Paul Chesser, Heartland Institute Correspondent

The findings from Penn State University’s investigation into Climategate scientist Michael Mann were due this week, and today the university announced today that one allegation warranted further scrutiny:

In looking at four possible allegations of research misconduct, the committee determined that further investigation is warranted for one of those allegations. The recommended investigation will focus on determining if Mann “engaged in, directly or indirectly, any actions that seriously deviated from accepted practices within the academic community for proposing, conducting or reporting research or other scholarly activities.” A full report ( concerning the allegations and the findings of the inquiry committee has been submitted.

In the investigatory phase, as in the inquiry phase, the committee will not address the science of global climate change, a matter more appropriately left to the profession. The committee is charged with looking at the ethical behavior of the scientist and determining whether he violated professional standards in the course of his work.

Meanwhile, lawyers for the university have informed climate skeptic Ronald Armstrong (and probably others), who requested Mann’s emails via a Freedom of Information Act request and under Pennsylvania’s Right to Know Law, that Penn State is not subject to either transparency law because it is not an “agency:”

Consequently, the information you requested will not be disclosed since it is confidential and not made available to the public.

Legal weasel words, of course. In a high-profile misconduct case Penn State could certainly choose to release the records, but much like the Climategate conspirators, they can’t afford to let the public see. So they hide behind lawyers who are willing to do their dirty work for them — in this case, Katherine Allen at McQuaide Blasko in Central Pennsylvania.

What’s the matter, doesn’t PSU have some attorney hack on staff who could have cranked out this deflection, rather than paying outside counsel hundreds of dollars an hour to be their bad guy for them?

I imagine just about everyone at one time or another has been added to a mailing list of an organization or candidate who doesn’t align with their worldview. An amusing example of this hit the emailbox of the Commonwealth Foundation, via an message signed by environmentalist Teresa Heinz Kerry (renowned wife of two Johns), who asked recipients to provide their nominees for this year’s Heinz Awards (no, they’re not called Heinies for short):

For most of the program’s history, we have honored five awardees, one each in fields of great importance to John (Heinz), including arts and the humanities, the environment, public policy, technology, and the human condition. Last year, we made an exception to this approach, honoring 10 individuals for their work on the environment, one of John’s highest priorities. This year we want to take this focus even further.

The world is at a crucial moment, brought there by the scale of the human enterprise on Earth. Scientists refer to the cumulative effects of human activities and natural processes on the Earth as global change. The risks of failing to address global changeare too great to accept. Therefore, we seek nominations of people who are addressing global change in unique, innovative and powerful ways.

Note that environoiacs are now moving from “global warming” and “climate change” to “global change.” Let’s prevent humans from doing anything to affect the planet!

You might also recall that Commonwealth Foundation is the Pennsylvania think tank that called for an independent, outside investigation of Climategate‘s hockey stick scientist Michael Mann. I am sure they can come up with some innovative candidates for the awards. If I had the opportunity I would choose the Climategate whistleblower, who certainly instigated “global change” on the climate issue.

Rep. Earl Pomeroy, North Dakota Democrat, writes today that he’s had enough of EPA’s efforts to regulate CO2:

It is time to end the irresponsible game of chicken being played with the future of energy regulation in this country. Those in favor of sweeping new regulations on our economy to address the issue of global warming are demanding that Congress quickly pass a “cap-and-trade” bill on greenhouse gas emissions or face a battery of new mandates to be developed and imposed by the Environmental Protection Agency. This type of legislative extortion is not an appropriate strategy to pass any bill in Congress — especially a complicated and far-reaching cap-and-trade proposal that could have a dire impact on North Dakota.

Agencies like the EPA would normally be prohibited from jumping out in front of congressional action under the Constitution of the United States. However, the Supreme Court has ruled that the EPA can use a statute passed 20 years ago — the Clean Air Act — even though that law was written to address acid rain, not greenhouse gas emissions. Throughout this Congress, the cap-and-trade crowd has worked cheek to jowl with the EPA to try and pass this bill. Whenever a critical point in the legislative process has been reached, more rumblings would burst forth from the EPA regarding potential administrative action, just to make certain all were aware of what was in store if proposed legislation stalled out.

Looks like Alaska Sen. Lisa Murkowski may get more Democratic support for her motion to halt EPA than originally thought.

