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Response to Request for Input from Commissioner Allison Herron Lee, Securities and Exchange Commission
Response to Request for Input from Commissioner Allison Herron Lee, Securities and Exchange Commission on Climate Risk Disclosures Benjamin Zycher Resident Scholar, American Enterprise Institute June 10, 2021 Estimation of climate “risks” by public companies would be futile, politicized, distorted by an imperative to avoid regulatory and litigation threats, and largely arbitrary, and thus would not serve the traditional goal of the provision of material information to investors. Submitted by webform: https://www.sec.gov/cgi-bin/ruling-comments This comment letter responds to a request for input from Securities and Exchange Commissioner Allison Herren Lee on the topic of climate “risk” disclosures by public companies.1 It is organized as follows: Summary I. Climate Uncertainties and Choices Among Crucial Assumptions. II. The Evidence on Climate Phenomena and the Effects of Climate Policies in the EPA Climate Model. III. Observations on the Materiality of Climate “Risks.” IV. Additional Observations and Conclusions. 1 See https://www.sec.gov/news/public-statement/lee-climate-change-disclosures#. The American Enterprise Institute (AEI) is a nonpartisan, nonprofit, 501(c)(3) educational organization and does not take institutional positions on any issues. The views expressed in this testimony are those of the author. 2 Summary • No public company and few, if any, government administrative agencies are in a position to evaluate climate phenomena, whether ongoing or prospective, with respect to which the scientific uncertainties are vastly greater than commonly asserted. • The range of alternative assumptions about central parameters is too great to yield clear implications for the climate “risks” facing specific public companies, economic sectors, and geographic regions. -
Ngeo170 Commentary.Indd
COMMENTARY To blog or not to blog? GAVIN SCHMIDT is at the NASA Goddard Institute of Space Studies Columbia University 2880 Broadway, New York, New York 10025, USA; co-founder of RealClimate.org. e-mail: [email protected] Scientists know much more about their fi eld than is ever published in peer-reviewed journals. Blogs can be a good medium with which to disseminate this tacit knowledge. ike it or not, there are certain important from a quick skim of the lively. However, this kind of informal scientific areas, such as climate methodology, a figure or two and the second-stage peer review is vital to change, stem-cell research, principal results. Their experience the need to quickly process the vast genetic modification of food teaches them to pay little attention to amount of information being produced. L or evolution, that attract a the occasional piece of overreach in Scientists from all fields rely on it heavily disproportionate amount of public the last paragraph and to fill in the to make a first cut between the studies attention. This is usually because they are sometimes understated background. that are worth reading in more detail and perceived to have relevance for strongly By contrast, a lay person might focus those that aren’t. held ethical, economic, moral or political much more on the easy-to-understand Scientists writing in blogs can make beliefs. Scientific results in these fields ‘throwaway’ comments, and spend little this context available to anyone who is are therefore parsed extremely closely to time evaluating the usefulness of the interested. -
STATEMENT to the COMMITTEE on SCIENCE, SPACE and TECHNOLOGY of the UNITED STATES HOUSE of REPRESENTATIVES Hearing on Climate S
