CO2, EPA, Politics, and all that

In a stunning act of political kowtowing, the EPA caved to special interest groups and politics and declared CO2 a “dangerous pollutant”, even though it is part of the natural cycle of life. Now the gloves come off and the real fight begins during the 60 day public comment period. If you’ve never stood up to “consensus” before, now is the time for all good men to come to the aid of their country. See instructions below for submitting public comment. – Anthony

co2-dichotomy

Proposed Endangerment and Cause or Contribute Findings for Greenhouse Gases under the Clean Air Act

Background

On April 2, 2007, in Massachusetts v. EPA, 549 U.S. 497 (2007), the Supreme Court found that greenhouse gases are air pollutants covered by the Clean Air Act. The Court held that the Administrator must determine whether or not emissions of greenhouse gases from new motor vehicles cause or contribute to air pollution which may reasonably be anticipated to endanger public health or welfare, or whether the science is too uncertain to make a reasoned decision. In making these decisions, the Administrator is required to follow the language of section 202(a) of the Clean Air Act. The Supreme Court decision resulted from a petition for rulemaking under section 202(a) filed by more than a dozen environmental, renewable energy, and other organizations.

Action

You will need Adobe Acrobat Reader, available as a free download, to view some of the files on this page.  See EPA’s PDF page to learn more about PDF, and for a link to the free Acrobat Reader.

The Administrator signed a proposal with two distinct findings regarding greenhouse gases under section 202(a) of the Clean Air Act:

  • The Administrator is proposing to find that the current and projected concentrations of the mix of six key greenhouse gases—carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6)—in the atmosphere threaten the public health and welfare of current and future generations. This is referred to as the endangerment finding.
  • The Administrator is further proposing to find that the combined emissions of CO2, CH4, N2O, and HFCs from new motor vehicles and motor vehicle engines contribute to the atmospheric concentrations of these key greenhouse gases and hence to the threat of climate change. This is referred to as the cause or contribute finding.

Today’s proposed action, as well as any final action in the future, would not itself impose any requirements on industry or other entities. An endangerment finding under one provision of the Clean Air Act would not by itself automatically trigger regulation under the entire Act.

Proposed Finding

The Proposed Endangerment and Cause or Contribute Findings for Greenhouse Gases under the Clean Air Act was signed on April 17, 2009, and will be published in the Federal Register and available in the Docket (www.regulations.gov) shortly under Docket ID No. [EPA-HQ-OAR-2009-0171].  A pre-publication copy is provided below.  While EPA has taken steps to ensure the accuracy of this Internet version of the document, it is not the official version.

Technical analyses developed in support of the Proposed Endangerment and Cause or Contribute Findings for Greenhouse Gases under the Clean Air Act may be found here:

Submitting Comments on Proposed Finding

The public comment period is open for 60 days following publication in the Federal Register. (Please note that official comments on the proposed finding cannot be submitted until the Federal Register publication).

Written Comments

Written comments on the proposed finding (Docket ID No. EPA-HQ-OAR-2009-0171) may be submitted by using the following instructions:

When providing comments, please submit them with reference to Docket ID No.  EPA-HQ-OAR-2009-0171.

Public Hearings

There will be two public hearings for this proposed finding.  EPA requests those who wish to attend or give public comments, to register on-line in advance of the hearing.  EPA will audio web stream both public hearings.  The meeting information pages will be updated with this information as it becomes available.

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173 Responses to CO2, EPA, Politics, and all that

  1. Antonio San says:

    Anthony you have to read this one from AP Seth Borenstein:

    “SETH BORENSTEIN
    The Associated Press
    April 14, 2009 at 4:23 PM EDT
    WASHINGTON — A new scientific study finds that the absolute worst of global warming can still be avoided if the entire world cuts emission of greenhouse gases the way U.S. President Barack Obama and Europe want.
    A computer simulation by the National Center for Atmospheric Research in Colorado looks at what would happen by the end of the century if greenhouse gas levels were cut by 70 per cent.
    The result: The world would still be a warmer world, but by about one degree Celsius instead of two degrees.
    Arctic sea ice would shrink but not disappear, and sea level would rise less.
    About half the temperature increases and changes in droughts and floods can be avoided compared to a scenario without emission cuts, according to the study, which will be published next week in the journal Geophysical Research Letters.
    Future heat waves would be 55 per cent less intense.
    Thawing of permafrost in the far north would also be reduced.
    The study is one of the first to use computer models to quantify how much of the effects global warming can be avoided, compared to a world if nothing is done about the problem.
    While the study looked at what would happen with dramatic cuts in future pollution, history has shown that reductions are much easier to talk about than to make. The controversial 1997 Kyoto Protocol called for industrialized countries to cut emissions but since then levels worldwide have gone up 25 per cent. In the United States, where emissions are up six per cent in the last decade, Congress is fiercely arguing over a plan to reduce pollution.
    “If we follow on the path that Obama has outlined of cutting emissions by 70 or 80 per cent and the rest of the world does it, then we can make a big difference on the climate by the end of the century,” climate scientist and study chief author Warren Washington told The Associated Press.
    But if the United States and Europe cut back on carbon dioxide and China, India and other developing countries do not, then the world is heading toward a harsher hotter future, not the one the study shows, Mr. Washington said.
    The study mapped areas that would benefit the most by emission cuts, comparing what would happen with less carbon dioxide pollution and what would happen if greenhouse gas continue to grow. The difference between the two scenarios is starkest for temperatures in Alaska and the mountain west, which would see temperatures rise a couple degrees less with emission cuts. Reduced carbon dioxide would also significantly lessen predicted future droughts on the Pacific coast and flooding in the Northeast.
    Much of Europe, Russia, China and Australia would see the biggest temperature benefits from reductions in greenhouse gas pollution, while the Mediterranean, Caribbean and North Africa region would benefit the most in predicted changes in rainfall from less global warming.
    If the world cuts back on fossil fuels, “it isn’t going to be as bad,” Mr. Washington said.”

    So if they re-elect Obama for the next 20 years, we may even enjoy a glaciation…
    And this gem: “Future heat waves would be 55 per cent less intense.” Guys not half, but 55- FIFTY FIVE-, all is in the extra 5%… LOL

  2. tokyoboy says:

    As a chemist having studied the molecular mechanism of photosynthesis for 30 years, I watched with much delight the fine collage at the article top. Let me please use this at a debate with AGWers to be held next Saturday.

    REPLY:
    Take my art, please. – Anthony

  3. Cliff Huston says:

    What, the number one greenhouse gas is left off the list?

    REPLY: Water vapor, of course, but its a natural part of the earth’s environment and cycles, so regulating it would be just crazy, oh, wait….

  4. David L. Hagen says:

    Anthony
    May I propose setting up a proforma post for each major section of the two documents:
    * Pre-publication copy of the Administrator’s Proposed Endangerment and Cause or Contribute Findings for Greenhouse Gases under the Clean Air Act
    * Technical Support Document for the Proposed Findings
    Then let readers post substantive references and comments to each of those sections. e.g. see
    Nature Not Human Activity Rules the Climate
    (Strongly recommend all readers cut the flak and focus on substance in these sections.)
    Readers could then work together to write well documented responses to those sections citing the technical literature and data.
    It would help to have links on the side to these posts to easily access them over the next 60 days while other posts continue.

  5. David Segesta says:

    It seems our government has become detached from reality (i.e insane!) This is reminiscent of Orwell’s 1984; “war is peace”, “freedom is slavery”, “ignorance is strength”.
    In this case; lots of ice is no ice, cold is hot, a beneficial gas is dangerous, etc.

  6. Ron de Haan says:

    tokyoboy (20:01:59) :

    “As a chemist having studied the molecular mechanism of photosynthesis for 30 years, I watched with much delight the fine collage at the article top. Let me please use this at a debate with AGWers to be held next Saturday.

    REPLY: Take my art, please. – Anthony”

    tokyoboy:

    For your information:

    1. http://scienceandpublicpolicy.org/reprint/markey_barton_letter.html

    2. http://www.ilovemucarbodioxide.com

    3. http://factsnotfantasy.blogspot.com/2009/04/stop-epa-before-it-destroys-america.html

  7. Dave Wendt says:

    Obama announced his intention to do this back during the campaign, but I guess no one believed him, or they just didn’t realize how much more dangerous this is than even the worst cap and trade scheme. If this goes through, every proposal, plan, or action by any corporation, business, governmental unit, or even individual will become immediately subject to the extortionate legal predations of the ravaging hoards of the environmentalists lawyers. It will not take long for the entire economy to come to a screeching halt. We are already experiencing the litigation costs inflicted across the economy, in health care, development,equal opportunity, and other areas where the reach of the regulations is a minuscule fraction of that which these rules will provide. If this colossal folly is allowed to stand we will have reached a “Will the last one out please turn off the lights” moment. Unfortunately, these donkeys have such an advanced case of cranio-rectal inversion syndrome, that no amount of public outcry may dissuade them. But we had all better give it our best shot anyway, because, unlike the catastrophe fantasies of Algore and Hansen, our lives will really be on the line if this stands.

  8. Imran says:

    This is the mother of all political correctness gone completely mad ….

    In fact I find the whole thing terribly sad … it just shows that we, the human race, have not travelled very far from the days when we locked up Gallileo for daring to state that the earth went around the sun.

    It is beginning to remind me of some of the sci-fi books I used to read as a kid where futuristic society behaves in some ridiculous fashion – like not going outside because air would kill you …. under the management of some “Big Brother” government which just maintained the lie for no other reason than control.

    The damage done to science and progress will last a generation and I just hope that the debacle of this issue from the first decade of the 21st century will be used as a learning and as an example about the dangers of political dogma gone crazy – it is the opposite of every good value we teach our children.

    Anthony is right – now is the time to stand up and say “THIS IS NONSENSE”.

  9. timetochooseagain says:

    Pat Michaels has shredded the “Technical Support Document”:
    http://cato.org/pubs/articles/michaels_ANPR_EPA.pdf

  10. Ben Lawson says:

    [snip - not interested in your opinions on lead, take it somewhere else - Anthony]

  11. Fat Man says:

    Let the games begin.

    Folks, do not panic. This is only one more step in a process that will grind on until everyone thoroughly sick of it.

    The EPA issued a proposed finding. Now they have to hold hearings, which should be quite droll. Once they have done that. and the comment period has closed. They must review the mountains of comments they will receive and the hundreds of hours of testimony they will have to transcribe. Then they must prepare findings. All of that will take months. The EPA will have have to propose a remedy. (I do not think that anything but automobiles is on the table here so cap and trade, and coal fired power plants will not be issues).

    Then the litigation begins. I see at least two trips to SCOTUS. Of course, Congress could still act (your life, liberty and property are not safe).

    The administration will discover that it is of two minds about most of these issues, being firmly converted to Gaia worship, but also having sunk or committed to a $Xe11 stake in the US auto industry. Try to figure out how to bail out that pup without sell SUVs.

    Overall, I think that it is fairly safe to bet on a new ice age starting before this clusterf*** is resolved. Generations of lawyers will send their children to college, and fund their IRAs off of the litigations. Millions of trees will die needless deaths. And still nothing meaningful will have happened.

    Make no mistake, the administration wants to use this development to push a “cap and trade” or carbon tax through congress, not to appease the Goddess, but to find a source of money to pay for their bailouts and for socialized medicine. I doubt that it will work for them in that way.

  12. Mike Strong says:

    Gauntlet Dropped. Grass Roots need to add fertilizer.

    I already sent a protest to the “EPA Chief Administrator” (Lisa Jackson) who spoke for the media stories. You can find her bio here on Wiki: http://en.wikipedia.org/wiki/Lisa_P._Jackson

    My suggestion is that EVERYONE who reads this blog and disagrees with the IPCC conclusions (Al Gore, Hansen, et al)…needs to fill out the EPA public comment form without delay.

    You can find Lisa’s email by typing her name in here: http://cfpub.epa.gov/locator/index.cfm

    You would be surprised how these people actually takes your comments seriously. It’s how we recalled a governor in CA and beat down some votes in our legislature.

    And President Obama says he wants to hear from you. You can write to him here: http://www.whitehouse.gov/CONTACT/ But be careful, and respectful. Once you hit SEND…you don’t want a visit from the FBI or Secret Service.

    …and don’t be a Hansen or Joe Romm. Be *nice*: we are presenting science, not emotion.

  13. Ohioholic says:

    Time for a tea party, carbonated of course.

  14. Ohioholic says:

    As a matter of fact, if this goes through, civil disobedience is in order. Not the Hansen variety, the Henry David Thoreau variety.

  15. P Folkens says:

    Every student who passed high school biology knows at least the fundamentals of the carbon cycle, so there shouldn’t be any point in restating it here. However, the higher reaches of the government don’t seem to understand that if CO2 is a pollutant, then O2 must also be a pollutant. Hey gang: plants use CO2 from the air and sequester the C part in the form of, well, plants, and in the process, release the O2 part. Animals use the O2 from the air, eat the plants, and sequester the C part from the plants in the form of, well, a carbon-based animal and, in the process, release CO2 into the air or CH4 (methane, another one of the bad-ass gasses which produces more CO2 when burned in the presence of O2). When the animal dies, the C part is released again in the form of CO2 which is used by the plants . . . and so on infinitum.

    This is getting aggravating!

  16. Smokey says:

    [Don't feed the trolls -Anthony]

  17. Roger Sowell says:

    This is an excellent opportunity to be heard by the EPA.

    I want to share some thoughts about making public comments, as I attend many public hearings on various issues before agencies and commissions, listen to the comments, observe the commenters, and read many of the written comments that are submitted. I also make comments from time to time. I meet with various commissioners and members of public agencies, and get their views and feedback on comments and those who make the comments.

    One of my public comments on California’s Global Warming law is here:

    http://www.arb.ca.gov/lists/scopingpln08/1554-arb_letter_sowell_12-9-08.pdf

    Comments are made in all forms and styles. Some are more effective than others. For those who want to view some comments on other issues, for style and content, please have a look at the link below. Some comments are one or two sentences, and others extend for several pages. Length does not matter, but content does.

    For the most effect, it is a good idea to consider the following format for a comment:

    Use letterhead. When the letter is complete, scan it and attach the digital file to your comment.

    Identify yourself and / or your organization, describe what you do or your experience. It is a good idea to thank the EPA for the opportunity to make comments. (They like reading this, even though they are required by law to accept comments). If you work for an employer who does not support your view, it is important to state that your views are your own and do not represent anyone else.

    Organize your comments into paragraphs.

    Use a form letter only if you must. It is far more effective to write a comment using your own words.

    However, if someone else’s comment states what you wanted to say, it is fine to write and refer to the earlier comment, by name and date, and state your agreement with what was written. The agency appreciates that, as it reduces the number of words they must read.

    It is important to know that the agency staff reads the comments, categorizes them, and keeps a total of how many comments were made in each category. So, the number of comments do count. Encourage your friends to make comments, too.

    Make your statement/point in the paragraph, refer to actual data where possible, and give the citation or link. Tell them why you hold your view. Try to maintain a positive, reasonable tone, and if criticizing the EPA, tread gently. Point out the inconsistencies of their view compared to other respected publications, or to accepted methodologies.

    It is a good idea to describe how you are affected, or will be affected, by this proposed rule.

    Close by thanking the EPA for considering your view.

    Sign your name (comments get much more serious consideration when signed).

    The link to public comments on U.S. government issues:

    http://www.regulations.gov/search/search_results.jsp?css=0&&Ntk=All&Ntx=mode+matchall&N=8099&Ne=2+8+11+8053+8054+8098+8074+8066+8084+8055&Ntt=comments&sid=120B596A7935

  18. Ohioholic says:

    Save the environment! Outlaw beans at once!