Hat tip: My Heartland Institute colleague Peter Fotos.

At his BBC blog Andrew Neil lays out the itemized fraud from the 2007 UN IPCC report that has been rolling out in recent days, previously reported by the BBC and other formerly mainstream media as “sound” and “consensus” science. So many “Gates,” and so many discredited reporters:

But the flood gates really opened after the IPCC had to withdraw its claim that the Himalayan glaciers would likely all have melted by 2035, maybe even sooner.

This turned out to have no basis in scientific fact, even though everything the IPCC produces is meant to be rigorously peer-reviewed, but simply an error recycled by the [World Wildlife Fund], which the IPCC swallowed whole….

Then at the weekend another howler was exposed. The IPCC 2007 report claimed that global warming was leading to an increase in extreme weather, such as hurricanes and floods. Like its claims about the glaciers, this was also based on an unpublished report which had not been subject to scientific scrutiny — indeed several experts warned the IPCC not to rely on it.

Now after Climate-gate, Glacier-gate and Hurricane-gate — how many “gates” can one report contain? — comes Amazon-gate. The IPCC claimed that up to 40 percent of the Amazonian forests were risk from global warming and would likely be replaced by “tropical savannas” if temperatures continued to rise.

This claim is backed up by a scientific-looking reference but on closer investigation turns out to be yet another non-peer reviewed piece of work from the WWF. Indeed the two authors are not even scientists or specialists on the Amazon: one is an Australian policy analyst, the other a freelance journalist for the Guardian and a green activist.

Yep, this is the “scientific consensus” that Al Gore based his post-VP life upon; the imagined groundswell that so many politicians used to justify government growth; the nonexistent evidence that journalists cited to justify their alarmism activism. It’s the two words that every global warmist (whether lying or deceived themselves) threw in the face of skeptics in an attempt to intimidate. Didn’t work!

No wonder why hardly any of them wanted to debate and those who did got slaughtered. We tried to explain that the “consensus” was an illusion. You — yes, I’m talking about you, Society of Environmental Journalists — would have none of it.

Now you’re stuck in the shoes of the environmental equivalent of Jayson Blair as your newspapers and television stations fall apart, and while what’s left of your audience doesn’t care about the issue you hold so precious. But it’s your good fortune that you still qualify for the do-nothing flack positions that are plentiful in both government and nonprofit arms of the environoia industry.

As I mentioned yesterday, Scott Brown’s election is making the Democrats do all kinds of things that they wouldn’t have considered even last week. Bloomberg reports that cap-and-trade is dead (citing California Sen. Dianne Feinstein, for one) for this year, so the Dems’ thinking is to try and move some of the alt-energy initiatives into a jobs bill:

Chief executives officers of Exelon Corp., Nike Inc., and 81 other companies [yesterday] urged Obama and lawmakers to enact climate legislation. In a letter, the group called for “strong policies and clear market signals that support the transition to a low-carbon economy and reward companies that innovate.”

The new Senate version of the jobs bill may include funding for a “cash for caulkers” program providing grants to make homes more energy efficient, said Lowell Ungar, policy director for the Washington-based Alliance to Save Energy.

“The money will run out from the recovery act and if there’s not further legislation to push these retrofits, there’s a real risk that the infrastructure we’re creating right now will wither,” Ungar said in an interview. “The people who are being trained right now to do these retrofits will no longer have jobs.”

Translation: “Rewarding companies that innovate” means giving them taxpayer dollars or else they’ll go out of business. Mr. Ungar could not have said it more plainly.

In early December I reported in this space that Penn State University Climategate scientist Michael Mann received $541,184 in stimulus funds, which the school claimed was creating 1.62 (presumably “green”) jobs. Today the National Center for Public Policy Research called for the return of the funds to the U.S. Treasury:

Professor Mann is currently under investigation by Penn State University because of activities related to a closed circle of climate scientists who appear to have been engaged in agenda-driven science. Emails and documents mysteriously released from the previously-prestigious Climate Research Unit at the University of East Anglia in the United Kingdom revealed discussions of manipulation and destruction of research data, as well as efforts to interfere with the peer review process to stifle opposing views. The motivation underlying these efforts appears to be a coordinated strategy to support the belief that mankind’s activities are causing global warming.

How about he returns all $6 million he’s received from the government over the years?