STATEMENT TO THE COMMITTEE ON SCIENCE, SPACE AND TECHNOLOGY OF THE UNITED STATES HOUSE OF REPRESENTATIVES Hearing on Climate Science: Assumptions, Policy Implications and the Scientific Method 29 March 2017 Judith A. Curry Climate Forecast Applications Network Georgia Institute of Technology [email protected] Major points: • Scientific progress is driven by the creative tension spurred by disagreement, uncertainty and ignorance. • Progress in understanding the climate system is being hampered by an institutionalized effort to stifle this creative tension, in the name of a ‘consensus’ that humans have caused recent climate change. • Motivated by the mandate from the UN Framework Convention on Climate Change (UNFCCC), the climate community has prematurely elevated a scientific hypothesis on human-caused climate change to a ruling theory through claims of a consensus. • Premature theories enforced by an explicit consensus building process harm scientific progress because of the questions that don’t get asked and the investigations that aren’t undertaken. As a result, we lack the kinds of information to more broadly understand climate variability and societal vulnerabilities. • Challenges to climate research have been exacerbated by: o Unreasonable expectations from policy makers o Scientists who are playing power politics with their expertise and trying to silence scientific disagreement through denigrating scientist who do not agree with them o Professional societies that oversee peer review in professional journals are writing policy statements endorsing the consensus and advocating for specific policies • Policymakers bear the responsibility of the mandate that they give to panels of scientific experts. The UNFCCC framed the climate change problem too narrowly and demanded of the IPCC too much precision – where complexity, chaos, disagreement and the level of current understanding resists such precision. -
$1.2 Million Conflict of Interest Plagues Climate Change Denial Research
$1.2 Million Conflict of Interest Plagues Climate Change Denial Research... http://natmonitor.com/2015/02/22/1-2-million-conflict-of-interest-plague... $1.2 Million Conflict of Interest Plagues Climate Change Denial Research By James Paladino, National Monitor | February 22, 2015 A recently uncovered document shows that Wei-Hok Soon, a well-known aerospace engineer, was granted over $1.2 million from fossil-fuel companies for climate research and failed to disclose a conflict of interest in his peer-reviewed publications. In Washington, climate change deniers are fighting a fierce battle to stave off energy policy reform. The latest casualty of this war of ideas is Wei-Hock Soon, a part-time employee of the Harvard-Smithsonian Center for Astrophysics. Resilient to the scientific consensus that human carbon emissions are fueling gradual warming, the aerospace engineer has served as a beacon for conservative legislators. A recently uncovered document shows that Soon was granted over $1.2 million from fossil-fuel companies and failed to disclose a conflict of interest in his peer-reviewed publications. Since the Smithsonian is part of the federal government, former Greenpeace member Kert Davies legally obtained the Soon’s grant agreements through the Freedom of Information Act. Contributors include the American Petroleum Institute, the Koch brothers, Exxon Mobil and Southern Company. Several scientific papers and a congressional testimonial were termed as “deliverables,” reports The New York Times. “These proposals and contracts show debatable interventions in science literally on behalf of the Southern Company and the Kochs,” said Davies. “What it shows is the continuation of a long-term campaign by specific fossil-fuel companies and interests to undermine the scientific consensus on climate change.” These recent revelations have drawn fire from members of the Harvard-Smithsonian Center and NASA, among others. -
Why Won't the Australian Government Follow
WHY WON’T THE AUSTRALIAN > GOVERNMENT FOLLOW CANADA’S LEAD ON FREE SPEECH? AARON LANE Research Fellow at the Institute of Public Affairs n a visit to Canada earlier this year, Prime Minister Tony Abbott praised Canada for being a longstanding friend of IAustralia that has always shared our commitment to democracy and liberty. So why won’t the Australian government follow Canada’s lead and completely repeal section 18C of the Racial Discrimination Act? In June 2013, Canada repealed its section 13 of its Human Rights Act. This section made it unlawful to communicate, by phone or internet, ‘any material that is likely to expose a person or persons to hatred or contempt’ based on grounds of discrimination. (The prescribed grounds of discrimination included race, national or ethnic origin, colour, and religion.) A key problem with Canada’s section 13 of the provision