  19. Robert Bateman says:

    I wrote the President and Lisa Jackson.
    Something tells me they are not listening.
    Something tells me that the bus is going the wrong way on the freeway.
    The only one who is against this in my neck of the woods in our Republican Congressman, Wally Herger.
    In fact, I would say in this politically charged war on C02, you will be whistling in the wind writing to any Democrat. They buy AGW.
    Find a Republican and write them instead.

  20. MarcH says:

    Anthony,
    Does UP EPA consider submissions from outside the US? If this goes through other pseudo green lobby groups are likely to use it as a precedent.

  21. Pofarmer says:

    But wait, it gets even better.

    Vilsack names head of Environment and Climate

    By Lisa M. Keefe on 4/17/2009

    Handtmann, Inc
    As the controversy over global warming — and meat production’s contributions to it — gains steam, USDA Secretary Tom Vilsack announced that an executive of the Environmental Defense Fund (EDF) is appointed Senior Advisor to the Secretary for Environment and Climate.

    In this position, Robert Bonnie, EDF’s Vice-President for Land Conservation and Wildlife, will help guide broad policy and program decisions with an emphasis on those concerning the nation’s natural resources and climate issues.

    Bonnie is described as a leading national expert on the use of markets as a means to reward stewardship on farms, ranches and forest lands, including carbon crediting and conservation banking for endangered species.

    “Robert Bonnie brings to USDA 14 years of experience at the Environmental Defense Fund where he worked to conserve natural resources and protect the climate on America’s farms, ranches and forest lands,” Vilsack said in a release.

    “President Obama has been clear that two of his top goals for the department are related to the environment: expanding the capacity of our land, our farms, and our ranches to produce alternative forms of energy and fuel; and developing the research that will help agriculture transition away from its significant dependence on fossil fuels.

    “Robert’s work on conservation incentives and markets, as well as conservation policy, will help guide USDA as we address some of the most challenging issues facing our nation’s future.”

    A Harvard graduate, Bonnie holds a master’s degree in resource economics and forestry from Duke University’s Nicholas School of the Environment, Durham, N.C. He grew up on a farm in Kentucky and now lives in Virginia.

    Yeah, radical enviromentalists within USDA. What could go wrong?

  22. Jon Jewett says:

    Why this call to action is important: In that respect this is not OT.

    I am a history buff and have learned something about economics. This may sound ‘too basic and silly” but….

    Money only has value because it represents “stuff”, i.e. goods and services. A special hand picked organic apple is sold for $1. Everyone agrees (except maybe me) that a perfect organic apple is the equivalent of a piece of paper that has a “$1” on it.

    But suppose that one player in the economic game says that we have printed so many $1 that your $1 is no longer worth that perfect apple. Let’s imagine that player says that they will not take any more pieces of your paper i.e. loan you money or accept your money in trade. Should (heaven forbid) that idea catch on, soon nobody will believe that your paper has any value at all. Your paper (and everything denominated in your paper) will not only be worth less, but literally worthless.

    See here from the UK Times, it talks about our biggest creditor:
    http://www.telegraph.co.uk/finance/comment/ambroseevans_pritchard/5160120/A-Copper-Standard-for-the-worlds-currency-system.html

    Here are some examples as to why you should be concerned:
    http://www.brazilbrazil.com/inflat.html
    http://en.wikipedia.org/wiki/Economy_of_Zimbabwe
    http://en.wikipedia.org/wiki/Inflation_in_the_Weimar_Republic

    The expected regulations will add a giant tax to the economy of this country. To pay for that tax (if the Chinese aren’t stupid enough to loan us the money) will require that the government print a gadzillion dollars. See what happened in the Weimar Republic, above.

    I am at the age when I can no longer start over.

    I am concerned-very concerned.

    Regards,
    Steamboat Jack

  23. This needs to be addressed on 2 fronts…

    Cap and Trade and the EPA Clean Air Act

    Both most be stopped or this battle is lost, and maybe even the war. Do not kid yourselves into thinking the bloated bureaucracy of DC will hinder the EPA, the regulations are drafted and the funding for enforcement is in place courtesy of the Stimulus Bill providing a 50% increase in funding or 3.6 Billion per year for two years on top of the 7.2 Billion operating budget, what do you think that funding was for?

    In either scenario the EPA will receive enforcement powers, and they intend to use them.

    The Chamber of Commerce has been subverted already as have the Oil Companies and Steel Workers Union. Utilities have been green lighted to pass the costs to consumers thanks to Sen Boxer neutering the Thune Ammendment.

    The units are all in place, the battlefield has been selected and the command to advance given.

    Lets send the Administration to Copenhagen empty handed, which is their greatest fear on the International Stage, an embarrassed President communicating the real will of Americans to the world.

  24. Dane skold says:

    O/T

    In a refreshing acknowledgment of the lack of predictive capability in AGW climate models, “scientists” hope that using cheap, error-prone computer hardware will introduce randomness into the models and thereby increase predictive accuracy. In other words, their super-computers are too accurate to produce reliably predictive results?

    Why don’t they just engage 7th graders to do the math for them since they’re looking for computational errors?

    “Cheap and noisy chips could improve climate predictions. As scientists fill out the picture of a future dramatically changed by global warming, the use of climate models is increasingly important. Simulations on cheap computer chips that produce results tainted with random noise could improve those models. New Scientist, England. 17 April 2009.”

  25. Ben Lawson says:

    Re: [snip - not interested in your opinions on lead, take it somewhere else - Anthony]

    [snip again ~ charles the moderator this time. Seriously, if you want to contribute then contribute, but hurl insults somewhere else]

  26. Matthew C. Wiatt says:

    My post to the EPA and Whitehouse. Keep it clean, keep it science, keep them coming!

    I am a retired Air Force member. I worked in Meteorological and Astro-Geophysical forecasting for 26 years.
    The changes in temperature observed around the world are a result of variations in the Solar Cycle which in turn drive the oceanic oscillations. While the variation in solar output is only 0.1%, certain energy spectra are much more affected. These variations produce more or less cloud cover which cause increases or decreases in the amount of heat in the oceans. The oceans, covering nearly 75% of the earth’s surface are what set our planets climate.
    While CO2 is a green house gas, its effect is miniscule compared to the solar forcing effects on our oceans. To say CO2 is causing the observed change in weather patterns is to suggest that a monkey jumping into a tree caused it to fall while ignoring the elephant pushing the tree over. The Solar cycle in the 20th Century was very active and produced the warming we have seen in the recent past. The Solar cycle has entered a much quieter phase and global temperatures as a result are declining.
    CO2 is part of the natural environment and the earth knows how to recycle it in a myriad of ways without help from humans. To treat CO2 as some detrimental pollutant is to try and solve a non-issue. This will only distract scarce resources from real human problems.

    Sincerely; Matthew C. Wiatt, USAF Retired.

  27. timetochooseagain says:

    Robert Bateman (21:20:13) : I’m no Dem, but there are “not now” Dems we could appeal to, and just trying to get the minority party to listen gets us nowhere. With even one R, the activists have cloture, and they’ve got ol’ John McCain in the bag. But if you say to the Dems “please don’t let them do this to us, please don’t do it to us yourself, not now, not when we are still hurting from the economy” you’ll find that in their high minded “empathy” they may have a hard time not listening.

  28. theduke says:

    Ohioholic (20:32:41) :

    As a matter of fact, if this goes through, civil disobedience is in order. Not the Hansen variety, the Henry David Thoreau variety.
    ———————————————————–

    Why wait until it “goes through?” This represents the most egregious attack on the rights and well-being of American citizens that I have witnessed in my lifetime. We need to be “taking (this) to the streets,” as the song says. Environmental authoritarianism, which is what this represents, is, or should be abhorrent to all Americans.

    I read the list of authors and expert reviewers of this finding. The only name I recognized was Gavin Schmidt’s. I don’t recall ever voting for any of these people. I don’t believe they should have the power to change the very nature of constitutional government in this Republic. And let’s be clear: that is what they are intending to do.

    Political power in the United States has always been and always should be subservient to the economic power, since it is the power of the economic system that pays for government and allows it to function. Does government regulate and provide stability? Yes, of course. But stability is dependent on the ability of people to act freely to create wealth and prosperity. What this finding does is give the government, in the name of speculative, unproven science, the power to strangle growth and economic dynamism.

    In a Republican Congress, this kind of finding by the EPA would have been laughed at. In a Democrat Congress, anything is possible, given that Henry Waxman is in the pivotal position of power on these issues. I urge everyone to contact your Representative and express your outrage and disbelief at this assault on the fundamental economic rights of all Americans.

  29. F. Ross says:

    CO2 declared a “dangerous pollutant”!

    This is a recipe to bring our republic, the greatest experiment in government ever created, to its knees … and if followed, means back to the dark ages for the USA.

  30. Pofarmer says:

    You folks can write all you want. But, I truly beleive this is a done deal. They’ll wait the 60 days then enact whatever regulations they’ve written. Simple as that. They don’t CARE what we think. Look at the bailouts, look at the stimulus bills, they were 100 to one or more calls and e-mails against and they got passed. Buy some warm clothes and a generator if you are in a cold climate. You’ll need them when the lights go out.

  31. Eric Anderson says:

    Agree with David Hagen and Roger Sowell.

    A couple of additional points for those making comments to the EPA:

    - The second proposed finding, namely that emissions from new motor vehicles contribute to the atmospheric concentrations of the 4 named greenhouse gases emitted by motor vehicles, is probably not worth spending a lot of energy on. To be sure, there are weaknesses in the EPA’s position, particularly in terms of whether “new motor vehicles” is to be understood as “additional” motor vehicles that will also be driven full tilt, or whether it is understood to mean “new” in the sense of replacing older motor vehicles (e.g., when I bought my new car last year, I stopped driving the old one). Nevertheless, this second proposed finding largely follows from the first proposed finding. Thus, the real meat of the discussion needs to be on the first proposed finding.

    - The first proposed finding, namely that “greenhouse gases in the atmosphere endanger the public health and welfare of current and future generations,” is where the real battle should lie. There are several potential attack points in this first proposed finding:

    First, it appears that the EPA is claiming that the *current* concentrations threaten the public health and welfare of the *current* generation. The larger pre-publication document is less direct on this point than the summary sheet, but it appears that this is the EPA’s position. This is a significant weakness, as the evidence marshalled by the EPA in support of this position seems to consist only of blanket statements that recent events have been caused by climate change, coupled with concerns about “likely” projected future events. Further, the idea that *current* concentrations threaten the public health and welfare today is a significant departure from even most CAGW supporters, other than perhaps the most fanatical fringe, a la Hansen. Almost all CAGW alarm is directed at future possible events, and there are numerous public acknowledgements that it is impossible to link any particular current catastrophic event to climate change.

    I have not researched the issue enough to be certain, but I believe the EPA’s claim that the current concentrations threaten public health and welfare here and now may be necessary in order to bring the matter under the EPA’s purview or at least under particular sections of the Clean Air Act. In other words, if the EPA were to conclude that some anticipated future concentration would constitute a threat to public health and welfare in the future, would the EPA still have the full slate of regulatory tools at its disposal? I suspect not, but if anyone can point us to chapter and verse, please do so.

    In either case, the EPA’s position that the current concentrations are a threat here and now, is, in my estimation, the weakest chink in the EPA’s findings from an evidentiary standpoint.

    Second, the EPA is specifically not seeking to regulate CO2 because it is directly harmful to humans. The EPA acknowledges that it is not, and that it is only through the secondary effects of climate change that the threat exists. I believe this is a significant departure from the EPA’s standard operating procedure, namely, that a specific pollutant can be shown to have a direct and demonstrable link to health and/or welfare. If anyone knows otherwise, please let me know. If I am correct in my assessment, this represents perhaps the weakest legal link in the EPA’s position.

    Third, and the part that jumps out at most people, is that there are dozens of statements of “fact” that are widely in dispute. These will hopefully be challenged one by one, but permit me to suggest that most individuals who provide comments to the EPA need not get bogged down in each and every one of these misstatements. I would recommend that if you have good evidence — particularly peer reviewed literature — to counter specific statements, then by all means present it. Otherwise, I believe the old adage “silence is better than a bad argument” should rule. For example, be wary of random links to graphs and charts on the Internet that are not well documented — you argument will be better served by not proffering questionable evidence. Commenters who do not have the time or expertise to challenge each of the EPA’s “factual” statements can still provide valuable input on the absurdity of regulating CO2, the failure of models to adequately predict current climate events, the fact that even if warming occurs, it will not necessarily be net detrimental, etc.

    Fourth, the pre-publication document has a section on uncertainties. This section should be exploited by pointing out how the EPA has vastly understated the uncertainties in its findings, while vastly overstating its confidence in projections and models that have to date proven inadequate to the task.

    - Finally, some have asked about water vapor. The full pre-publication findings do spend about 2 pages discussing water vapor, but solely for the purpose of explaining why it should not be regulated under the Clean Air Act. Specifically, the EPA states that “direct water vapor emissions from human activities have only a negligible effect on atmospheric concentrations of water vapor” and that “changes in water vapor concentrations are not an initial driver of climate change, but rather an effect of climate change which then acts as a positive feedback that further enhances warming.” This is not the most worthwhile area to spend time on in comments to the EPA, but there may be some value in a couple of brief, well-placed challenges to these statements.

  32. Ray says:

    Those politiciens are stuck in a Gorian loop. They keep recycling the untruth from Gore’s movie. God, stop voting those people in, please.

  33. nvw says:

    I agree with Fat Man (20:28:05) that the time before anything comes to pass will take years, however there is a simpler solution to the problem.

    First, realize the reason CO2 was declared a “pollutant” was via the Supreme Court. If you thought the IPCC was a loosely credentialed scientific organization, what does that make the Supreme Court?

    The Obama administration is floating a trial balloon by having the EPA start this process. The Administration agenda right now is to solve: financial crisis, health care, energy, Iraq, immigration, and on and on. The political reality is that not everything can be done. As soon as they meet serious resistance they will switch to a different topic. And they most certainly will meet resistance when the public realize that following the EPA down the path of CO2 = pollution is a one-way ticket to national poverty.

    The best solution to the problem will be to force Congress to rewrite the Clear Air Act. Clearly written statutes from Congress will remove any possibility for the courts to make mischief with their interpretations. A Clean Air rewrite may be the first bipartisan bill of the current Congress, as Republicans and centrist/rust-belt/Blue Dog Democrats unite to support American economic and reform the environmental laws that have lead us to this current fiasco.

    So by all means submit comments to the EPA, but I suggests a more fruitful approach would be to lobby your Representatives and Senators and demand a Clean Air Act rewrite now.

  34. GK says:

    This has become so political, that there is NO POINT in trying to argue this with science or facts. It`s fact global temperatures are cooling. It`s a fact sea ice is increasing. It`s a fact water vapor is not increasing as their models demand. It`s a fact all of the AGW climate models fail spectacularly. Considering this, do you think they will EVER acknowledge the truth ? Of course not. These people are not and have never been interested in the actual science. AGW is just a mechanism to spread and enfore the new socialist ideology of the “Western Socialist Left”.

    The only way these con artists will come clean, is if they know that they will face criminal and financial charges for their mass fraud.

    There needs to be a “movement” (political or not) that will proposed to charge these people with crimes such as treason, criminal fraud, etc. And not only criminal charges, but they will also be personally liable to pay financial compensation. I’m not talking about a “republican” movement, they arent much better (with few exceptions like Inhofe etc). This needs to be something like the current US “Tea Party” movement.