Whaddaya know — ever since Climategate and brutal cold (snap!) sawed in half the global warming illusion that the formerly mainstream media had sold as reality, all of a sudden there’s massive upheaval: dogs and cats living together; news networks hosting climate debates; CBS exposing taxpayer-funded boondoggle junkets to Copenhagen; and politicians (other than Oklahoma Sen. James Inhofe) boldly denouncing fraudulent research about the “benefits” of “solutions” to global warming. Just check out last Friday’s press release from Michigan State Rep. Tom McMillin:

McMillin made the call following a plan from the global-warming advocacy group the Center for Climate Strategies that likely overstated possible job growth and will cost Michigan taxpayers millions of dollars to follow a political agenda.

“To expend taxpayer money on such a biased group as CCS was just wrong and exemplifies how Governor Granholm has run this state into the ground – by putting political agendas ahead of truth and Michigan job creation,” said McMillin, R-Rochester Hills. “There will not be a net 129,000 jobs created. To follow the recommendations of this study may actually result in net job losses for Michigan.”

McMillin noted the long history of questionable action from the Center for Climate Strategies that can be found here.

“The report is intentionally false in order to promote CCS’s radical agenda, which always conveniently leave out costs to taxpayers and job providers,” McMillin said. “The results of this so-called study is as bogus as the far left group the governor chose to stage this charade – that group, CCS, is closely aligned with scientists who hide data, delete emails and contrive to bully peer review methods in order to promote their radical, non-scientific, highly questionable agenda. In effect, Michigan now has its own version of Climategate. Let’s see if, in Michigan, they’ll come clean or hide.”

McMillin is right, of course — CCS has proven to engage in the same fudge-factoring and half-baked analysis as the Climategate cooks. The failure of Copenhagen and the poor election-year forecast for national cap-and-trade passage may mean the Greens return to the state-level, pressure-up strategy. It would help if more state lawmakers like McMillin engage to expose how this scheming has worked around the country.

Liberal Washington Post columnist Eugene Robinson today writes about former Alaska Gov. Sarah Palin’s policy flip-flop on global warming and the need to reduce greenhouse gas emissions. He notes her current recommendation — expressed in her own Post op-ed last week — that President Obama boycott Copenhagen, citing the Climategate scandal as reason enough to skip the climate conference. But while she was governor she held a slightly different view, as Robinson explained:

Back then, Palin was the governor of a state where “coastal erosion, thawing permafrost, retreating sea ice, record forest fires, and other changes are affecting, and will continue to affect, the lifestyles and livelihoods of Alaskans,” as she wrote (in a 2007 administrative order creating the state’s Climate Change Sub-Cabinet). Faced with that reality, she sensibly formed the high-level working group to chart a course of action.

“Climate change is not just an environmental issue,” wrote Palin. “It is also a social, cultural, and economic issue important to all Alaskans….”

In her administrative order, Palin instructed the sub-Cabinet group to develop recommendations on “the opportunities to reduce greenhouse gas emissions from Alaska sources, including the expanded use of alternative fuels, energy conservation, energy efficiency, renewable energy, land use management, and transportation planning.” She also instructed the group to look into “carbon-trading markets.”

Robinson is right about Palin’s seeming switch, but he leaves out context and cuts no slack on how the Climategate scandal has been a game-changer. For context, the idea of setting up a blue-ribbon panel to study climate issues likely came from Tom Chapple, a greenie envirocrat in her administration who left not long after she created the Subcabinet. The responsibility for managing the project fell to his successor, Larry Hartig, who has had to juggle the interests of environmentalists and the oil industry up there.

As director of Climate Strategies Watch I studied how the Subcabinet was put together, and specifically how and why they hired the global warming alarmist Center for Climate Strategies as technical advisers and consultants to run all the Subcabinet’s activities. I had written a long narrative — linking public documents and emails — explaining the developments and the less-than-transparent process, for the CSWatch Web site last year. However, that project has been folded into the activities of the Heartland Institute — my current employer — as CSWatch (we believe the site was victimized by a hacker) was only planned to last a year (it lasted about 18 months).

For those who want to plow through the story, I am reproducing the original CSWatch narrative below with links (some of which may not work) to documents embedded. You’ll see at the end that I tend to believe that then-Gov. Palin was doing the politically correct thing at the time by signing the administrative order, but left the major decisions to Chapple, Hartig, and the Subcabinet itself. I think the views she’s expressed now only serve to confirm that theory, but I could be wrong.