is the use of the word ‘likely’ to have exposed somebody to ‘hatred of contempt’. Canadian Conservative MP, and sponsor of the repeal bill, Brian Storseth explains: This is a very subjective and unnecessarily vague definition, not AUGUST 2014 | IPA Review 11 IPA_21 Review July 2014 C2.indd 11 5/08/2014 6:17:02 PM R FREE SPEECH Volume 66 I 2 CONTINUED undermine the dignity and self- THE BATTLELINES WERE one of the narrowly defined legal worth of target group members DRAWN BETWEEN definitions that would be far more and, more generally, contribute to > THOSE WHO SOUGHT appropriate for this clause. This is disharmonious relations among TO PROMOTE GROUP where section 13 truly fails to make various racial and cultural and RIGHTS AND ENDORSED a distinction between real hate religious groups, as a result eroding STATE-CENSORSHIP, speech and what I often term as the tolerance and open-mindedness AND THOSE WHO ‘hurt speech’, or speech that is simply that must flourish in a multicultural SOUGHT TO DEFEND offensive. -
Tracking Climate Models
TRACKING CLIMATE MODELS CLAIRE MONTELEONI*, GAVIN SCHMIDT**, AND SHAILESH SAROHA*** Abstract. Climate models are complex mathematical models designed by meteorologists, geo- physicists, and climate scientists to simulate and predict climate. Given temperature predictions from the top 20 climate models worldwide, and over 100 years of historical temperature data, we track the changing sequence of which model currently predicts best. We use an algorithm due to Monteleoni and Jaakkola that models the sequence of observations using a hierarchical learner, based on a set of generalized Hidden Markov Models (HMM), where the identity of the current best climate model is the hidden variable. The transition probabilities between climate models are learned online, simultaneous to tracking the temperature predictions. On historical data, our online learning algorithm's average prediction loss nearly matches that of the best performing climate model in hindsight. Moreover its performance surpasses that of the average model predic- tion, which was the current state-of-the-art in climate science, the median prediction, and least squares linear regression. We also experimented on climate model predictions through the year 2098. Simulating labels with the predictions of any one climate model, we found significantly im- proved performance using our online learning algorithm with respect to the other climate models, and techniques. 1. Introduction The threat of climate change is one of the greatest challenges currently facing society. With the increased threats of global warming, and the increasing severity of storms and natural disasters, improving our understanding of the climate system has become an international priority. This system is characterized by complex and structured phenomena that are imperfectly observed and even more imperfectly simulated. -
Volume 3: Process Issues Raised by Petitioners
EPA’s Response to the Petitions to Reconsider the Endangerment and Cause or Contribute Findings for Greenhouse Gases under Section 202(a) of the Clean Air Act Volume 3: Process Issues Raised by Petitioners U.S. Environmental Protection Agency Office of Atmospheric Programs Climate Change Division Washington, D.C. 1 TABLE OF CONTENTS Page 3.0 Process Issues Raised by Petitioners............................................................................................5 3.1 Approaches and Processes Used to Develop the Scientific Support for the Findings............................................................................................................................5 3.1.1 Overview..............................................................................................................5 3.1.2 Issues Regarding Consideration of the CRU E-mails..........................................6 3.1.3 Assessment of Issues Raised in Public Comments and Re-Raised in Petitions for Reconsideration...............................................................................7 3.1.4 Summary............................................................................................................19 3.2 Response to Claims That the Assessments by the USGCRP and NRC Are Not Separate and Independent Assessments.........................................................................20 3.2.1 Overview............................................................................................................20 3.2.2 EPA’s Response to Petitioners’ -