    Outside of that, we are all wasting our time. If these people are prepared to ingore all the fact (temps cooling, sea ice increasing, no water vapor), then what`s the point pointing out more facts ? They will just continue to ingore it and lie so more. Why will more facts make a difference to frauds and liers?

  35. MRCXS says:

    Wait, there may be some hope yet. There is a techhnology known only to GWAs that deniers haven’t been told about yet. There are large tanks of this toxic CO2 gas in the storage rooms of hundreds of thousands of restaurants all over the world.

    Somehow this gas known to cause serious harm to humans, as it travels through a special tube to a top secrete machine, is mixed whith certain chemicals and served as refeshinng drink.

    In all seriousness, the health dept did come by and lable my CO2 tank as a toxic gas. If it sounds too incredible to be true check with the Riverside, Co CA health Dept as to how all CO2 tanks are labled.

    How long before CCola is sued? My guess is that GWAs would rather not have attention drawn in that direction because the general public won’t go along with any regulation that messes with their fav soft drink.

    Best to stick with endless studies on the contribution of cow farts to AGW. We haven’t gotten hooked on drinks made with those yet.

  36. Troppo says:

    Please correct me if I am wrong…but the picture on the left (behind the burning CO2) is of a power station and that is steam coming out from the stacks not smoke…yes I know this is favourite shot of the AGWers for its dramatic, but highly misleading, effect.

  37. Roger Sowell says:

    GK, you make some good points. However, the politicians and EPA under Obama do not listen and will not listen to anything but the AGWers. Al Gore, Hansen, and others have effectively made their song the only one on the radio (or IPod).

    The AGWers have waited a very long time to get to this point in history, and they are not about to let anything stand in their way, not facts, not evidence, not credentials, not persuasive arguments made by eloquent speakers, not even record cold and snow. The AGWers have painted the picture so that everything that happens can be and is made to be a result of man-made GHGs. Very clever, these AGWers. No-lose situation for them.

    Given all that, an outpouring of comments, well-written, and pointing to facts as Eric Anderson wrote above are still necessary to show the level of disagreement. Even then, the EPA will issue the proposed finding. This is not about the facts, and never has been.

    One can only hope that entire industries write comments, with threats to shut down factories and lay off thousands (millions) of people should this CO2 regulation be passed. Americans out of work by the millions is about all a politician cares about. Out-of-work voters do not vote for the party that put them out of work.

    We are seeing industries shutting down or moving out already in California, and Texas has made rumblings about shutting down refineries and chemical plants if their costs to operate increase due to carbon cap and trade. Shell in Australia made similar arguments a few weeks ago – said they would shut down the refinery (a major employer) and simply import gasoline and diesel and jet fuel. And that threat is real. Several major refineries either just started up, or are under construction around the world, so there is plenty of refining capacity.

    Every industry that uses energy (and that includes EVERY industry) will be impacted, steel, aluminum, copper, electronics, textiles, aircraft, automobiles, refining, defense, lumber, every single employer will see their costs rise. Only import tariffs will keep America competitive, and those are generally forbidden by international agreements.

    Once the manufacturing is gone overseas, all the other satellite industries are finished, too, such as finance, banking, and mortgage lending. With millions out of work, retail and entertainment collapse, and restaurants and coffee shops soon follow. Construction collapses too.

    It is far cheaper for manufacturing to move overseas and ship the goods back to the U.S.A. Many millions will be out of work, as there are not enough hamburger joints in the U.S. for all of us to get a job sprinkling salt on the fries. People will resort to making their own baloney sandwiches again, like we did in the 1950′s.

    And the ironic thing is, the Democrats and AGWers can always point to the economic crisis that started under George Bush, and blame it all on Bush. They will never accept any blame for CO2 caps causing any problems. Their economic models show that capping CO2 is good for the economy and increases employment. By the way, those economic models make the GCMs look great.

    Still, we can and should write the comments. At least we can later point to the comments and say I Told You So. I’m drafting mine now.

  38. Pete Stroud says:

    I heard Obama promising this ridiculous change in the law during his campaign together with the promise to bankrupt the coal industry. My thoughts then were that he was only making these claims to win the environmentalists vote and would quietly forget all about such rubbish when elected. How wrong I was. As a UK citizen living under a socialist high spend, high tax government I sympathise with your plight.

    You have a fight on your hands and I guess our idiot politicians will follow suit.

  39. Richard111 says:

    It will require a police force larger than the military to police this.
    How will they decide who is guilty of which emissions by how much?
    Welcome to Brave New Worlds.

  40. Sukiho says:

    great blog, personally I fully support the EPAs stance.

  41. PT says:

    Isn’t the issue to focus on how and why CO2 is not a significant greenhouse gas ? That this is absolutely paramount to the debate ?

    On the one side we have temperature and ice recordings that are diverging from measured CO2 trends in the atmosphere. That’s good

    On the other side we don’t have good enough models and explanations (both amoung scientists and for the layman?) to show that CO2 is not a significant greenhouse gas. This is very important, no ?

  42. John Edmondson says:

    Does this mean a genuine debate? Can we submit to the EPA from the UK?

  43. carlbrannen says:

    Fatman is right that this will take years and before it’s done, we’re likely to see a planet sufficiently cold that the idiots will not be able to maintain the political power required to do anything really dangerous to the economy. Some lawyers will make money.

    Having done my share of environmental permitting, I further believe that if they did declare CO2 a pollutant, the agencies would have to consider the cost of avoiding the pollutant, and that this cost would not be economic in almost all situations. Industry is required to use “best management practices (BMP)”, not “zero pollution”. Sure, it would be possible to use EPA to halt all (new) industrial development in the US but this is not going to happen.

    An “air permit” is basically a legal agreement between a business and the government where the business gets to pollute in certain ways and amounts but not in other ways, and which, in return, the business is made immune to lawsuits over its pollution. See the EPA description of air permits.

    Once you get a permit, all you have to do is stay within its limits. Then lawsuits on our pollution have to go to the permitting EPA office, not us. If the EPA system really were as extreme as a lot of people (who have never had to deal with it) believe, industry would have halted long ago in the United States. The permitting agencies are state agencies, not US government. In those states which desire industrial growth, permits are made easier because states are not that stupid; they know business knows how much time permits will take and avoid states with long permit delays.

    I believe that this global warming stuff will have no effect on US industry even over the very long term and even if we weren’t diving into a cold spell. It’s basically grandstanding for the left wing voters who gave Obama all that money. He’s gone back on his other campaign promises, this is the only thing he’s doing. But the way this is going, it will have no real effect. Obama’s gig seems to be another politician simply after power, more like Clinton than a true believer.

  44. john k says:

    All these nice people trying to save the world and all I am doing is exhaling the foul substance 24/7 I feel so bad, maybe if they taxed breathing it would expiate my guilt. Can someone lend me a copy of Alice in wonderland or AiW2 the computer simulation?

  45. Alan Chappell says:

    Anthony,
    as you have one million plus visitors here every month, of which the majority are concerned as to where the AGW movement are leading us, what would happen if even half of your visitors sent an email to the White House expressing there concern as to the direction this administration is heading? I think that if 500,000 emails arrived to the President on a particular subject even he, just might spend a few seconds to reflect.

  46. jeez says:

    Just so that there is no false rumors started. Anthony gets about about 1.5 million page views a month, not visitors. He gets about 120k visitors a month, about half are from the US. Just over 43% are regulars (visit more than once a month). These are not bad stats, but not as high as you stated.

    jeez aka charles the moderator

  47. Sukiho says:

    PT (01:23:50) :

    Isn’t the issue to focus on how and why CO2 is not a significant greenhouse gas ? That this is absolutely paramount to the debate ?

    On the one side we have temperature and ice recordings that are diverging from measured CO2 trends in the atmosphere. That’s good

    On the other side we don’t have good enough models and explanations (both amoung scientists and for the layman?) to show that CO2 is not a significant greenhouse gas. This is very important, no ?

    - good point, surely it could be easily disproved if it is so untrue, why no papers disproving it yet? maybe there are political motivations but that wouldnt stop one of the posters here writing a paper proving once and for all that CO2 is an insignificant greenhouse gas one would think.

  48. old construction worker says:

    Well it’s official. The EPA has ruled (based on junk science) CO2 is DANGEROUS GAS and if Congress doesn’t regulate it, they will!
    This a BIG BLUFF on the part Polosi/Obama and the EPA. The last thing Polosi/Obama and the EPA want is a lawsuit against the EPA and have the issue in front of the Supreme Court again. Science and the facts are not on their side. CO2 does not drive the climate.
    Polosi/Obama and the EPA need this CO2 cap and trade Scam in order to pay for their over spending
    We better start sending a clear massage to Congress
    NO CO2 TAX/CAP AND TRADE
    NO CO2 REGULATIONS.
    CO2 TAX, The NEW TEA TAX!

  49. Graeme Rodaughan says:

    I would love to be present the day that an EPA zealot walks into a Hells Angels Bar waving his “Authority” around and demands that they serve their beer flat.

  50. Rhys Jaggar says:

    You guys still haven’t got it yet?

    This is about giving the Wall Street Boys a new casino.

    Yup, that’s right. Sub prime bailed out, they need a new scam to continue their gambling. Now they’ve disarmed the London boys from their ‘market lead’……

    Cap N Trade.

    And in a few years, they’ll have bankrupted the banks again with phoney climate products and you suckers will be asked to bail them out. Again.

    Or is this time about the US exporting all that from day 1 to the rest of the World?

    Tell me it’s not……

  51. Keith Thompson MD says:

    I hope Fatman and carlbrannen are right that EPA regulations will take years to implement and that they will run out of political support before that happens.

    But I don’t think we should underestimate the damage our policymakers can inflict….witness the past six months of reckless spending.

    Does anyone know the legal trajectory that will occur? Who will sue the EPA and in what venue? What standards do their findings have to meet?

    Seems like the courts will be the best forum to bring down this craziness.

  52. Micky C (MC) says:

    You know I believe it was on this site or CA a year ago that someone mentioned this upcoming decision. I think this is a prime example of the power of linear thinking, cause = effect, and how we still haven’t moved on in any meaningful way as to consider more subtle and complex interactions.

    “CO2 goes up, temperature goes up. Look its a no-brainer” is a kind of comment we get. Maybe it is that simple, but I need it shown to me that it is.

    This type of legislation will move on the UK in a bit I can see it now.
    I laughed the other day at the Huxley quote about sense being overridden by democratic vote, as if people would vote against the law of gravity. Well this may just be a vote against non-linear systems.
    I’ll await the point when we have to ‘fill the mineshaft gap’.

  53. matt v. says:

    For decades we have been urged to urgently prepare for unprecedented global warming or there will be gloom and doom for the world. Yet only few years after the issue of their 2007 or latest report, exactly the opposite is happening. Matter of fact global cooling already started after 2002 and the long term climate trend is totally in the opposite direction of that predicted by the global warming science.
    So why are we taxing people for carbon and proposing even more ‘back door’ taxes via the ‘cap and trade’ mechanism to be followed by even more future green plan taxes to fight global warming that does not even exist.

    http://www.woodfortrees.org/plot/uah/from:2003/plot/rss/from:2003/plot/gistemp/from:2003/plot/uah/from:2003/trend/plot/rss/from:2003/trend/plot/gistemp/from:2003/trend

    This is the era of scams and very few are prepared to check the facts for themselves. To say that “carbon dioxide poses a risk to public health and welfare” is one of the most unscientific and contrary to any medical findings statement ever made. Every air quality index excludes it because it is harmless. http://www.epa.gov/air/urbanair/
    It would appear to me that we need to change the climate debate somewhat as the AGW science is being shown to be seriously wanting. Initially IPCC used the term GLOBAL WARMING and predicted unprecedented warming starting immediately [0.21C in each of the next two decades]. When this proved to be in error because the planet is actually cooling at a rate of [-0.195/decade since 2002*], the term was switched to FIGHT CLIMATE CHANGE. We are now asked to stop climate change. Well climate change has been with us ever since records were kept and natural climate variability and change is the name of the game on this planet .You cannot stop it. Every natural weather and climate event like the flood at Fargo or the Red River or the latest drought in California, if only slightly more severe than the last one, is falsely blamed on manmade greenhouse gases instead recognizing that there are natural climate cycles that cause these. It seems to me that if one does not pay homage or worship climate change religion, your opinions it does not count. Reminds one of the days when anyone questioned the reality of the weapons of mass destruction and wisdom of going to war in Iraq, he or she was falsely accused of being unpatriotic. Just because all the intelligence agencies of all major nations said they were real, genuine errors were still made by all. The same error may be being made today with respect to non existing global warming.
    Now that term” fight global change” has been proven to be wrong as well, a new term is being used REDUCE THE CARBON PRINT. This term will also prove to be wrong as Nature knows how to deal with excess carbon. It is neither a threat nor a pollutant. It is not even included in the AIR QUALITY INDEX. Highs and lows of carbon dioxide far greater than current have existed well before we came to play a significant role on this planet.
    However we have forgotten the term REDUCE POLLUTION which was the true legitimate fight until the global warming sidetracked everyone like the war in Iraq sidetracked the fight in Afghanistan. Fighting pollution involves real pollutants like NOX, SO2, CO, GROUND LEVEL OZONE, SMOG, LEAD and PARTICULATE MATTER. These kill people TODAY, not a 100 years from now. We should focus on the problems of today not those that are a century, 200 years or 1000 years from now as some studies suggest. When were lower targets for these real pollutants last discussed in the headlines? Whether we are talking about short term or long term, reducing real pollutants should be our battle. Becoming aware of natural climate cycles that cause floods like the one in Fargo, North Dakota or in the Winnipeg region in Manitoba this year and learning how to better prepare for the cooler weather ahead are all worthy goals. So is the goal of improving energy efficiency, the development of pollution free energies and a reduction of our dependence on foreign fuels. Let’s do the right thing and do it for the right reason instead of just focusing on carbon dioxide.

  54. Norm in the Hawkesbury says:

    Summer 2009: The international monetary system’s breakdown is underway

    The perspective of a US default this summer is becoming clearer as public debt is now completely out of control with skyrocketing expenses (+41%) and collapsing tax revenues (-28%), as LEAP/E2020 anticipated more than a year ago. In March 2009 alone, the federal deficit has nearly reached USD 200-billion (way above the most pessimistic forecasts), i.e. a little less than half of the deficit recorded for the entire year 2008 (a record high year)… (page 2)

    (Learn more)

    Will cap’n-trade happen? I doubt it!
    Will CO2 be banned? I doubt it!
    Will this administration be re-elected? I doubt it!
    Will the US economy collapse? Hmmmmmmmmmmmm!

  55. Tom in Florida says:

    First, I believe we must take the time to issue comments as described by Roger Sowell.

    Second, I also believe it won’t make any difference but still needs to be done as a first step.

    Third, I believe that in the end it will take lawsuits to make the EPA document how they came to the conclusion that “the atmospheric concentrations of these key greenhouse gases and hence to the threat of climate change” “threaten the public health and welfare of current and future generations”. The basis of the suit would, IMO, be based on how they determined what the correct temperature of the entire Earth should be in order to prevent this threat to public health and how they intend to keep the entire Earth at this constant temperature.