The story, posted late August/early September last year:

I hate to be the Baby Ruth in the punchbowl at the celebration over John McCain’s choice for a running mate, but since it’s my job to follow these things, I’ve got to highlight one area where Alaska Gov. Sarah Palin has aligned with the GOP candidate on an issue that makes many conservatives cringe: global warming.

Gov. Palin signed an administrative order last September that created the Alaska Climate Change Sub-Cabinet. Her order is perhaps not as strident on greenhouse gas emissions as some other governors, but she still buys into the argument that GHGs must be reduced.

Unfortunately her Department of Environmental Conservation hired the Center for Climate Strategies as their climate commission management team. I requested documents pertaining to the CCS hire from DEC and was sent some records, but others were identified as “deliberative” and therefore withheld from me, which officials said was allowed under state law. I still have my doubts, because other records sent to me appeared to fall into that category but were sent anyway. Regardless, the withholding of several documents with regard to an issue that does not fall under “highly-sensitive” or “security-related” undermines the governor’s reputation for greater government transparency.

As for CCS, it all began last August when DEC’s Tom Chapple (now working in the private sector) reached out to CCS’s executive director (PDF) Tom Peterson, “to discuss the opportunities and the possibility of CCS interest in helping Alaska.” In fact, it appears that Chapple was the driving force behind the state’s hiring of the Pennsylvania-based advocacy group, to manage Alaska’s development of their greenhouse gas emissions policy.

Chapple learned some about CCS from the Washington Dept. of Ecology’s Janice Adair — as his handwritten notes show (PDF) – which include a discussion about how to work out a sole source contract for CCS, and that “some states have paid some, some have paid nothing” (Washington state paid CCS $200,000). Other notes (PDF) from a conference call, presumably that included Ken Colburn of CCS, show that the typical CCS cookie-cutter process was explained, and that as elsewhere CCS would handle everything, once hired: Meetings, scheduling, technical information, Web site, preparation of pre-meeting documents, meeting minutes, etc. Oh, and we can’t forget CCS’s own grant-funding service.

In the meantime Gov. Palin signed her administrative order on Sept. 14, 2007.

A month later negotiations between Chapple of DEC and CCS representatives intensified, as they began to discuss what the typical CCS “process memo” would contain. A draft (PDF) of the agreement said, “Although additional research may be needed to help the public and policymakers better understand Alaska’s changing climate and how to anticipate and respond to its effects, the time for climate debate is over; it is now time for climate action.” Also, the document states on page 13 clearly what is off-limits: “Participants will not debate the science of climate change….” Private funders are identified as the Rockefeller Brothers Fund, the Marisla Foundation, the Energy Foundation, and others. The opening negotiating cost (PDF, see second page) for the process was set at $480,000.

As if total control over the process wasn’t enough for CCS either, though, there’s this: CCS recommended who would be appointed (PDF) to the climate commission. Read the list and note how strongly the representation is that they want from environmentalism and government. Meanwhile private business gets short shrift, as do climate scientists, taxpayer activists, property rights activists, and other protectors of individual rights.

On November 6, 2007 the Climate Change Sub-Cabinet held its third meeting, in which CCS was allowed to make the case (PDF) for being hired as its management consultant. Ken Colburn, in his PowerPoint presentation (PDF), promoted CCS’s nonsensical economic analysis from Arizona (285,000 new jobs and $5.5 billion in net savings to the state!) and New Mexico ($2.1 billion in savings to the state). As I’ve reported in the past, those claims by CCS have been thoroughly debunked.

But unsurprisingly the Fairbanks Daily News-Miner swallowed the Colburn claims (PDF), unchallenged. The newspaper reported that Larry Hartig, Palin’s commissioner of environmental conservation, expressed interest in CCS: “If it’s not them, we should do something similar to that.” Also, Colburn explained that CCS’s services typically cost about $500,000, “but states generally pay only about 10 percent of the cost,” the News-Miner reported. “CCS covers the rest with funding from various foundations” – that is, Rockefeller Brothers Fund.