Statement of Undisputed Facts
SUPERIOR COURT OF THE DISTRICT OF COLUMBIA CIVIL DIVISION ) MICHAEL E. MANN, PH.D., ) ) Plaintiff, ) ) Case No. 2012 CA 008263 B v. ) Judge Alfred S. Irving, Jr. ) NATIONAL REVIEW, INC., et al., ) ) Defendants. ) ) STATEMENT OF UNDISPUTED MATERIAL FACTS IN SUPPORT OF DEFENDANT STEYN’S MOTION FOR SUMMARY JUDGMENT Defendant Mark Steyn submits the following Statement of Undisputed Material Facts in support of his Motion for Summary Judgment. Mark Steyn’s July 15, 2012 Blog Post 1. On July 15, 2012, Mark Steyn posted a blog titled “Football and Hockey” on National Review’s online blog “The Corner” (“the Steyn Post”) to National Review Online. See Mark Steyn, Football and Hockey, National Review Online, July 15, 2012, https://www.nationalreview.com/corner/football-and-hockey-mark-steyn/. 2. The Steyn Post states, in full: In the wake of Louis Freeh’s report on Penn State’s complicity in serial rape, Rand Simberg writes of Unhappy Valley’s other scandal: I’m referring to another cover up and whitewash that occurred [at Penn State] two years ago, before we learned how rotten and corrupt the culture at the university was. But now that we know how bad it was, perhaps it’s time that we revisit the Michael Mann affair, particularly given how much we’ve also learned about his and others’ hockey-stick deceptions since. Mann could be said to be the Jerry Sandusky of climate science, except that instead of molesting children, he has molested and tortured data in the service of politicized science that could have dire economic consequences for the nation and planet. -
Open PDF File, 8.71 MB, for February 01, 2017 Appendix In
Case 4:16-cv-00469-K Document 175 Filed 02/01/17 Page 1 of 10 PageID 5923 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS FORT WORTH DIVISION EXXON MOBIL CORPORATION, § § Plaintiff, § v. § No. 4:16-CV-469-K § ERIC TRADD SCHNEIDERMAN, § Attorney General of New York, in his § official capacity, and MAURA TRACY § HEALEY, Attorney General of § Massachusetts, in her official capacity, § § Defendants. § APPENDIX IN SUPPORT OF EXXON MOBIL CORPORATION’S BRIEF IN SUPPORT OF THIS COURT’S PERSONAL JURISDICTION OVER THE DEFENDANTS Exhibit Description Page(s) N/A Declaration of Justin Anderson (Feb. 1, 2017) v – ix A Transcript of the AGs United for Clean Power App. 1 –App. 21 Press Conference, held on March 29, 2016, which was prepared by counsel based on a video recording of the event. The video recording is available at http://www.ag.ny.gov/press- release/ag-schneiderman-former-vice-president- al-gore-and-coalition-attorneys-general-across B E-mail from Wendy Morgan, Chief of Public App. 22 – App. 32 Protection, Office of the Vermont Attorney General to Michael Meade, Director, Intergovernmental Affairs Bureau, Office of the New York Attorney General (Mar. 18, 2016, 6:06 PM) C Union of Concerned Scientists, Peter Frumhoff, App. 33 – App. 37 http://www.ucsusa.org/about/staff/staff/peter- frumhoff.html#.WI-OaVMrLcs (last visited Jan. 20, 2017, 2:05 PM) Case 4:16-cv-00469-K Document 175 Filed 02/01/17 Page 2 of 10 PageID 5924 Exhibit Description Page(s) D Union of Concerned Scientists, Smoke, Mirrors & App. -
Ilya Shapiro (D.C. Bar #489100) Counsel of Record Trevor Burrus (D.C
Nos. 14-CV-101 / 14-CV-126 IN THE DISTRICT OF COLUMBIA COURT OF APPEALS COMPETITIVE ENTERPRISE INSTITUTE, ET AL., Defendants-Appellants, and NATIONAL REVIEW, INC., Defendant-Appellant, v. MICHAEL E. MANN, PH.D, Plaintiff-Appellee. On Appeal from the Superior Court of the District of Columbia Civil Division, No. 2012 CA 008263 B BRIEF AMICUS CURIAE OF THE CATO INSTITUTE SUPPORTING PETITION FOR REHEARING Ilya Shapiro (D.C. Bar #489100) Counsel of Record Trevor Burrus (D.C. Bar#1048911) CATO INSTITUTE 1000 Mass. Ave., N.W. Washington, D.C. 20001 Tel: (202) 842-0200 Fax: (202) 842-3490 [email protected] Counsel for Amicus Curiae CORPORATE DISCLOSURE STATEMENT The Cato Institute states that it has no parent companies, subsidiaries, or affiliates, and that it does not issue shares to the public. Dated: January 3, 2019 s/ Ilya Shapiro Ilya Shapiro i TABLE OF CONTENTS CORPORATE DISCLOSURE STATEMENT ..................................... i TABLE OF AUTHORITIES ............................................................... iii INTEREST OF AMICUS CURIAE ....................................................... 