  56. Bobby Lane says:

    As I have been saying for months now, this is NOT ABOUT SCIENCE. As much as the AGWers wanna scream about the evidence being on their side and the debate being closed, etc., this (once again) HAS NOTHING TO DO WITH SCIENCE. That is only being used as a shield and a cover for manipulation of the law to achieve an ideological agenda. It is a re-ordering of society based on a perceived universal threat. It is softer than though als more insidious than Communism. I knew Congress would never go for anything this stupid, so that the EPA would have to act on the “threat.” Congress, being controlled by the Democrats, and most of the Republicans being useless on this issue, can now look the other way while the Executive branch, defender of America abroad, destroys America at home. So now we have an unelectable, unaccountable beauracracy controlling vast expanses of the American economy. Congress, so long as it is led by Pelosi, et al. will never bat an eyelash. Obama will be president for 3 more years and will no doubt use the EPA’s authority to re-shape various markets (energy, automotive, etc.) to suit his agenda. By the time Republicans gain any political traction back, it will probably be too late.

    I encourage everyone to fill out the form for Public Comment on this to the EPA. I shall do the same. But personally, in the end, I think the conclusion has already been reached and it won’t matter what anyone outside of D.C. and its circles of power thinks. The ship has sailed on that one.

  57. Skeptic Tank says:

    If CO2 is a pollutant and pollutants are bad then less CO2 would always be better than more CO2; and no CO2 would be better than some CO2. What would the planet be like with no CO2?

    This is fascism. The molecule is the problem. The molecule is evil. It is to be feared. It is to be hated. it is to be eradicated.

    Once the Government controls the molecule, and all activities relating to the molecule, they control everything. Give the Government the authority to control, regulate and tax the molecule and you surrender all Constitutional, statutory or civil liberties. Assuming the exercise thereof entails breathing.

  58. ChuckNJ says:

    This ruling is driven purely by political ideology. Being from NJ I know that Lisa Jackson was the former head of our DEP and is deeply involved in liberal-democratic politics. I can only imagine what would “fly” if she ruled that C02 was in fact not a pollutant. The only way we non-scientists can affect this ruling is by appealing to the political class and their endless desire to be re-elected. I wonder if they realize that their political future may be in jeopardy if they go along with this charade and in fact the “global warming” really turns out to be “global cooling”. I sent this letter to the President, my congressman and the local newspaper but my next one will include more of how they may all look like fools if the climate doesn’t go along with this charade.

    President Obama repeatedly states that we must separate politics from science yet when it concerns “cap and trade” and regulating CO 2 emissions, which the EPA has absurdly determined is a “health hazard” the science takes a back seat. The fact that over 750 internationally renowned scientists have signed onto the U.S. Senates Minority Report debunking CO 2 as the driver of global warming speaks volumes. When the President said in November “The science is beyond dispute and the facts are clear.” The Cato Institute’s response was “With all due respect Mr. President, that is not true.” with a letter signed by over 100 scientists in related fields. This isn’t the “consensus” that Al Gore was hoping for. The real consensus is that the earth stopped warming in 1998 and has leveled off and actually cooled in the last couple of years. The consensus is that CO 2 is an effect not the cause. The consensus is that mans influence on the climate is miniscule compared to the natural changes. The consensus is that man can’t control the climate but the politicians can and will try to control every facet of our lives. This attempt to regulate CO 2 with their more appropriately called “cap and tax” policy will do next to nothing to reduce the amount of CO 2 in the atmosphere, but it will certainly reduce the amount of money in your wallet. I should have added or is this just “deja vu all over again” like the 1970′s “Ice Age Scare”

  59. Geogrl says:

    It sounds like there is a push on from some quarters to move the USA into some sort of “utopian” non-technological agrarian society powered by wind and unicorns(the non-methane-producing kind).

  60. G.R. Mead says:

    It will require a police force larger than the military to police this. How will they decide who is guilty of which emissions by how much?
    Welcome to Brave New Worlds.”

    Oh, that’s already in play:

    We cannot continue to rely on our military in order to achieve the national security objectives we’ve set. We’ve got to have a civilian national security force that’s just as powerful, just as strong, just as well-funded.”

    Barack Obama,
    Colorado Springs,
    July 2, 2008

  61. Richard M says:

    Sukiho (02:53:49) :

    “- good point, surely it could be easily disproved if it is so untrue, why no papers disproving it yet? maybe there are political motivations but that wouldn’t stop one of the posters here writing a paper proving once and for all that CO2 is an insignificant greenhouse gas one would think.”

    LOL. The fact is there is no way to “PROVE” much of anything related to climate because it a massively complex and unpredictable phenomenon. That’s why you don’t see any papers “proving” AGW either. What you see is computer models that are far too simple and incomplete.

    If science was as smart as you appear to think it is, then why haven’t all diseases been cured? Why do we still have no clue about gravity? Why has this latest quiet sun cycle been such a surprise to most solar scientists? (I could go on forever). Once you understand that the sciences of complex systems is still in it’s infancy will you understand exactly what is going on.

  62. Eric Anderson (22:42:16) :

    Excellent points Eric. This needs to be argued to expose the main weaknesses and we need to focus on a select few talking points. I agree with all of your points except the last one about water vapor. It is also an important talking point since the evidence points to a very strong negative feedback for water vapor and clouds, i.e., that the cooling effect of clouds and convection carrying heat far higher into the atmosphere where the heat is easily exchanged to space is far stronger than the warming effect of additional water vapor in a radiative sense. +feedback is the basis of the AGW machine and is THE reason all GCM’s fail in the same way. This is an important fact to pound home.

    In the letter below, Christopher Monckton clarifies and supports his congressional testimony in March, and raises 50 “red flags” about testimony others gave in congressional hearings in March (inconsistencies or potentially fraudulent points he thinks deserve further review and questions to be raised for other presenters). This is perhaps the best summary I have seen to date that crushes the AGW alarmist position:

    http://scienceandpublicpolicy.org/images/stories/papers/reprint/markey_and_barton_letter.pdf

    This has been posted before, but really folks, if you’re here, you need to read this entire document. Twice. Among the 50 red flags, there are some very good talking points you can bring up in responding to the EPA. Please review and comment about which major points should be the focus of our attention. Thanks.

  63. Tonyb2 says:

    Sounds like a real opportunity to fix the credit crunch

    A new tax on breathing should do it

  64. The lessons of history:
    http://www.spunk.org/texts/places/germany/sp001630/peter.html#bib1

    PS:More than 15 days not showing the above link.

  65. Pofarmer says:

    Fatman is right that this will take years

    No, it won’t. In 61 days we’ll see the new regs. We already have a SC decision. They’ll say it’s “Urgent” or “emergency” or some such and just put the regs in place. Thing is, while this is going on, no company in their right minds will expand our build any new capacity till they see what the effects of all this will be, deepening the reccession we are currently in.

  66. Mark_0454 says:

    I have to read all the comments here on this, but I wanted to do this writing while I have my coffee.

    Chris Horner has made this point, part of this is to scare industry into supporting cap and trade. If they don’t go for the cap and trade they may get worse from the EPA. And some of them have gone along with it (Exxon).

    One of my favorite few paragraphs in the books I have read is the opening of the typhoon chapter in the Caine Mutiny. Wouk describes the warship and the typhoon as living things in a struggle. He gives the advantage to the warship, so to win the typhoon has to frighten the captain. It makes noises and sends waves to make him do something foolish. As long as the captain keeps his head, the warship has enough horsepower and engineering to ride out a storm. If the Captain loses his head and gives into his fears, the ship dies.

  67. Craig Moore says:

    I suspect much of the PR sales pitch for the EPA branding CO2 as dangerous will be about the “green economy” and “green jobs.” A study from the University of Illinois explodes those myths: http://www.law.illinois.edu/prospective-students/news/article.asp?id=1059

    =====================
    Much of the study examines the methodology used by various special interest groups to calculate how many green jobs new energy policies would create. Starting with simple fundamentals, these studies do not define new job creation in an economically sound manner failing to account for employment productivity or efficient use of labor. These basic flaws make comparison of job claims almost impossible and thus fail to create a statistical consensus.

    “Economic analysis is not a matter of justifying policy goals by making optimistic assumptions and ignoring those realities that fail to support your objectives,” said Dr. William Bogart, Dean of Academic Affairs and Professor of Economics at York College of Pennsylvania, another study author. “Our work here clearly shows that the foundations of these “green” jobs claims do not measure up to the kind of research standards we should demand when evaluating change in direction for our economy.”

    The study notes that one of the major flaws in existing research is its failure to acknowledge that mandating a move to new “green” sectors of the economy and away from fossil fuel-based sectors will shift jobs rather than create new jobs and thus overall economic growth.
    =========================

  68. timbrom says:

    P Folkens

    methane, another one of the bad-ass gasses

    Pun intended?

  69. pby says:

    I love this blog for info but the facts that are discussed here will have absolutely no factor in the co2 political debate; the fix is in the nazis are in control

  70. Bob B says:

    I don’t know if this has been posted already, but it is great news:

    http://www.rasmussenreports.com/public_content/politics/environment/energy_update

  71. DAV says:

    Fat Man (20:28:05) : Folks, do not panic. This is only one more step in a process that will grind on until everyone thoroughly sick of it. The EPA issued a proposed finding. Now they have to hold hearings, …

    Maybe you should look at the path DDT took through the EPA and how the final ruling was achieved. Yes, it will take time but the juggernaut has been released. Not that I’m advocating sitting still but I fear “resistance is futile.”

  72. M White says:

    From the Guardian

    http://www.guardian.co.uk/environment/2009/apr/17/obama-administration-emissions-warning

    “Environmentalists celebrated the ruling as the most definitive break to date with eight years of “climate denial” under George Bush.”

    Evironmentalists have their dodgy dossier too

  73. timbrom says:

    I’d love to help, but being a resident of the former colonial power, I’ll have to sit on the sidelines and watch this one. However may I suggest anyone thinking of submitting comments to the EPA have a good read through of Viscount Monckton’s letter to Congress?

    Letter to Represenatives Ed Markey & Joe Barton

    I think it’s about the most concise rebuttal of the whole AGW fandango yet written. 51 red flags and a host of graphs, papers and so forth. Frankly, if this was the only submission and the trolls at EPA actually read the damned thing, there might be hope.

  74. DAV says:

    carlbrannen (01:47:20) : Having done my share of environmental permitting, I further believe that if they did declare CO2 a pollutant, … Once you get a permit, all you have to do is …

    Unfortunately, CO2 has already been declared a pollutant. As for the rest: that process might be fine for a small number of cases. After all, how many of us produce or discharge hydrogen cyanide and how many of us produce CO2? This opens the door to governmental control of everyone without redress. Note that the EPA is proceeding with this DESPITE Congress.

    In those states which desire industrial growth, permits are made easier because states are not that stupid;….

    You think so? Then why was this lawsuit necessary?

  75. Keith J says:

    So whats wrong with the GCMs?
    Over the past 400K years, CO2 has varied between 175ppmv and 280ppm before industrialization as we transitioned from glacial to interglacial. That is a whopping 65% increase to get this spread. But every increase FOLLOWED temperature rise and every decrease FOLLOWED temperature fall by hundreds to thousands of years. But the climate modelers tell us that while the mechanism that initiates the change is likely due to orbital forcing, once the change occurred, CO2 levels were the main driver in maintaining the temperature. Now that we are approaching 400ppmv, we are told by the climate modelers we’ve reached a “tipping point” and temperatures will soar upward to 4deg C by 2100 as we approach 1000ppmv per the 4th assessment report. Looking back at the Mesozoic, CO2 varied between 1000-2000ppmv (mostly on the higher end) but oxygen isotope data show the temperature varied between 2 and 6deg C warmer than today. During the Eocene that followed, CO2 varied between 2000-3500ppmv and temperatures climbed to 6deg C warmer than today. But suddenly withing a few thousand years, temperatures plummeted to within 1deg C of today’s temperatures and CO2 was where 1500PPMV!! So when the IPCC states that since 1950, climate forcing has been driven by anthropogenic gases that overwhelm natural forcings such as TSI and thermocline, it begs the question, why can’t the GCMs account for the dramatic changes in temperature despite CO2 levels in excess of 1000ppmv if it forces at least a 4deg C temperature increase? Possible answer, there must be one heck of a negative feedback in the system that isn’t in their models.

  76. Ron de Haan says:

    Why there can be no temperature increasing greenhouse effect in our open atmosphere?

    In all their wisdom even skeptic scientists accept the existence of Global Warming and they also accept CO2 as a greenhouse gas.

    The only discussion is about how much CO2 influences atmospheric temperatures.

    The authors of this article simply say (and proof) that the influence of CO2 on atmospheric temperatures is ZERO, NIL, NADA.

    I think they are right. The effect of CO2 in our atmosphere has ZERO effect om temperatures.

    http://www.climatedepot.com/a/321/Analysis-Why-there-can-be-no-temperature-increasing-greenhouse-effect-in-our-open-atmosphere

    This eliminates CO2 as a greenhouse gas

  77. theduke says:

    On the state level, we have the chaos described in the following link breaking out all over California:

    http://www.signonsandiego.com/uniontrib/20071213/news_lz1e13lowe.html

    which proves the state can do anything stupid it wants to do if environmental law is poorly written and based on incomplete science.

  78. JohnD says:

    I’m looking forward to EPA regulations coming-to-a-face-near-you, requiring all polluters to install personal CHANGE units (Counteract Hazardous Anthorpogens by Neutralizing Global Emissions), which will convert every homo-exhalation in to inert, and most likely beneficial, Fairy Farts and Patchouli ions.

  79. David L. Hagen says:

    Encourage sending a copy of all comments submitted to the EPA to your
    1) Senators
    2) Representative
    3) President
    4) Editors
    (Note that Al Gore’s Repower America is collecting “members”. It is advertising “2,191,147 members” and seeks to ““repower” our country with 100% clean electricity within 10 years”! Replacing coal with current wind etc would result in a major jump in electricity costs. Best to take the email addresses and send email directly to editors separately.)
    David

  80. John Galt says:

    I’m shocked, absolutely shocked that a government agency would be in favor of expanding it’s regulatory power over it’s citizens. Especially since the agency is headed by a political appointee who has already expressed public support for that regulation.

  81. anonymous (again) says:

    Having a little bit to do with public commenting ;) let me make the following recommendations:

    It is not a vote or poll, although many special interest believe so.

    Make your comments count. Make specific points, questions and references.

    The EPA will likely post “supporting materials” along with the regulation text. View the “docket details” to see the supporting materials. Read and attack those materials as well as the regulation.

    Regulations.gov accepts attachments so you can begin now and you can attach supporting documents along with your comment document.

    The site will tell you what document formats are accepted. PDF and Word are probably best. If you upload a PDF, make sure it is searchable and not just a scanned image of the original. If you use Word, make sure it is the common .doc format and not .docx

    Mailed documents will be scanned into the same system as electronic comments. Probably no point in doing both, but check back on regulations.gov a few days after your submission to see if you can find your comments. The system uses a full text search engine, so the best way to find your comment is to look for a unique phase. The system will give you a tracking number, but I don’t believe that number is useful for you to find your comment once it is posted. If you can’t find your comment the help desk may ask for the tracking number.

    You comment will be posted back to the website after it is process by the EPA. They may not NOT reading the comment for content at this point. Only checking to make sure there is no reason not to post it. Frankly, I don’t know what they are look for if anything.

    With the mountain of comments expected it is likely EPA will hire a contractor to “process” the comments. They will first try to identify duplicates and near duplicates. Make your comments truly unique.

    It is possible in regulations.gov to comment on comments during the 60 comment period. You can look at the comments as they are coming in and respond to specific comments. This is not widely known and it is not clear to me how the EPA will deal with this.

    You can comment more that once. If you think of something after you comment, submit another one.

    Don’t wait until the last minute to submit a comment. If you have something you don’t want people to see and comment on I’d recommend mailing it in towards the end of the comment period. Make sure it gets there in time though.

    Finding the right link to submit your comment can be tricky. It will probably be best if we can identify the proper link and post it here.