Later in November DEC’s Chapple sent out a plea (PDF) – and forwarded to Colburn — to various state departments asking for help “in shaping up the scope of work for the proposed contract with (CCS).” The message was met with enthusiasm from Colburn: “This is a remarkable email, carrying precisely the right content and precisely the right tone.” Translation: “I won’t stop kissing your rump until you hire us.” More negotiations and contract details were addressed (PDF) in a conference call Nov. 29.

In early December 2007 DEC’s Hartig, with Chapple and Colburn in the loop, considered engaging the National Commission on Energy Policy (PDF) to help on climate adaptation strategies. NCEP is funded by the William and Flora Hewlett Foundation, which is also paying the total cost for Colorado Gov. Bill Ritter’s climate and energy policy advisers.

As the February meeting approached in which CCS would be formally approved as manager by the Sub-Cabinet, questions were raised (PDF) about why the cost for Alaska’s portion of CCS’s services rose from $49,000 to $180,000. No other documents were provided to me that addressed this situation and its resolution, but the final contract (PDF) shows that the state is indeed contributing the $180,000. However, the full budget (see pages 36-37 of the contract) for the process is double what any of these have cost in other states: $972,196. This could be attributed to the distance of the state from the lower 48, but it’s hard to believe that could account for that great an increase in the average CCS budget.

As for the holes in my story, Alaska DEC’s Gary Mendivil sent a letter with the documents that were provided, but also explained that some records were withheld (PDF) from me. My original request was received by DEC on Dec. 27, 2007, and according to an email from Mendivil on Feb. 1, 2008, he “was told that the stack of records that was sent to the (State of Alaska) attorney for review was four inches thick….” The CD containing records was mailed to me on Feb. 20 (according to DEC’s response letter), and the documents therein did not even measure a half-inch, much less anything close to four inches. Even with the documents they listed as withheld (PDF), it would be hard to believe they could measure four inches.

When asked why any records needed to be withheld in the first place, Mendivil provided a minimal explanation: “We’ve claimed a privilege under AS 40.25.120(a)(4) (“records required to be kept confidential by a federal law or regulation or by state law”).” Not satisfied, I asked which federal or state laws DEC was citing to justify keeping a lid on certain records. His answer:

“The Alaska Supreme Court has adopted the common law recognition of a deliberative process privilege. Because Alaska’s statutory definition of “state law” encompasses common law as well as positive law, the Alaska Supreme Court has held that the deliberative process privilege is one of the judicially recognized state law exceptions to public access under the public records act. This is the privilege that the State has claimed on certain documents identified on the privilege log that was most recently given to you. In other words, the documents withheld as “deliberative process” show the mental processes of government decision makers, and are thereby protected from disclosure.”

If you review the list of withheld records, and compare it to the documents DEC did provide, you might wonder what criteria they used to determine “deliberative” vs. non-deliberative. It seems clear that many of the records they did supply could have also fallen under “deliberative” status as well.

I would say it’s pretty odd that the State of Alaska could withhold documents from the public about a commission that will go a long way towards influencing its policies on energy, environment, property rights, taxes, the state budget, land use, education, and just about every other public policy area. The DEC has not given a clear explanation why, nor clearly cited a law that allows them to make a “deliberation” exception. And even if they could, what possible reason would they have to do so when there are no national or state security issues at stake, or any other sensitive issues?

DEC’s decision, as has been the case in other states where CCS is working, undermines the claim in their contracts and process memos that their “process is fully transparent.” There is no clear indication that Gov. Palin is behind these DEC decisions – on the face it looks like all she has done is sign the administrative order creating the Sub-Cabinet, then depended on her environmental agency leaders (Chapple and Hartig) to make the rest of the decisions. But the way this has played out sure does foul up her reputation as a reformer in pursuit of greater government transparency.

An article by environmentalist journalist Fred Pearce about the “public relations disaster” that is Climategate is getting a lot of attention for Yale Environment 360, as it should. But the Web site, a clearinghouse for eco-Left points of view, crossed into bizarro territory last week with an “analysis” piece co-written by Michael Northrup and David Sassoon that touts “ambitious actions” by U.S. states to push “toward climate goals.” And the centerpiece of their “expert” analysis about the “great” things states are doing on climate policy? The Center for Climate Strategies:

Twenty-four policies and measures account for 85 percent of the states’ emissions reduction potential, touching every sector of the economy. The majority of the policies save money or expand the economy; the remainder either cost money or require investment, but overall they create new economic opportunity.