1 ARGUMENT ........................................................................................ 2 I. DISAGREEMENT WITH OFFICIAL BODIES IS NOT EVIDENCE OF BAD FAITH ................................ 2 II. CALLS FOR INVESTIGATION, COMMONPLACE PEJORATIVE TERMS, AND ANALOGIES TO “NOTORIOUS” PERSONS CANNOT BE ACTIONABLE FOR LIBEL ........................................... 6 CONCLUSION .................................................................................. -
A Rational Discussion of Climate Change: the Science, the Evidence, the Response
A RATIONAL DISCUSSION OF CLIMATE CHANGE: THE SCIENCE, THE EVIDENCE, THE RESPONSE HEARING BEFORE THE SUBCOMMITTEE ON ENERGY AND ENVIRONMENT COMMITTEE ON SCIENCE AND TECHNOLOGY HOUSE OF REPRESENTATIVES ONE HUNDRED ELEVENTH CONGRESS SECOND SESSION NOVEMBER 17, 2010 Serial No. 111–114 Printed for the use of the Committee on Science and Technology ( Available via the World Wide Web: http://www.science.house.gov U.S. GOVERNMENT PRINTING OFFICE 62–618PDF WASHINGTON : 2010 For sale by the Superintendent of Documents, U.S. Government Printing Office Internet: bookstore.gpo.gov Phone: toll free (866) 512–1800; DC area (202) 512–1800 Fax: (202) 512–2104 Mail: Stop IDCC, Washington, DC 20402–0001 COMMITTEE ON SCIENCE AND TECHNOLOGY HON. BART GORDON, Tennessee, Chair JERRY F. COSTELLO, Illinois RALPH M. HALL, Texas EDDIE BERNICE JOHNSON, Texas F. JAMES SENSENBRENNER JR., LYNN C. WOOLSEY, California Wisconsin DAVID WU, Oregon LAMAR S. SMITH, Texas BRIAN BAIRD, Washington DANA ROHRABACHER, California BRAD MILLER, North Carolina ROSCOE G. BARTLETT, Maryland DANIEL LIPINSKI, Illinois VERNON J. EHLERS, Michigan GABRIELLE GIFFORDS, Arizona FRANK D. LUCAS, Oklahoma DONNA F. EDWARDS, Maryland JUDY BIGGERT, Illinois MARCIA L. FUDGE, Ohio W. TODD AKIN, Missouri BEN R. LUJA´ N, New Mexico RANDY NEUGEBAUER, Texas PAUL D. TONKO, New York BOB INGLIS, South Carolina STEVEN R. ROTHMAN, New Jersey MICHAEL T. MCCAUL, Texas JIM MATHESON, Utah MARIO DIAZ-BALART, Florida LINCOLN DAVIS, Tennessee BRIAN P. BILBRAY, California BEN CHANDLER, Kentucky ADRIAN SMITH, Nebraska RUSS CARNAHAN, Missouri PAUL C. BROUN, Georgia BARON P. HILL, Indiana PETE OLSON, Texas HARRY E. MITCHELL, Arizona CHARLES A. WILSON, Ohio KATHLEEN DAHLKEMPER, Pennsylvania ALAN GRAYSON, Florida SUZANNE M. -
Oversensitive How the Ipcc Hid the Good News on Global Warming
OVERSENSITIVE HOW THE IPCC HID THE GOOD NEWS ON GLOBAL WARMING Nicholas Lewis and Marcel Crok Foreword by Professor Judith Curry The Global Warming Policy Foundation GWPF Report 12 GWPF REPORTS Views expressed in the publications of the Global Warming Policy Foundation are those of the authors, not those of the GWPF, its Trustees, its Academic Advisory Council members or its Directors. THE GLOBAL WARMING POLICY FOUNDATION Director Dr Benny Peiser Assistant Director Philipp Mueller BOARD OF TRUSTEES Lord Lawson (Chairman) Baroness Nicholson Lord Donoughue Lord Turnbull Lord Fellowes Sir James Spooner Rt Rev Peter Forster Bishop of Chester Sir Martin Jacomb ACADEMIC ADVISORY COUNCIL Professor David Henderson (Chairman) Professor Richard Lindzen Adrian Berry Professor Ross McKitrick Sir Samuel Brittan Professor Robert Mendelsohn Sir Ian Byatt Professor Sir Alan Peacock Professor Robert Carter Professor Ian Plimer Professor Vincent Courtillot Professor Paul Reiter Professor Freeman Dyson Dr Matt Ridley Christian Gerondeau Sir Alan Rudge Dr Indur Goklany Professor Nir Shaviv Professor William Happer Professor Philip Stott Professor Terence Kealey Professor Henrik Svensmark Professor Anthony Kelly Professor Richard Tol Professor Deepak Lal Dr David Whitehouse OVERSENSITIVE How the IPCC hid the good news on global warming Nicholas Lewis and Marcel Crok Foreword by Professor Judith Curry ISBN 978-0-9573880-7-9 c Copyright 2014 The Global Warming Policy Foundation Contents Contents 1 Foreword 3 About the authors 5 Executive summary 7 Introduction