  82. Indiana Bones says:

    Have to admit I find this more than pathetic. In ancient Rome there was a curious tradition of proposing absurd laws in order to excite the Senate into action. While political dialog is of certain value, dialog on subjects unworthy of debate is a waste of quality thought. We fervently hope that this is not the case here – as the proposal is so patently unworthy of even passing fancy.

  83. Mike Bryant says:

    New ruling from the EPA:
    If your social security ends in an even number you may exhale on even numbered days, odd on odd numbered days… starting… NOW!

    REPLY:
    Mike I’m counting on you to channel some o that energy towards making a formal comment to the EPA. – Anthony

  84. inferno says:

    This is unbelievable, co2 is a benefit to plants and our way of life and they want to regulate it? Actually no suprise there…

    However if they were aware of recent scientific developments they would know co2 was higher in 1940 and 1827 than today. co2 follows temperature and there’s good evidence that co2 was over 2,000ppm during the Medieval Warm Period:
    http://denialdepot.blogspot.com/2009/04/co2-levels-may-have-been-over-2000ppm.html

    We stand no chance of reaching anything like 2000ppm from emissions, so all this alarmism and regulation is ridiculous.

  85. tarpon says:

    Isn’t it time we just state the obvious, it’s not truth that is the goal, it’s power.

    I sent in a response for all the good it will do.

  86. Indiana Bones says:

    DAV (07:47:22) :

    “Maybe you should look at the path DDT took through the EPA and how the final ruling was achieved.”

    Dav, I think you forget that DDT is a toxic pesticide designed to kill insects. GHG at atmospheric mixing – is simply non-toxic. EPA’s proposal claims health hazard due to climate change – an utterly unproven theory.

    I’ll admit to being goaded into writing the EPA. I asked, as does Roger Pielke Sr., if they plan to regulate water vapor – the vast majority of greenhouse effect. I suggested they would need to shut down man-made lakes, rivers and streams; outdoor water fountains, evaporation ponds and towers. And then there is the problem of natural oceans, lakes and rivers.

    Absurd.

  87. Karl Been says:

    Wow. I take a few minutes to write a comment and I’m behind the curve by about 50 additional ones. Oh, well, here’s my take. As a close-in and daily observer of the political games in Washington, I agree with Fatman, et al, that this EPA action is just political theater. Obama will not allow the EPA to regulate CO2 because, if he does, he will own the consequences lock, stock, and barrel. He is participating in a political dance of wills with members of Congress. He wants a bipartisan passage of a cap-and-trade bill to provide him with cover and protect him and the Democrats from the outrage that will follow. Thus, the most effective means of preventing either regulation or cap-and-trade is through correspondence with your senators and representatives. So, get on them pronto.

  88. ralph ellis says:

    .
    Not exactly off-topic.

    But could anyone help support David Bellamy, because the media seems to have it in for him. Bellamy was the favourite BBC naturalist, because he sounded ‘earthy’ and ‘natural’, but then he became a a non-liberal Climate Change Denier – and was given the cold shoulder. That was ten years ago, but the London Guardian are still determined to destroy him (article entitled, ‘Bellamy the Bearded Bungler’…).

    http://www.guardian.co.uk/environment/georgemonbiot/2009/mar/16/monbiot-bellamy-climate-change-denier
    http://www.channel4.com/news/articles/world/are%20the%20glaciers%20melting/107930
    http://greenfyre.wordpress.com/2009/04/06/climate-change-lies-lies-and-more-lies/

    This is how far the Greens will go to perpetuate their propaganda – career (and life) destruction is just the appetiser, I’m sure.
    .

  89. Alan Chappell (02:25:40) :

    While visitors may be 120k per month as Charles pointed out, I’m thinking one document with 120,000 signatures might be more effective than 500,000 emails. We know they can’t even read 600 pages of legislation before they vote on it, so I don’t have much hope that they will read many emails…

    I propose we submit a single statement with maybe 10 irrefutable talking points, with supporting documentation… Point 1 would be that negative feedback dominates, which is the key issue.

    What are the other 9 points? Does anyone on this forum have the capability to write a form to begin submitting / collecting pertinent information (names, addresses, etc) once an agreeable statement is formulated? We could submit it to the media as well & across the blogosphere, to get signatures from those outside WUWT… I have some webspace available but don’t yet know how to write the code… Any takers?

    I see this as the end for America, by design, from within. Unfortunately, we can’t just go discover another “new world” and start over, we have to keep this America. I think it’s worth fighting for.

  90. ralph ellis says:

    Here is more from the Guardian’s George Monbiot:

    http://www.guardian.co.uk/environment/georgemonbiot/2009/feb/12/christopher-booker-george-monbiot-climate-change

    Take a look at ‘claim 3′, that ‘global temperature has not been decreasing since 1998′. The rebuttal is not wrong in itself, but highly disingenuous.

    .

  91. Ron de Haan says:

    Climate Heretic (22:04:48) :

    “This needs to be addressed on 2 fronts…

    Cap and Trade and the EPA Clean Air Act

    Both most be stopped or this battle is lost, and maybe even the war. Do not kid yourselves into thinking the bloated bureaucracy of DC will hinder the EPA, the regulations are drafted and the funding for enforcement is in place courtesy of the Stimulus Bill providing a 50% increase in funding or 3.6 Billion per year for two years on top of the 7.2 Billion operating budget, what do you think that funding was for?

    In either scenario the EPA will receive enforcement powers, and they intend to use them.

    The Chamber of Commerce has been subverted already as have the Oil Companies and Steel Workers Union. Utilities have been green lighted to pass the costs to consumers thanks to Sen Boxer neutering the Thune Ammendment.

    The units are all in place, the battlefield has been selected and the command to advance given.

    Lets send the Administration to Copenhagen empty handed, which is their greatest fear on the International Stage, an embarrassed President communicating the real will of Americans to the world”.

    Climate Heretic,

    You are right but your scope is not complete.

    1. You also have to address EPA regulation plans with regard to the Clean Water Act:
    http://heliogenic.blogspot.com/2009/04/epa-to-regulate-co2-via-clean-water-act.html

    2. We also have to address the other “Greenhouse Gases” listed by EPA.

    What to think about Methane?
    Restrictions would greatly effect our food industry and could ruin our farmers.

    There even could be limits on the numbers of wild life.

    Can you imagine a situation where the number of Bisons are reduced saving the climate?

    Maybe Anthony could produce an article discussing the other Greenhouse gases?

    I am also interested in the planned action undertaken by our political orientated skeptic friends.

    As Alan Garuda concluded in his sharp written comment:

    “It is a cruel despotism that has been unleashed on all Americans”. (and the rest of the world)

    http://factsnotfantasy.blogspot.com/2009/04/stop-epa-before-it-destroys-america.html

  92. Mark_0454 says:

    Karl Been (8:54),

    I think this goes back to the idea of scaring industry into accepting the cap and trade as the lesser of two evils. If industry presents a united front against this, it would take a lot of political courage for the administration to own this issue without any legislative cover. If they can pick off a few here and there…?

  93. Dane skold says:

    Re: litigating new EPA regs on CO2:

    Here is how it works. In order to have standing to litigate a regulation promulgated by a federal agency, one has to lodge a comment on the proposed regulation during the comment period. Then when the EPA disregards the objection to the rule, the judicial standard is to defer to the federal agency (separation of powers constitutional issue) unless the EPA’s regulation is “arbitrary and capricious.” All EPA needs is one expert to opine that there is a scientific basis for the regulation, and notwithstanding a thousand other voices opining otherwise, the EPA’s regulation stands.

    A court will not review the evidence and substitute its own opinion for that of the EPA. The EPA’s conclusion will stand.

    It would be a flight of fantasy to believe it would be better to litigate this after the fact than to fight before the reg is promulgated.

  94. ralph ellis says:

    And here is the London Guardian’s attempt to finally destroy David Bellamy. For US readers, David Bellamy was the BBC’s darling naturalist, before he became a Climate Change Denier.

    http://www.guardian.co.uk/environment/georgemonbiot/2009/mar/16/monbiot-bellamy-climate-change-denier

    This is how far the Greens will go in destroying the careers of their opponents.

    .

  95. Walter Cronanty says:

    I hope everyone here responds, especially those with more scientific knowledge than I [which is everyone]. While I have zero scientific knowlege, I know a little bit about politics. I do not want to discourage anyone, but facts in politics are not the same as facts in science [well, I used to believe that until AGW, but that is the spirit in which this is written]. My prediction is that nothing submitted will change any policy. Let’s look at the cast of characters in charge:
    President Obama was elected on a platform of cap & trade, global warming, no nukes, no coal, no drilling, etc. He will not change.
    Lisa Jackson is the head of the EPA – and here is what the “enviros” said about her after her nomination. She had been the head of NJ’s EPA:
    “Green groups say Jackson also pushed Corzine toward tougher measures on climate and energy. The Global Warming Response Act, which the governor signed into law in July 2007, aims to reduce the state’s greenhouse-gas emissions to 1990 levels by 2020 and to 80 percent below 2006 levels by mid-century.

    The plan was released in mid-December, and enviros say it’s strong. It calls for 90 percent of new development to be in areas already served by public infrastructure, a moratorium on new coal-fired power plants, increased public transit, and a requirement that all buildings constructed after 2030 to have net-zero energy consumption. (The trick will be getting the legislature to sign off.)”
    Carol Browner is Obama’s “Assistant to the President for Energy and Climate Change.” The following is from the wikipedia entry on Ms. Browner, and is in keeping with other articles I’ve read:
    “According to an article in The Washington Times, up until the time when Browner was tapped by the Obama administration to fulfill the role of Climate Czar, she was listed as one of 14 leaders of a socialist group’s Commission for a Sustainable World Society, which calls for “global governance” and says rich countries must shrink their economies to address climate change. By January 8, 2009, Mrs. Browner’s name and biography had been removed from Socialist International’s Web page, though a photo of her speaking June 30 to the group’s congress in Greece was still available.

    Browner claimed that the George W. Bush administration was “the worst environmental administration ever.”[8] She has also claimed that global warming is “the greatest challenge ever faced”.[11]

    Again, I hope that all of you who have something useful to say to the EPA will say it. It will serve as an historical record when we look back and say “What in the hell did we do that for?” But, there already is “consensus,” where it matters, for vast regulation of CO2, with the result being that industry will prefer, and ask for, cap & trade. Sorry to be so pessimistic, but elections have consequences. Special interest groups have to be paid back. Anti-capitalism is more important than science.

    Oh yeah, one more thing. All of those “green energy” jobs we’re going to create? You know, like Spain? Obama’s model? Please review http://www.juandemariana.org/pdf/090327-employment-public-aid-renewable.pdf.
    From the executive summary:
    “Optimistically treating European Commission partially funded data1, we find that for every renewable energy job that the State manages to finance, Spain’s experience cited by President Obama as a model reveals with high confidence, by two different methods, that the U.S. should expect a loss of at least 2.2 jobs on average, or about 9 jobs lost for every 4 created, to which we have to add those jobs that non-subsidized investments with the same resources would have created.”

  96. Richard M says:

    I agree with karl Been. The real power will come from elected officials. Simply write your congressman and state that EPA passage of such a ridiculous finding or taxing the air you breathe through CapnTrade will mean you will have to find someone else to vote for in the next election. It may help to mention the Rasmussen Report linked to earlier.

  97. Ed Scott says:

    [Jonathan Adler, April 18, 2009 at 12:28pm]

    http://volokh.com/

    EPA Issues Endangerment and Contribution Findings:

    Yesterday, as expected, the U.S. Environmental Protection Agency issued a proposed finding that emissions of six greenhouse gases, including carbon dioxide, pose a threat to public health and welfare due to their contribution to global warming. The EPA further found that the emission of such gases from motor vehicles contribute to dangerous concentrations in the atmosphere. The EPA announcement is here.

    The proposed findings will now go through a 60-day public comment period. Shortly thereafter, the findings will be finalized. Industry and anti-regulatory groups will almost certainly challenge the findings in court, and their legal challenges will almost certainly fail. Even if one doubts the accumulated scientific evidence that anthropogenic emissions of greenhouse gases contribute to climate change and that climate change is a serious environmental concern, the standard of review is such that the EPA will have no difficulty defending its rule. Federal courts are extremely deferential to agency assessments of the relevant scientific evidence when reviewing such determinations. Moreover, under the Clean Air Act, the EPA Administrator need only “reasonably . . . anticipate” in her own “judgment” that GHG emissions threaten public health and welfare in order to make the findings, and there is ample evidence upon which the EPA Administrator could conclude that climate change is a serious threat. This is a long way of saying that even if climate skeptics are correct, the EPA has ample legal authority to make the endangerment findings.

  98. Ron de Haan says:

    You have to read it to believe it:
    “Governments are political bodies. And the IPCC’s function is – and always has been – to provide an appearance of scientific justification for political policies”.

    TO PROVIDE AN APPEARANCE OF SCIENTIFIC JUSTIFICATION.

    This remarkable statement is not made by a Skeptic but by an IPCC Official.
    Other statements are as much revealing:

    “There has been no mathematically significant rise in mean global temperature (MGT) since 1995. MGT has not again achieved the peak it had in the El Nino year of 1998 and has been static or gradually falling since 2001. Furthermore, the ‘fingerprint’ of enhanced greenhouse effect is greatest warming at altitude in the tropics, but independent measurements from weather balloons and from satellites both show slight cooling at altitude in the tropics. Meanwhile, atmospheric carbon dioxide concentration and anthropogenic emissions have continued to rise”.

    Let’s send this article to Obama and EPA and we have fixed the Hoax.

    Richard S Courtney Says:
    April 17th, 2009 at 3:10 am

    Of course the next IPCC report has to be delayed.

    The IPCC is the InterGOVERNMENTal Panel on Climate Change. Governments are political bodies. And the IPCC’s function is – and always has been – to provide an appearance of scientific justification for political policies.

    That appearance becomes progressively more difficult to sustain with each year the globe fails to warm.

    The IPCC Reports were originally scheduled for publication at 5-year intervals. But a 5-year period after the IPCC’s Fourth Assessment Report (AR4) would have to report cessation of global warming in the period since the AR4. There has been no mathematically significant rise in mean global temperature (MGT) since 1995. MGT has not again achieved the peak it had in the El Nino year of 1998 and has been static or gradually falling since 2001. Furthermore, the ‘fingerprint’ of enhanced greenhouse effect is greatest warming at altitude in the tropics, but independent measurements from weather balloons and from satellites both show slight cooling at altitude in the tropics. Meanwhile, atmospheric carbon dioxide concentration and anthropogenic emissions have continued to rise.

    The warming period from ~1970 to ~2000 was sandwiched between the cooling periods of ~1940 to ~1970 and ~2000 to the present. The changes between these warming and cooling periods coincide with phase reversals of the Atlantic Multidecadal Oscillation (AMO) and, therefore, it seems that the present lack of warming is likely to continue for the next two decades.

    The governments served by the IPCC can only hope that global warming resumes prior to the next IPCC report. Failing that, the next IPCC Report needs to be delayed until the political objectives – such as those the governments hope to achieve at Copenhagen in December – are obtained.

    Richard

    See the article here: http://climateprogress.org/2009/04/15/ipcc-2014-fifth-assessment-irrelevant/#comment-39812

  99. Stefan says:

    @Richard M

    Indeed, the understanding of complex systems appears in its infancy. The late Michael Chrichton made that very point; environmentalists don’t understand complexity, and they don’t understand the inherent unpredictability of the future.