“Every macroeconomic analysis of state climate action that we have done has shown an expansionary effect,” Tom Peterson, the CEO of the Center for Climate Strategies (CCS), told us. “It should not be a big leap to figure out how to nationalize it.”

Peterson’s group has worked with governors and elected officials on both sides of the aisle in dozens of states and is completing an economic analysis of state climate action for presentation at a series of events at the Copenhagen meetings.

The laughable, undisclosed thing about this article is that Northrup, one of the co-authors and program director for sustainable development at the Rockefeller Brothers Fund, probably has a conversation with Peterson every day. Why? Because RBF funds a substantial majority of their work, as I explained earlier this year:

While (CCS’s) Peterson and (Ken) Colburn have been far from transparent about their origins (they also hide how much they get paid), the work CCS does has also been thoroughly discredited. They forbade any debate or discussion about global warming science. As they wooed states out of as much money as they could (not much, it turns out) to reduce the burden on their subsidizers — mainly the Rockefeller Brothers Fund — they peddled incompetent economics (Green jobs! Cost savings!) in every state where they worked. They could not produce analysis in any state that showed the effect their policy recommendations would have upon climate — ostensibly the purpose for their state commissions. And besides their disregard for recent observed climatological trends, they continue to promote obsolete technologies like biofuels, which recent studies show have increased greenhouse gas emissions rather than reduced them.

So when I asked in the comments section (scroll, baby, scroll) of the Yale 360 article why the authors didn’t disclose the RBF-CCS funding relationship, the answer from co-author Sassoon was that they were disclosed — in RBF’s annual reports! That Leftist version of “pay no attention to that man behind the curtain” transparency was then followed by, “So what!” In other words, “you idiot readers ought to be well-acquainted with funding specifics of our multi-million-dollar foundation.”

Then, in keeping with the global warming alarmist playbook, they suggested I disclose who my funders are. So in response I asked if they could share some of that Standard Oil/Exxon slathered Rockefeller dough they enjoy with little ‘ol me. That comment hasn’t been posted at Yale 360 as of this writing.

Update 4:45 p.m.: I forgot to mention that CCS is over in Copenhagen delivering advice about how to further wreck state economies by raising energy costs. Surprise, surprise — RBF’s Michael Northrup is on their honored guest list. Payback is not a bitch at all!

Update 5:24 p.m.: Just noticed that the Yale Environment 360 editors posted the following at the end of the article sometime today:

The original posting of this article should have noted that the Center for Climate Strategies — whose CEO, Tom Peterson, is quoted in the story — has received funding from the Rockefeller Brothers Fund. One of the article’s co-authors, Michael Northrop, is program director for sustainable development at the Rockefeller Brothers Fund.

Likely a result of an email I sent them last night. I would have put it at the beginning of the article, but at least it’s there.

The hypocritical, inefficient anti-Greens at the United Nations, who will be responsible for the deaths of millions if they don’t change their behavior, have now far surpassed the simple wastefulness of selling out Copenhagen’s fuel-slurping limos instead of riding mass transit. As the National Center for Public Policy Research reported today, the U.N. has denied entrance to two-thirds of the NGO representatives they credentialed for the climate summit:

The restriction was announced today outside the Copenhagen conference center after several thousand accredited NGO conference delegates, including three from the National Center for Public Policy Research, waited outside for eight hours or longer in 32-degree F temperatures for admission.

NGOs apparently are being banned because the United Nations accredited 45,000 people for a building with a capacity of 15,000, although the stated reason was “security concerns.” The “security concerns” may be related to the fact that, after waiting several hours in the cold, delegations began to chant, “Let us in! Let us in!”

“To be an “accredited” or “admitted” NGO to a COP conference, NGOs must apply months in advance, and typically only make travel plans to attend after receiving complete credentials from the United Nations,” said Amy Ridenour, president of the National Center for Public Policy Research, an accredited COP-15 NGO organization that is as of now banned from the conference. “To give credentials to 45,000 people while choosing a building that holds 15,000 people is insane, though the United Nations, to be fair, has never been known for competence.”

As Ridenour noted, about 30,000 humans-worth of greenhouse gases were blasted into the atmosphere for no good reason. Remember, these are the people who want you to trust them with tracking carbon emissions and carbon offset coupons, not to mention enforcement of such.