The SEC climate change proposal is not grounded in science, Author’s Cut

By Andy May

This is the full uncut version of the op-ed I wrote for the Washington Examiner, here.

On March 22, 2022, the Securities and Exchange Commission (SEC) released a new rule for public comment (File Number S7-10-22) that would require public companies to report the climate-related impact of their businesses. Since it has been well established in multiple IPCC reports that the human impact on climate has never been observed, only modeled, this seems unnecessary. The climate models, used by the IPCC and NOAA to “compute” the human impact on climate have already been invalidated by Dr. Ross McKitrick and Dr. John Christy in their well-known Earth and Space Science peer-reviewed paper. McKitrick and Christy’s previous 2018 paper is cited numerous times in the latest IPCC report (AR6), and the report acknowledges that their paper is correct on page 3-24, where they also admit that one likely reason is the models are overestimating the sensitivity of the climate to CO2. They also admit on the same page that the models are overestimating warming relative to observations in both the atmosphere and the oceans. Page 10 of the SEC proposed rule states:

“In particular, the impact of climate-related risks on both individual businesses and the financial system as a whole are well documented.10

SEC: File Number S7-10-22

Footnote 10: “In 2020 alone, a record 22 separate climate-related disasters with at least $1 billion in damages struck across the United States, surpassing the previous annual highs of 16 such events set in 2011 and 2017. See NOAA, National Center for Environmental Information, Billion Dollar Weather and Climate Disasters: Summary Stats (3rd Quarter release 2021), available at In 2021, the United States experienced 20 separate billion-dollar climate-related disasters. See NOAA, U.S. saw its 4th warmest year on record, fueled by a record-warm December (Jan. 10, 2022), available at”

SEC: File Number S7-10-22

While “climate-related” risks do exist, as they always have, it is well documented that they are decreasing with time, both in terms of frequency, financial impact, and severity. Figure 1 is a plot of the number of climate related disasters from 2000 through 2019 from EM-DAT.

Figure 1. The number of climate-related disasters from 2000 to 2019 from EM-DAT, data downloaded from

Figure 1 shows the global number of climate-related disasters have been decreasing for the past 20 years. The database goes further back in time, but reliable reporting of disasters did not start until 2000, according to Regina Below and Prof. D.Guha-Sapir of EM-DAT. The decrease is logical since summers and days are warming at a lower rate than winters and nights. The tropics are hardly warming at all while the North Polar region[1] is warming quite a lot. Thus, the climate is becoming milder as it warms, with fewer extremes and therefore, fewer severe storms.

Climate is usually defined as a change in average weather over a period of 30 years or more. The footnote above specifies “climate-related disasters” that have $1 billion in damages in 2020 and notes they surpass previous highs from nine years before and three years before. The value of one billion dollars is corrected for the consumer price index (CPI) but not corrected for population or GDP. All the cited years are within one climate period of 30 years; thus they are considering weather events, not climate. It is well established that weather damages, as a percentage of GDP, are declining over climate periods of time. Figure 2, from Professor Roger Pielke Jr. shows the recent trend in disasters as a percent of GDP. Further, climate related deaths are also declining, as shown in Figure 3.

Figure 2. Global weather losses as a percent of GDP. Source: Roger Pielke Jr.

Chart, line chart

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Figure 3. A comparison of climate related deaths to non-climate related deaths in the 20th century. Source: (Lomborg, 2020), link.


The SEC document claims that: “the impact of climate-related risks on both individual businesses and the financial system as a whole are well documented.” This does not seem to be the case. Recent research by Professor Roger Pielke Jr., Dr. Bjorn Lomborg, and data from the EM-DAT disaster database all show the impact of climate change, whether of natural or human origin, is declining.

The costs in the NOAA “Summary Stats” document are adjusted for the consumer price index, but they are not adjusted for population or GDP, and these are critical factors. The document they cite about the 4th warmest year on record, critically does not document why warming since the 20th century is a bad thing. There were many very cold and deadly years in the 20th century and cold kills many more people than heat. The coldest years in the U.S. were 1985, 1899, 1977, and 1983. In the U.K. 1963, 1947, 1940 and 1979 stand out. Our current climate is much nicer.

Particularly, when considering the horrible suffering of people in the Northern Hemisphere during the Little Ice Age, due to cold and drought, one should not assume that a warmer climate is worse than a colder one. The Little Ice Age is now considered the “preindustrial period,” which the IPCC normally defines as 1850-1900, although sometimes they define it as 1750 to 1900[2]. The end of the Little Ice Age is normally taken as 1850. It was far from an ideal climate and during its colder periods, glaciers advanced in the Alps and destroyed entire towns. It was a time of perpetual war, famines, and plagues. Horrible persecutions of Jews and “witches” were common.

Society was suffering from the cold and lack of food, and they needed to blame someone. They chose Jews and older unmarried women unfortunately. Over 50,000 witches were burned alive. Tens of thousands of Jews were massacred. Not because there was any proof, just because someone had to suffer for the bad climate. Some people, the masses mainly, seemed to need to blame someone or humanity’s sins for natural disasters. Behringer notes that in the Little Ice Age: “In a society with no concept of the accidental, there was a tendency to personalize misfortune.” We should not make the mistake of blaming humans or human “sins” for natural disasters. Clear proof is needed first that human actions are significantly contributing to climate change. Such proof does not exist, the claim comes from computer models that have now been falsified.

It seems the SEC is accepting the politically correct dogma that warmer is bad, without demanding evidence that it is. This is no way to make policy.

Download the bibliography here.

  1. Tropics = ~0.12°C/decade, versus ~0.25°C/decade for the Arctic according to the UAH lower troposphere data.

  2. (IPCC, 2001, p. 185).