    What suppose we are left with is a bit of data about the planet which seems to get interpreted from a wirldview that bears some similarity to NeoRomantic, New Age, Pagan notions about “natural balance” and Nature’s cycles and spirit-as-Nature.

    All of these notions have some, some validity—-Nature is an awsome force, and for some people the closest thing they can identify to a God or spiritual radiance, but none of that needs any science. Those feelings exist in their own right for some people. It is like asking scientists to prove the existence of Love. It is not their field.

  100. Martin Mason says:

    Ron

    The article that you link is devastating. It agrees with another article I read by two German physicists. Is it correct though? If so we are being subject to the greatest deception in the history of mankind and we can do nothing about it

  101. tarpon says:

    “…six key greenhouse gases—carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6)” — From the original page.

    Isn’t this a serious turn of events to include all these other chemicals in one subject of GHG emissions? Is this to just obfuscate and deflect attention from what they really want, control over energy use? Or is this the result of they know that the CO2 argument is so seriously debunked that it needs support?

    Other than the obvious hoax of the ozone hole caused by CFCs, I have not heard anyone address these added chemicals. So can someone address these other gases that have just mysteriously appeared in the report.

    I believe, after quickly reading through their material, they may have set a trap. We have been so focused on CO2 that we may not see the trap.

  102. Ron de Haan says:

    When Anthony published his statistics about WUWT hits by countries I have noticed that Denmark scored relative high with over 35000 visits.

    Obviously it has payed off:
    Only 34% of the population believes Global Warming is caused by humans.
    (I think the recent winter made a contribution as well)

    http://www.rasmussenreports.com/public_content/politics/environment/energy_update

  103. Drew says:

    The comments provided to the EPA are nice but will not stop a regulatory agency from finalizing the proposed ruling. We need a coordinated, significant legal challenge to the proposed ruling. The EPA findings will not hold up in a court of law.

    I just created http://www.stopepaonco2.com
    It will take me a few days to get the website up and running.

  104. Walter Cronanty says:

    Ron de Haan (09:48:57) : “Let’s send this article to Obama and EPA and we have fixed the Hoax.”

    Ron, Ron, Ron. I hope you were being sarcastic. I have read many of your posts. You appear to be very intelligent and knowledgable about the science. But what we are talking about has very little to do with science. It has everything to do with politics, covered with a thin veneer of psuedo-science. AGW is the greatest camouflage the left has ever had. That is not to say that it started out that way. I will give the benefit of the doubt to those who raised questions in the beginning. But now? No, no time for questions now. This is the greatest opportunity for the left since the Great Depression. Science means nothing to them. Please, keep up the good fight, for it is posts like this one and comments like yours that keep me informed. But please, for your own sake, don’t believe for a minute that a “study” or an “article,” or a series of studies or articles, will ever change anyone’s mind in the current US Administration.

  105. Kath says:

    Calling CO2 a pollutant has me wondering if I am in some sort of strange non-rational parallel universe.

    Politician’s aren’t stupid. I believe most do not believe in AGW. They believe in getting elected and staying in power. Since the flavour du jour happens to be AGW, they will push AGW agendas. It has nothing to do with science and, as a result, using science to change minds will probably not work. But if there is a grass-roots movement to vote them out of office, they will listen.

  106. Ron de Haan says:

    Martin Mason (09:53:14) :

    “Ron

    The article that you link is devastating. It agrees with another article I read by two German physicists. Is it correct though? If so we are being subject to the greatest deception in the history of mankind and we can do nothing about it”

    Yes, but we knew this for a long time did we not!

    This is about the control over population based on the lunatic perception that human kind is using the resources of five earths.

    This is a really sick perception and like the AGW Hoax it is not true.

    This is a frontal attack on human kind.

  107. Fat Man says:

    @ Keith Thompson MD (04:23:14):

    “Does anyone know the legal trajectory that will occur? Who will sue the EPA and in what venue? What standards do their findings have to meet?

    “Seems like the courts will be the best forum to bring down this craziness.”

    I am not an administrative law jock, but I believe that any decision by the EPA can be the subject of an action in Federal District Court (5 USC 701) by an adversely affected party which in this case, is going to be legion. I think the action can be brought anywhere in the US, but the Court system will consolidate the cases in one court room.

    Any final decision by a District court may be appealed to Circuit Court of Appeals, which will assign the matter to a three judge panel chosen by lot from the numerous judges in that Circuit. That panels decision may be reheard by the entire court of appeals.

    That decision may be appealed to the US Supreme Court (SCOTUS). SCOTUS usually has discretion as to whether they will hear a matter. They generally hear less that 100 of the thousands of matters filled with them every year, but given the enormous potential impact of an EPA ruling, I doubt that they will duck.

    I don’t want to discuss standards of proof or review because most of that is like playing soccer with ripe melons. The statute (5 USC 706) empowers the District court to set aside agency actions that are arbitrary and capricious, unsupported by substantial evidence, or unconstitutional, or which exceed its statutory jurisdiction.

    According to the WSJ today:

    On a conference call Friday with environmentalists, EPA officials stressed they would take a go-slow approach, holding two public hearings next month before the findings are official. After that, any new regulations would go through a public comment period, more hearings and a long review.

    “Whatever the process it, it will be the time-honored and ordinary process of soliciting public input,” an EPA official said.

    I would say that each step of the process would take at least a year for the agency work, two years for the district court case, a year in the court of appeals, and a year at SCOTUS — say 5 years overall. So I think we are looking at 10 years at a minimum.

    No the courts are not a good place to resolve these questions because they are composed of the wrong people (scientific and mathematical illiterates), having the wrong training and experience (law school and legal practice), and with the wrong incentives (no downside in their mistakes, no upside if they are right) to make a decision. Courts are good at throwing cat burglars and drug dealers in jail and settling disputes over business deals. They are not good at this sort of world wide social reconstruction and they should not begin to try.

  108. LAShaffer says:

    Cliff Huston (20:04:59) :

    “What, the number one greenhouse gas is left off the list?

    REPLY: Water vapor, of course, but its a natural part of the earth’s environment and cycles, so regulating it would be just crazy, oh, wait….”

    Sloppy science or pure propaganda?
    Courtesy of the federal government:
    http://www.fueleconomy.gov/feg/contentIncludes/co2_inc.htm

    “How can 6 pounds of gasoline create 19 pounds of Carbon dioxide?

    It seems impossible that a gallon of gasoline, which weighs about 6.3
    pounds, could produce 20 pounds of carbon dioxide (CO2) when burned.
    However, most of the weight of the CO2 doesn’t come from the gasoline
    itself, but the oxygen in the air.

    When gasoline burns, the carbon and hydrogen separate. The hydrogen
    combines with oxygen to form water (H2O), and carbon combines with
    oxygen to form carbon dioxide (CO2).

    CO2 molecule with one carbon atom (atomic weight 12) and two oxygen
    atoms (atomic weight of 16 each)A carbon atom has a weight of 12, and
    each oxygen atom has a weight of 16, giving each single molecule of CO2
    an atomic weight of 44 (12 from carbon and 32 from oxygen).

    Therefore, to calculate the amount of CO2 produced from a gallon of
    gasoline, the weight of the carbon in the gasoline is multiplied by
    44/12 or 3.7.

    Since gasoline is about 87% carbon and 13% hydrogen by weight, the
    carbon in a gallon of gasoline weighs 5.5 pounds (6.3 lbs. x .87).

    We can then multiply the weight of the carbon (5.5 pounds) by 3.7, which
    equals 20 pounds of CO2! ”

    I have so many problems with this piece of government “work” that I hardly know where to begin. But let’s start with the first sentence and the word “create”, which may be appropriate in a discussion of theology, but has no business being used in an explanation of any phenomenon based on physics or chemistry. Then there is the use of (very) loose averaging, which apparently led to the CO2 gaining a pound between the first and second sentence. Then there is the assumption of a pure C-H mixture (not possible), and the further assumption of only two by-products forming, which is total fiction. And why is there an exclamation point at the end of the last sentence if this isn’t propaganda? When is the last time anyone read an abstract or research paper that used exclamation points? Amazing.

    I will forget all of that for the moment and point out a few things that were, no doubt, excluded from this piece intentionally.

    Using exactly the same proportions and math procedures, this hypothetical gallon of gasoline also released 7.4 lbs. of new H20 into the atmosphere. Since water vapor is considered the more powerful GHG of these two, does that mean I can obtain a government grant to study the effects of anthropogenic water vapor, or has it already been done? If anthropogenic CO2 is now considered a pollutant, shouldn’t we assign the same status to anthropogenic water vapor? What about H2O sequestration technologies? I can almost smell the research grants pouring in. This might be a good subject for the DHMO website to look into.

    All joking aside, why do I get the feeling that the true reason for all of the math in this piece is to obfuscate a basic fact? Regardless of the weight of the outputs, the net effect is the addition to the atmosphere of 6.3 lbs. of mass, and the reduction of the mass of the earth’s crust by exactly the same amount. So the total heat capacity of the atmosphere was increased, and an additional one degree of freedom was added (through molecular bonding) to ~27 lbs of O2, at the same time the total heat capacity of the of the earth’s crust was reduced . . Seems like they just might cancel each other out. And what about the ~107 lbs. of nitrogen that also cycled through that engine with every gallon of gas?

    Which brings up another vaguely nagging question. How long does H2O remain in the atmosphere before molecular dissociation versus CO2? I mean, left to it’s own devices in the atmosphere, the CO2 will eventually be broken back down, via the carbon cycle, into C and O2. The atmospheric free oxygen will be returned from whence it came, which seems like a good thing, if you like breathing. But what about the new water? Viewed from this perspective, carbon sequestration starts to sound like an attempt at suicide, doesn’t it?

    I think it’s about time to put this endless debate about CO2 to rest, once and for all. I have been saying for years now that the atmosphere cannot be treated as if it were a closed system. In the example in the above article, the total mass of the earth was not changed by even 1 mcg, we simply changed the phase state of molecules which came from underground, at least in this example. However, we did, in a very short period of time relative to natural processes, release large amounts of stored chemical energy from beneath the surface by converting it to thermal energy above the surface, releasing it to space, and at the same time, reduced the total heat capacity of the earth’s crust. Since the ability of gasses to store thermal energy relative to solids and liquids is virtually null, the only logical outcome is also null, or a cooling effect.

    This is sleight-of-hand posing as science.

  109. Martin38 says:

    I like being a “tree hugger”. I have succesfully turned 10 acres of pasture into forest on my own. Now, how can we get CO2 concentrations up to around 800 PPM so my trees will grow faster?

  110. MarkyMark says:

    It became necessary to destroy the village in order to save it.

  111. Pofarmer says:

    I would say that each step of the process would take at least a year for the agency work, two years for the district court case, a year in the court of appeals, and a year at SCOTUS — say 5 years overall. So I think we are looking at 10 years at a minimum.

    And, in the meantime, economic progress grinds to a halt because nobody knows what the final regulations will be. and aren’t willing to expand or build not knowing.

    Someone up thread mentioned buildings with no net energy usage by 2030. I suppose that will be possible, because there surely won’t be many being built, and the ones that are built will be REALLY expensive.

  112. Mike Bryant says:

    “Someone up thread mentioned buildings with no net energy usage by 2030. I suppose that will be possible, because there surely won’t be many being built, and the ones that are built will be REALLY expensive.”

    I think those energy free buildings will get here much quicker. Of course they will be filled by squatters and they won’t be generating any rents.

  113. timbrom says:

    ralph ellis

    It’s actually the Manchester Guardian. Or Grauniad.

  114. nvw says:

    There appears to be a level of misunderstanding here about the role of the EPA. They are a government department that is staffed at the upper levels by the current administration. In the previous eight years, for right or wrong the past administration was able to steer the interpretation of the law. Now, with the changing of the guard, there is a new set of apparatchiks pulling the levers of power.

    In the CO2 = pollution the way we got to this point is: 1) In the 1970’s the environmental movement convinced Congress to write laws protecting Clean Air. 2) That law authorizes the EPA to regulate pollutants emitted into the air. Fast forward to the new millennium…in order to use the existing laws a few clever lawyers with the cooperation of some scientists convinced the courts that because CO2 = pollution it is now appropriate that the EPA has the right to regulate its emission into the air using the existing laws.

    That some commenters (eg Dane skold (09:17:36), DAV (07:47:22)) express futility of changing the EPA reflects a world-view realizing that the fix is already in. This is precisely the reason why the real focus should be to change the source Clear Air laws. If the law clearly and unequivocally states that CO2 is NOT a pollutant, then no matter who runs the EPA or whoever sits on the Supreme Court there is no further basis for discussion – game over.

    Look, by all means write to the EPA on these proposed regulations, but if you really want to address the root cause of the problem – its the Clean Air act that needs rewriting, so when you contact your Senators and Representatives tell them that you want the law modernized for the 21 century to amongst other things, to clearly state that CO2 is not a pollutant.

  115. Ron de Haan says:

    Walter Cronanty (10:11:59) :

    “Ron de Haan (09:48:57) : “Let’s send this article to Obama and EPA and we have fixed the Hoax.”

    Ron, Ron, Ron. I hope you were being sarcastic. I have read many of your posts. You appear to be very intelligent and knowledgable about the science. But what we are talking about has very little to do with science. It has everything to do with politics, covered with a thin veneer of psuedo-science. AGW is the greatest camouflage the left has ever had. That is not to say that it started out that way. I will give the benefit of the doubt to those who raised questions in the beginning. But now? No, no time for questions now. This is the greatest opportunity for the left since the Great Depression. Science means nothing to them. Please, keep up the good fight, for it is posts like this one and comments like yours that keep me informed. But please, for your own sake, don’t believe for a minute that a “study” or an “article,” or a series of studies or articles, will ever change anyone’s mind in the current US Administration.”

    Walter,

    I you are correct, it was sarcastic. Read the article about the IPCC I have posted.
    I have plugged the http://green-agenda.com and the Agenda 21 http://www.un.org/esa/sustdev/documents/agenda21/index.htm on many occasions.

    This is political and it is about control over human kind.

    There are people who believe humanity is in need of five earths to generate the resources to maintain a global industrialized society compared to the USA and Europe. Those people are wrong. This is as much a hoax as the AGW Fraud.
    I am also convinced that the current crises is used to create momentum for the coup that is currently underway.

    As the last G20 meeting has failed, the USA started the money presses (1400 billion dollars to print) and the Chinese stopped buying US debt we can expect a collapse of the International Monetary System by the end of this summer.

    People will have a lot on their minds when this happens and the political mafia in this Administration will take advantage of the havoc they have created.

    Time to fight back.

    Use your Constitution!

    Save the Republic before it is too late:
    http://www.americanthinker.com/2009/04/saving_the_republic.html

  116. Lee Kington says:

    I generated a blog entry to visually demonstrate what the CO2 fuss is about. Since it requires use of images I am unable to recreate it here as a response.

    The title of the page is:
    EPA…. A Step Toward Carbon Caps & Tax

    The graphics are about pre-industrial and current CO2 levels.

    The entry can be found here..
    http://penoflight.com/climatebuzz/?p=503

  117. Drew says:

    I respectfully disagree. I believe that the courts are the ONLY place where we can achieve corrective action and adequately address the merits of either side of the issue.

  118. Highlander says:

    The whole ploy here is just this:
    .
    — They —the NWO/AGW CONTROL FREAKS— KNOW that the Earth is getting cooler.
    .
    — They KNOW that sun spot frequency has =EVERYTHING= to do with planetary atmospheric thermal dynamics.
    .
    — They KNOW that WE KNOW, but THEY DON’T CARE.
    .
    — The game afoot is just this: EVEN IN THE FACE of all the evidence, they will make the law and enforce it.

