed on March 16 to singleauthor comments with assistance acknowledged by John Davidson. There wasinsufficient time, however, because of deadlines imposed by the Office of Air andRadiation, to make the corresponding change in the use of the word “we” to “I” implicitin the change in listed authorship. This change has been made in this version.It is very important that readers of these comments understand that thesecomments were prepared under severe time constraints. The actual time available wasapproximately 4-5 working days. It was therefore impossible to observe normal scholarlystandards or even to carefully proofread the comments. As a result there are undoubtedlynumerous unresolved inconsistencies and other problems that would normally have beenresolved with more normal deadlines. No effort has been made to resolve any possiblesubstantive issues; only a few of the more evident non-substantive ones have beenresolved in this version.It should be noted, of course, that these comments represent the views of theauthor and not those of the US Environmental Protection Agency or the NCEE.Alan CarlinJune 27, 2009
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