Published by Andy May

Petrophysicist, details available here:

14 thoughts on “The SEC climate change proposal is not grounded in science, Author’s Cut

  1. Another good article. I posted a short version with attribution, and links to the original, on one of my blogs. Recommended your climate blog once again.

    I did have a problem with the “Behringer” paragraph in the conclusion connecting climate to anti- Semitism and witch hunts. I have not read the book but the paragraph didn’t pass my internal BS detector (I do have a BS degree!) because I’d never heard that in 25 years of climate science writing, EXCEPT from Behringer. So I deleted that paragraph — it didn’t support the main point, IMHO. The imaginary coming climate crisis — always coming, never arrives — is blamed on burning fossil fuels — not on a specific group of people.

    I could imagine blaming ACTUAL bad climate, such as in the 1690s. on someone, but I don’t see what that has to do with today’s climate. I consider today’s climate to be the best climate for humans, animals and plants since the Holocene Climate Optimum, 5,000 to 9,000 years ago. We should be celebrating today’s climate! I know many people believe the FUTURE climate can only get worse, and will be a disaster, but that’s just a belief, — a belief that’s over 50 years old — not the ACTUAL climate.
    Richard Greene
    Bingham Farms, Michigan

    1. Try a wider perspective. In the little ice age they picked witches and Jews. They used to sacrifice virgins or first-borns. Now they are trying to destroy Western Civilization and society by blaming climate change on those predominately white christian countries. History is always blaming one group or another as Andy mentions.

    2. There are a great many parallels to past times and a people blaming others for their ills, real and imagined on those others. I suggest you read this which is a very good article on enumerating the parallels. The climate change hysteria well matches past times in my opinion.
      The persecutions have always had motives of politics and power behind them and jealously. Jews have always been favorite targets of persecutions. If there had been Jews in Salem, no doubt, they would have been the first targeted.
      Human nature really hasn’t, it seems, changed very much after all.
      The Specter of Systemic Racism.The Salem Witch Trials teach us much about modern mass hysteria.

    3. Thanks for reposting Richard. I think the very idea that humans are controlling the climate with our greenhouse gas emissions, is akin to the thought that witches and Jews controlled the climate during the Little Ice Age. As Behringer says in his book, we have this need to personalize natural misfortune for some odd reason. Before the Little Ice Age there was another cold and miserable period around 700 to 800 AD and the Archbishop of Lyon said this:
      “In these parts nearly everyone – nobles and common folk, town and country, young and old – believe that human beings can bring about hail and thunder…We have seen and heard how most people are gripped by such nonsense, indeed possessed by such stupidity…”

      Read either Behringer or my post:
      for more.

  2. Thanks for all the comments and links.
    I’ll do further reading, and that may change my opinion.
    My thinking was: There have always been scapegoats, in good climates and bad climates. Jews have been “popular” as scapegoats. I don’t see a correlation between scapegoats and the climate in past centuries or this century, to the extent that we even know the past climate. Climate reconstructions are low accuracy, and they are local, not global. Average lots of proxies together, as a “global proxy”, and the variations tend to smooth out.

    For the Little Ice Age, the period’s tarting and ending years depend on who you ask. And most decades in those centuries were not unusually cold.
    I just can’t consider climate changes as an important cause of blaming
    others for your problems, which seems to be a common human fault with no more than a weak link to the general climate.

    During a portion of the Little Ice Age, where we have real time temperature
    measurements from three weather stations in Central England, the average temperature remained in an 8 to 10 degrees C. range. Did people hate the Jews at 8 degrees C., and love them at 10 degrees C.? I doubt it. If Jews had converted to Christians, and the climate was cold, would they still be hated? I doubt it. Just my two cents.
    Richard Greene
    Bingham Farms, Michigan

    1. I would do more reading, especially Behringer’s excellent book. He is a historian and an expert on the LIA. According to my reading, the persecutions of witches and Jews were not continuous during what we now call the Little Ice Age (roughly 1300-1850) only when it was very cold for a long time. The coldest period in Europe was from around 1600 to 1720, that was the time of the worst persecutions. The cold was accompanied by drought. Flooding would occur when ice dams across rivers melted during the summer. See this year-by-year weather history from the U.K.

  3. I did whatever reading i could find that was free.
    I’m not buying the hating Jews due to the climate claim.
    I understand when the climate was unusually cold,
    as in the 1690s, Jews and other minorities might get blamed.
    But I see no evidence as the climate improved for the
    next 300+ tears, that discrimination stopped as a result
    of a better climate. I don’t see a long term positive correlation.

    I also wonder how much we know about the Little Ice Age
    centuries. The only real time temperature data were from
    three weather stations in Central England (CET).
    Their records begin in 1659, and they do show the
    1680 to 1700 decades as being unusually cold.
    Perhaps 1 to 1.5 degrees C. colder than usual in the 1690s.
    The CET temperature quickly returned to “normal”
    after 1700, and never again had such a cold decade.

    So assuming CET is representative of all of Europe, which is
    just a guess, there would be no climate reason for anti-semitism
    for the next 300+ years. Yet anti-semitism never stopped
    as the climate improved.

    My conclusion is that anti-semitism existed BEFORE
    the cold 1690s, and after 1700, with a small correlation
    to the average temperature.

    The fact that anti-semitism existed during cold weather
    does not mean cold weather caused anti-semitism.
    Discrimination probably worsened when the climate was bad,
    … but the climate didn’t cause discrimination in 1930’s and
    1940’s Germany, and in too many Muslim nations today.
    One book, by one author, won’t change my mind.

    My Motto:
    Everyone is entitled to my opinion!

    Richard Greene
    Bingham Farms, Michigan

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