    But EVEN THOUGH the temperature is falling and will continue to do so naturally, THEY will claim success even though what was forced upon us HAD ZERO EFFECT.

    They will VOCIFEROUSLY proclaim success and demand EVEN MORE restrictions.

    It is time to stand up to those idiots. Sooner or later we —all of us— are going to have to stand up to those jerks, come what may.

  119. Dave Wendt says:

    For those of you clinging to the faint hope that politicians can be enlightened to the truth of the state of the global climate, I’d like to recommend this NPR interview with Rep. Henry Waxman, who is unfortunately a powerful figure in the present Congress. http://www.pbs.org/kcet/tavissmiley/archive/200904/20090413_waxman.html
    The following question and answer is probably the money quote, but all of it is depressingly enlightening about the mindset we’re dealing with.
    But there is this debate, however you break it down, about whether or not there really is global warming, and there are people who scoff at Al Gore and others who make that case, and you all the time, for making that case. Talk to me about where we are in that debate on the science, because there is this tension around this.

    Waxman: Well, there have been scientists brought together to see if they could figure out the science and make it clear whether this is a danger or not, whether it’s a danger that’s a great one or one that we can postpone for a while, and the overwhelming consensus of all the leading scientists that have looked at this issue is there is a warming of the planet, it’s manmade, caused by our burning of carbon fuels, and it’s happening faster than anybody ever thought it would happen.

    We’re seeing the reality of a lot of the North Pole starting to evaporate, and we could get to a tipping point. Because if it evaporates to a certain point – they have lanes now where ships can go that couldn’t ever sail through before. And if it gets to a point where it evaporates too much, there’s a lot of tundra that’s being held down by that ice cap.

    If that gets released we’ll have more carbon emissions and methane gas in our atmosphere than we have now. We see a lot of destruction happening because of global warming, climate change problems, so we’ve got enough warning signals and enough of a scientific consensus to take this seriously.

  120. Fat Man says:

    Drew (12:29:18) : “I respectfully disagree. I believe that the courts are the ONLY place where we can achieve corrective action and adequately address the merits of either side of the issue.”

    Because?

  121. ralph ellis says:

    I like this analysis of the Greenhouse effect.

    Quote:
    If glass lets visible wavelengths of sunlight in but doesn’t let invisible long-wavelengths (infrared) out, thus raising the temperature inside, then glass thermometers have been misleading us for centuries. According to the greenhouse theory, glass thermometers necessarily register an extra “greenhouse effect,” and not the true temperature.
    End quote

    Any flaws in this analysis?
    http://tech-know.eu/uploads/ACCInput.pdf

    .

  122. pyromancer76 says:

    I see a number of tasks presented to those of us who are willing. First and foremost is to compose an intelligent scientifically rigorous response to the EPA with copies to our Senators and Representative, and to editors of newspapers and other media. This, in itself is no small task.

    If we are to do this knowledgably, we probably should read the “Pre-publication copy of the Administrator’s Proposed Endangerment and Cause or Contribute Findings…” (133 pp), the “Technical Support Document for the Proposed Findings (171 pp), “Massachusetts v. EPA” Supreme Court Case, Transcript of Oral Arguments 11/29/06 (70 pp) and the Opinion of Court 4/2/07 (66 pp). Perhaps chinks in the marxist-armor might be found in the latter two.

    Second, is to address the Clean Air Act immediately and to ask for (demand) its revision.

    I have no doubt that Obama was elected President for this governmental-authoritarian purpose as well as for the purpose of bankrupting western/developed world affluence. He is not a natural born citizen as required by our Consitution; his father was a British Empire/then Kenyan Citizen and his father was a marxist Muslim. His mother also was a marxist. From my research, global financial institutions bankrolled him from the beginning for their own purposes, which he has fulfilled by gifting them everything they (CEOs/top management) want and imposing no new regulations, the lack of which got us into this financial mess in the first place.

    Furthermore, corruption and fraud got Obama nominated and elected, not a majority of honest American voters.

    I believe this will be the fight of our lives. One of my requests is for us not to call those in power, those attempting to promulgate these regulation “liberals”. They have no liberal ideals — only authoritarian, progressive-marxists. This effort will take a concerted partnership by conservatives and liberals — there is no one else with the best interest of America at heart. It is very difficult for conservatives not to use the term “liberal” as an epithet for everything they dislike, but it is time to bury the hatchet and recognize your allies. Both classical and modern liberals believe fervently in capitalism — that also provides a safety net. It is about the latter liberals and conservatives most disagree. Liberalism does not support the welfare state and it does not support government boondoggles like cap-and-trade or declaring essential chemicals for life pollutants.

    I begin my reading.

  123. Car stickers.

    A presentation we can agree on, that we can take around to talk to groups of people about “real climate science”. Assemble an “Idiot’s Guide to Climate Science” IN PICTURES since people are being conned because they don’t know or don’t connect about CO2 feeding plants – etc. A picture is worth 1000 words.

    Get behind Monckton’s letter: but if so, then also, we need to list here all the false criticisms AGW has massed against Monckton, so we can have the answers to the AGW slanders at hand.

    Pray. Think positive. Reach for your highest. Be proud to stand up and be counted.

    Ask with compassion why all the scientists and science teachers who know the truth about CO2 and scientific method, are not standing up.

  124. Drew says:

    Fat Man (14:31:55) :

    Drew (12:29:18) : “I respectfully disagree. I believe that the courts are the ONLY place where we can achieve corrective action and adequately address the merits of either side of the issue.”

    Because?

    Because we’re not going to win a scientific debate outside of the courtroom since they determine who wins. They control the administrative and legislative side of the house and, as mentioned many times even on this post, this is all politics – not science. If we’re going to force science to form the basis for the regulations, then the court of law is perhaps the only place where we can get a fair shot.

  125. Walter Cronanty says:

    Ron de Haan (12:09:24) : “I you are correct, it was sarcastic. ”
    Sorry for doubting you, Ron.
    Drew (12:29:18) :

    “I respectfully disagree. I believe that the courts are the ONLY place where we can achieve corrective action and adequately address the merits of either side of the issue.”

    As an attorney who has been practicing for over 25 years, taught as an adjunct at a law school, and practiced before all levels of federal and state courts – I disagree. With the burden one would have to overcome for a court to overrule the rule making abilities of a regulatory body [arbitrary and capricious] and the absolute inundation of poor science on this subject, the Sup. Ct. could be sitting in the middle of a blizzard in August in Washington DC, and I would be doubtful of a favorable outcome. Unfortunately, I believe that only good science, such as demonstrated here, together with somehow getting the MSM’s attention, together with political action will change this country’s current course. Someone said on another post here that companies will make the EPA promulgate draconian anti-CO2 rules, and that, coupled with the cost and no catastrophic AGW will finally wake up the US electorate. If that is the only way, we’re in for a long, expensive ride.

  126. Joel Shore says:

    Ralph Ellis says:

    Quote:
    If glass lets visible wavelengths of sunlight in but doesn’t let invisible long-wavelengths (infrared) out, thus raising the temperature inside, then glass thermometers have been misleading us for centuries. According to the greenhouse theory, glass thermometers necessarily register an extra “greenhouse effect,” and not the true temperature.
    End quote

    First of all, it is well-recognized that while there is a rough analogy between actual greenhouses and the atmospheric greenhouse effect, the analogy does not extend to the actual mechanism for the trapping of the heat: i.e., in an actual greenhouse, most of the heat trapping is due to trapping of the air itself and thus preventing convection whereas the atmospheric greenhouse effect is due to the trapping of radiation. See “Real Greenhouses” here for further discussion: http://en.wikipedia.org/wiki/Greenhouse_effect

    Second of all, in regards to the thermometer: To the extent that glass does allow through visible radiation but does not allow out infrared radiation, this should not have an effect on a correctly-taken temperature reading. Basically, the main mechanism by which a thermometer comes into equilibrium with its surroundings is by conduction of heat. If you put a thermometer in direct sunlight then indeed the solar radiation can play a role in skewing the resulting reading. This is just a reason, however, why a thermometer should not be placed in direct sunlight: the reading obtained in such a case does not accurately represent the actual temperature of the air, a fact that I think is fairly well-known.

    Any flaws in this analysis?
    http://tech-know.eu/uploads/ACCInput.pdf

    There is almost nothing right in that analysis.

  127. Mark T says:

    ralph ellis (14:47:11) :

    I like this analysis of the Greenhouse effect.

    You shouldn’t, it is rather moronic, or at least, their thermometer example is moronic. First, thermometers don’t actually measure temperature. They typically measure the expansion of a liquid, usually either mercury (for medical) or alcohol (for the one on your porch), that results from heating. Basically, the output of this type of thermometer is a volume measurement. That measurement is converted to temperature through a calibration. So, even if there is some greenhouse effect with the thermometer, it is accounted for in the calibration.

    Mark

  128. matt v. says:

    Notice that carbon dioxide is not included as part of the air quality index.

    http://www.ec.gc.ca/cas-aqhi/default.asp?Lang=En&n=065BE995-1#calculated

  129. Dane Skold says:

    Dead right @Walter.

    As an attorney, I’ve contended with FDA in the lair of the dragon on a citizen’s petition for rule making.

    One of the FDA’s “experts” on the issue at the meeting spouted a belief that had been demonstratively proven false repeatedly. He was not current on the literature. It was a challenge not to laugh at his ignorance, but that one doesn’t laugh out loud at the witness, judge, and jury rolled into one.

    At the public hearing on the petition, the FDA’s chair admonished one of the FDA’s chosen panel members that his comments were on the record and would be published. The comment? If the petition were granted, it would moot his ongoing research — funded by the NIH. (One of his published gems is that smoking prevents arthritis.)

    Outcome? FDA conceded that the substance had a demonstrably beneficial effect, but denied the petition on the grounds that it lacked adequate scientific support.

    Litigating an administrative regulation is not civil litigation where the preponderance of evidence prevails. If there is any evidence supporting the regulation, the courts will not override the executive branch regulation. In other words, if one scientific source supports the reg despite nine refuting it, the regulation stands. Since there are published papers concluding that AGW exists, regulations built on such papers meet the APA standard.

    It is not enough alone to be correct on the merits.

    It is a political issue, and must be defeated at that level if at all.

    It’s going to be a tough 3 and 3/4 years.

  130. nvw says:

    My concern with the courts is that they are filled with lawyers and judges. Neither are particularly well versed with science. As Fat Man (10:31:38) commented above, courts are ideal for deciding whether a criminal goes to jail or settling business disputes, but their experience with science is limited. Besides, the trouble with the legal system and the reason that environmentalists have this country tied up in knots is that it only takes one environmentalist to file a law-suit. Inevitably the case gets taken to some favorable venue – for example the Ninth Court of Appeals in San Francisco, to seek a favorable judgment.

    Nothing illustrates how our environmental laws are being abused more than this CO2 = pollution. Again, the way to solve this is to demand our legislators to definitively rewrite the law.

  131. Dave Wendt says:

    Richard111 (01:07:12) :
    It will require a police force larger than the military to police this.
    How will they decide who is guilty of which emissions by how much?
    Welcome to Brave New Worlds.

    You might want to reference this document http://www.dtic.mil/whs/directives/corres/pdf/140410p.pdf

    It supercedes a directive from the Clinton era that dealt with overseas deployments of civilian contractors and unlike this one made no mention of ” restoration of order

    Richard111 (01:07:12) :
    It will require a police force larger than the military to police this.
    How will they decide who is guilty of which emissions by how much?
    Welcome to Brave New Worlds.

    You might want to reference this document, http://www.dtic.mil/whs/directives/corres/pdf/140410p.pdf
    It supercedes a directive from the Clinton years that dealt with overseas deployments of civilian contractors and unlike this one made no mention of “restoration of order” or “stability operations” which seem to be key features of the new one. Check the date of issuance as well, they’ve obviously been giving this some thought for quite a while. Given Obama’s calls for a civilian defense force to rival our military during the campaign and the recent DHS document on “rightwing extremists” i e anyone who disagrees with the Big O, it’s becoming very apparent that they plan to brook no insubordination from we lowly peons out here in flyover land.

  132. old construction worker says:

    Walter Cronanty (16:07:52) :
    ‘As an attorney who has been practicing for over 25 years, taught as an adjunct at a law school, and practiced before all levels of federal and state courts – I disagree.’
    How would the Data Quality Act play into EPA ruling and have they violated the Act?
    Martin38 (10:39:30) :
    ‘I like being a “tree hugger”. I have succesfully turned 10 acres of pasture into forest on my own. Now, how can we get CO2 concentrations up to around 800 PPM so my trees will grow faster?’
    Do you have any endanger plant life on your tree farm? Wouldn’t any attempt to regulate CO2 be counter intuitive of the endanger species act?

  133. Mike Bryant says:

    “old construction worker (17:20:27) :
    Do you have any endanger plant life on your tree farm? Wouldn’t any attempt to regulate CO2 be counter intuitive of the endanger species act?”

    OCW,
    That is simply brilliant! Does anyone have a list of endangered plants?? I’ll start planting right away.
    Mike Bryant

  134. kim says:

    Another thing that is obvious, but virtually unmentioned, is that the animal part of the biosphere is almost completely dependent upon the plant part of the biosphere. What’s good for the plants is good for the animals. Rising CO2, up to a limit is good for everything. Who could ask for anything more?
    ===========================================

  135. Nasif Nahle says:

    Normal CO2 Levels. The effects of an increased level of CO2 on an adult person in good health can be summarized as follows:

    Normal outside levels: 350 – 600 ppmv.

    Acceptable levels: up to 600 ppmv.

    Stiffness and odors: 600 – 1000 ppmv.

    Data provided by the Occupational Safety and Health Administration (OSHA):

    Standards: 1000 ppmv.

    Stupor: 1000 – 2500 ppm.

    Maximum allowed concentration in an 8 hour working period: 5,000 ppmv.

    Extreme and Dangerous CO2 Levels:

    Nausea and increase of the cardiac and respiratory frequencies (from oxygen deficiency): 30,000 ppmv.

    The above plus headaches and sight impairment: 50,000 ppmv.

    Unconsciousness and death: 100,000 ppmv (OSHA).

  136. Nasif Nahle says:

    Carbon dioxide is an essential gas for living beings, from bacteria to mammals, including plants. The declaration on CO2 as a toxic pollutant dangerous for life is plainly pseudoscience similar to dogmatism. EPA declared to Media that they reached that conclusion after a “meticulous” research by scientists. I would like who those scientists are, because they are demonstrating their illiteracy on biological issues.

  137. Ron de Haan says:

    matt v. (16:47:27) :

    Notice that carbon dioxide is not included as part of the air quality index.

    http://www.ec.gc.ca/cas-aqhi/default.asp?Lang=En&n=065BE995-1#calculated

    matt,

    Neither is methane,
    Let’s keep it that way.

  138. Nasif Nahle says:

    This value: Nausea and increase of the cardiac and respiratory frequencies (from oxygen deficiency): 30,000 ppmV, would correspond to 2.65% of carbon dioxide in the atmosphere. For comparison, current percentage of carbon dioxide in the atmosphere is only 0.034%. Physiologically, the effect of nausea and increase of the cardiac and respiratory frequencies are due to deficiency of oxygen in blood, not to any specific “toxic” effect of carbon dioxide. The same criterion applies to concentrations of 50000 ppmV and 100000 ppmV.

  139. Ron de Haan says:

    kim (17:52:12) :

    Another thing that is obvious, but virtually unmentioned, is that the animal part of the biosphere is almost completely dependent upon the plant part of the biosphere. What’s good for the plants is good for the animals. Rising CO2, up to a limit is good for everything. Who could ask for anything more?
    ===========================================

    Kim,

    You are 100% correct.
    That is why it is utter madness to tax cattle stocks for methane emissions.

    There is also evidence that our great leaders don’t understand their own policies.

    Cattle stocks maintain a closed CO2 system.

    They intend to achieve the same with bio fuels.

    Bio fuels are supported with Government grants.

    Farmers now are lited for regulation and taxation.
    This is insane.

    The most insane idea of all is to feed the cattle with fish to reduce methane.

    This is the fastest way to empty the oceans permanently and process any fish caught by the nets.

    I have made this remark not for the first time: Green is not green, it is RED.

    And with red I mean the red used in the flag of the fallen USSR Empire.

    Also think about the palm oil plantations destroying tropical forests (Borneo) and the mad bio fuel plan that generates havoc in our food markets.

    Green is Red and Red kills people and destroys eco-systems.

  140. Nasif Nahle says:

    Ron de Haan (19:07:02) :

    matt v. (16:47:27) :

    Notice that carbon dioxide is not included as part of the air quality index.

    http://www.ec.gc.ca/cas-aqhi/default.asp?Lang=En&n=065BE995-1#calculated”

    matt,

    Neither is methane. Let’s keep it that way.

    Because methane is an unavoidable byproduct of biological processes, the same as carbon dioxide. It seems obvious that the objective of EPA’s declaration is not related to environmental concerns.

  141. Fat Man says:

    Drew (16:06:26): “If we’re going to force science to form the basis for the regulations, then the court of law is perhaps the only place where we can get a fair shot.”

    Sorry, Drew. More than a century ago the great humorist Pete Finley Dunne wrote: “no matter whether th’ constitution follows th’ flag or not, th’ supreme coort follows th’ iliction returns.” “Mr. Dooley’s Opinions” p. 26 (1901).

    The courts are political institutions and they will reach political conclusions. The only good news is that they work slowly. Slowly enough that the fever of the current hour will have time to break, and the failure of the predictions of doom will have time to become laughable. That is the best you can hope for.

  142. Ron de Haan says:

    Walter Cronanty (16:07:52) :

    Ron de Haan (12:09:24) : “I you are correct, it was sarcastic. ”
    Sorry for doubting you, Ron.
    Drew (12:29:18) :

    “I respectfully disagree. I believe that the courts are the ONLY place where we can achieve corrective action and adequately address the merits of either side of the issue.”

    Walter,

    With your experience as a lawyer, especially experienced at all levels of State and Federal Law you are the best judge to determine which steps to take.

    In the mean time I am still figuring out with which part of my posting you don’t agree.

    In my opinion going to court is all about using the constitution and your civil rights to fight your case in court?

    I personally think that the scientific arguments from EPA are very weak.
    I also think that we have the best science, the expertise and very motivated people who already are organized and will fight back at any level, even in court if necessary.

    As long as the judges are not biased in which case we are dealing with fowl play.

  143. Mike Bryant says:

    “Neither is methane,
    Let’s keep it that way.”

    Secondhand Methane Fact Sheet
    Secondhand Methane, also know as environmental colon exhaust(ECE), is a mixture of the methane given off by the rear end of a cow, person or other mammal and anything else that might escape at the same time (see breakdown in graph 3 below). It is involuntarily inhaled by nonemitters, lingers in the air for what seems like hours after it has been expelled and can cause or exacerbate a wide range of adverse health effects, including cancer, respiratory infections, asthma and nausea.

  144. Eric Anderson says:

    Walter Cronanty wrote:

    “With the burden one would have to overcome for a court to overrule the rule making abilities of a regulatory body [arbitrary and capricious] and the absolute inundation of poor science on this subject, the Sup. Ct. could be sitting in the middle of a blizzard in August in Washington DC, and I would be doubtful of a favorable outcome.”

    I believe this is a fair assessment.

    There is a better opportunity to do something now, rather than waiting for things to get where you don’t want them and then challenging in court.

  145. Ron de Haan says:

    ralph ellis (09:21:19) :

    And here is the London Guardian’s attempt to finally destroy David Bellamy. For US readers, David Bellamy was the BBC’s darling naturalist, before he became a Climate Change Denier.

    http://www.guardian.co.uk/environment/georgemonbiot/2009/mar/16/monbiot-bellamy-climate-change-denier

    “This is how far the Greens will go in destroying the careers of their opponents”.

    And this is how David Bellamy and David Archibald destroy the climate greenies:

    http://www.davidarchibald.info/

    also see: http://www.davidarchibald.info/papers/synopsis.pdf

  146. ralph ellis says:

    >>This has been posted before, but really folks, if you’re here,
    >>you need to read this entire document. Twice.

    Agreed, this is a valuable petition by the venerable Viscount Monckton of Brenchley. It was Viscount Monckton who prevented the UK Department for Education including ‘An Inconvenient Truth’ into the UK education syllabus. A valuable service to the nation, I feel.

    http://scienceandpublicpolicy.org/images/stories/papers/reprint/markey_and_barton_letter.pdf

    .

  147. ralph ellis says:

    .
    >>And this is how David Bellamy and David Archibald
    >>destroy the climate greenies:

    Indeed, by scientific argument and not an ad hominem in sight. This is in complete contrast to the Guardian’s George Monbiot, who made a vitriolic personal attack on Bellamy himself.

    Bellamy – Archibald et al:
    http://www.davidarchibald.info/papers/The%20Past%20and%20Future%20of%20Climate.pdf
    http://www.davidarchibald.info/papers/Failure%20To%20Warm.pdf

    Guardian’s Monbiot:
    http://www.guardian.co.uk/environment/georgemonbiot/2009/mar/16/monbiot-bellamy-climate-change-denier

    .

  148. GailC says:

    Comment to the EPA and then FAX the congress critters sponsoring these bills as well as your own. Make sure it is a FAX, everything else gets tossed but they have to keep Faxes for seven years.

    While you are at it comment about the anti farming “food safety bills” I really really do not want to see food shortages in the USA because they put farmers out of the business of growing food. If we see cooling we will see lower crop yields and we can not afford the loss of even one farm.

    If these bills pass I will get rid of my crops and animals and plant nice carbon credit trees they are much less hassle, less paperwork and less liability. Other farmers will do the same. The fact that the grain traders convinced Congress to do away with USDA food reserves in 1996 and we are now a bad growing season away from food shortages in the USA is YOUR problem so make sure your Congress Critter knows you know you are being setup for a famine. By letting them know the combination of these bills will lead to FAMINE should get their attention especially after BIO-fuel regs were blamed for the food riots last year.

    No remaining grain reserves
    http://www.standeyo.com/NEWS/08_Food_Water/080606.no.grain.reserves.html

    Financial reports show 20 straight months of cattle being sold at a loss in 2008. http://www.avma.org/onlnews/javma/apr09/090415a.asp

    A Solemn Walk through HR 875
    http://www.opednews.com/articles/A-solemn-walk-through-HR-8-by-Linn-Cohen-Cole-090314-67.html

    Read the bottom of this article to see how the international HACCP system removed government oversight of large slaughter houses. It is a real eye opener…
    http://yupfarming.blogspot.com/2009/04/food-safety-bills-exempt-foreign.html

    I realize Ag is sort of off topic but if the Carbon tax and anti farming bills cause farmers to slaughter animals and plant trees instead of crops the damage can not be undone easily. We seem to be swamped with bills designed to destroy the USA and the rest of the world.

    “Isn’t the only hope for the planet that the industrialized civilizations collapse? Isn’t it our responsibility to bring that about?” Maurice Strong Father of the global warming hoax

  149. Ellie in Belfast says:

    That Monbiot article on David Bellamy is vile. I suspect Prof Bellamy does not that well known outside the UK, but he is still a very recognisable figure in Britain – for adults at least – and therefore he is someone that sceptics could and should support and help. People know him as a serious environmentalist and be more open to listen to his views. He used to be all for doing something about climate change in the 1990′s* but then denounced it as ‘a load of poppycock’ in 2004. So somewhere in between his views changed and I am quite sure many ordinary members of the public would be interested to know just what made him change his mind.

    *cited in another vitriolic anti-Bellamy article: http://www.monbiot.com/archives/2008/12/09/a-beardful-of-bunkum/

    Anthony – would you consider giving him a chance to explain his conversion? it might well be picked up by others too. Or perhaps this is not appropriate if he is not well known outside the UK.

    Some better press (but it still does not explain what changed his mind)
    http://www.express.co.uk/features/view/73486/David-Bellamy-Global-warming-is-nonsense

  150. Ellie in Belfast says:

    Actually here is a link to a copy of the original 2004 article that caused all the trouble:
    http://www.junkscience.com/july04/GW_David_Bellamy.JPG_1.jpeg

  151. Ron de Haan says:

    Ellie in Belfast (09:14:29) :

    Actually here is a link to a copy of the original 2004 article that caused all the trouble:
    http://www.junkscience.com/july04/GW_David_Bellamy.JPG_1.jpeg

    I would be embarassed if I had to work for the current BBC.
    At least David Bellamy keeps a sane view on the world.
    He is a far better example compared to Sir Richard Attenborough who is not expelled by the BBC.
    He recently took “the wrong exit” in his support of the fascist opinions of Prins Charles in regeard to population reduction also propagated by the UN http://green-agenda.com and chose a few very obscure “friends”.
    http://www.ibdeditorials.com/IBDArticles.aspx?id=324516647690251

  152. ralph ellis says:

    >> http://www.ibdeditorials.com/IBDArticles.aspx?id=324516647690251

    I think that was David Attenborough, not Bellamy. Nevertheless, Attenborough is right in that the biggest threat to the environment is population growth.

    However Greenpeace states:
    “We have never campaigned on the issue
    of human population and have no plans to do so.”

    So there you have it – the Greens will deliberately ignore the biggest threat to the environment, so they are a complete fraud.

  153. Ellie in Belfast says:

    Yes, I found myself contrasting Bellamy and Attenborough too, and population growth is potentially a huge problem – however so is the falling birth rate in the first world, which the linked article above also mentions.
    “Our biggest problems in the next 100 years won’t be too many people; it will be figuring out how a shrinking base of younger workers will be able to pay for our fast-expanding population of elderly retirees.”
    ….and paying for the cost of climate change mitigation if current political strategies continue.

    Then of course (not meaning to be alarmist) there is always the threat of the next big pandemic around the corner (and it is not if, but when, and how bad).

  154. Keith W says:

    A reasoned response by large numbers of rational Americans can be influential and I agree with David Hagan on how to approach it.

    Not all of the Democrats went along with the carbon cap and trade vote at the beginning of the month and 26 Democrats joined all 41 Republicans insisting that this legislation be voted on normally.

    See Wall Street Journal article from 3 April

    http://online.wsj.com/article/SB123872261427685233.html

  155. Eric Anderson says:

    “Nevertheless, Attenborough is right in that the biggest threat to the environment is population growth.”

    Assuming, of course, that humans aren’t part of the environment. After all, I suspect he wouldn’t argue that an increase in the population of, say, whales is a threat to the environment?

    We’ve come pretty far OT here.

    Back to reading the EPA nonsense . . .

  156. old construction worker says:

    Mike Bryant (17:33:49)
    “old construction worker (17:20:27) :
    Do you have any endanger plant life on your tree farm? Wouldn’t any attempt to regulate CO2 be counter intuitive of the endanger species act?”
    Could you imagine that case in front of the 9th district court? I think they would blow a fuse.

  157. SG says:

    I agree with Keith W.

    The people to go after are the senators in the mid west states where the electricity/jobs come from coal powered plants. We need to carefully inform them that cap-n-trade/EPA regulations are political suicide. Just the thought of electricity going up four fold scares the crap out of me and should scare them…

    I do also believe that are at an inflection point in this country and this could finally be the catalyst that determines if we get back to common sense solutions or repeat history and head to the dark ages….

    Remember…without Jimmy Carter there would have not been a Ronald Regan…

  158. Tom in Florida says:

    As everyone knows, years ago the government mandated the use of catalytic converters on all autos to reduce the emission of unburned hydrocarbons and carbon monoxide that was expelled into the air by auto exhaust. This is done by converting them into the “harmless” gas CO2. Now, the government is on the verge of mandating a reduction in the “pollutant” gas CO2 they ordered us to create. So there you have it: we are required to produce CO2 in order to save the planet and now we are going to be required to pay a tax on the same CO2 in order to save the planet. Brilliant!!

  159. carlbrannen says:

    DAV (08:04:59) links to an article in the NYT about carbon cap and trade in the northeast states. Yes, carbon cap and trade really is a threat to industry and consumers, but it’s not EPA mandated. And, note that it’s happening in blue states that hate industry, not in Arizona or Texas.

    I think that cap and trade through the legislative branch is the real threat, not CO2 through the EPA. The legislative branch can do these things very quickly, the EPA cannot. And like I mentioned, the EPA is industry’s buddy. The legislative branch is not. Without EPA, industry would be inundated with lawsuits; far far more lawsuits than they have to deal with now.

    As far as I can tell, the EPA cannot create cap and trade. All they can do is issue permits that allow us to pollute, and old polluters will likely be grand fathered. For example, if I want to build a new plant, I have to use a modern boiler with a really low NOX and CO spec. But it’s legal to keep running an old boiler provided it was under its agreement when installed. As far as paying to pollute, no, the EPA doesn’t have one of these programs as far as I know. Anyone knows better, please correct.

    A rather well connected renewable fuels czar for a blue state told me (3 months ago) that Obama would not begin cap and trade until at least 2012. My interpretation is that the politicians know that cap and trade is a turd and they want to put it on a lame duck president, i.e. Obama in 2013. And I suspect that they somehow imagine they will the Republicans to not filibuster it.

    I think it’s highly unlikely that global warming will survive that long. My dad told me the other day that a liberal scientific couple he knows has recently reversed on man caused global warming. I think the tide is turning both in the weather and in the politics.

    There are many things that the EPA does right and even though I am a right wing nut cake, I would not like to see a world where the EPA was eliminated. The same applies to OSHA. Left to their own devices, the worst run companies would do amazingly dangerous and dirty things. Even with EPA and OSHA amazing stuff goes by. The best thing the US could do for health in the 2nd and 3rd world would be providing free training to other countries for their own agencies.

    And it’s not obvious to me that the rural energy producing states are the ones that will be most damaged by cap and trade. Instead, I think the most damage will be in urban energy consuming states. Someone who heats their house with electricity will be hurting, someone who uses wood, a lot less.

  160. Rick Gibbs says:

    This is nothing but a money grab from Governments. Follow the money.

    http://newsbusters.org/blogs/noel-sheppard/2008/03/04/weather-channel-founder-sue-al-gore-expose-global-warming-fraud

    Rick Gibbs

  161. Jim Cudahy says:

    I have only been able to read about half of the comments, so I appologize if I’m repeating other comments. Unfortunately, at this time, I don’t believe that the science matters to the politicians. What does matter is the desire of congress and the senate to remain in office. Therefore, one of the best strategies is two-fold. Send letters to your congressmen and senators that climate change is a natural cycle and that you will be outraged if they pass cap and trade or any other form of carbon tax. Secondly, get the word out to friends and the people in your area (letters editor, radio, TV, letters to magazines, etc.) that climate change is a natural process. Quote Moncton in a simple way about temperature decreasing and the IPCC models missing it and Dr. Plimer’s book or You-Tube videos. These resources have been on Anthony’s web-site. It seems to be already working, based on recent surveys. If we can get enough people publically objecting to cap and trade and carbon taxes, we can win this.

  162. Bill from Pittsburgh says:

    In addition to the excellent observations and comments of Roger Sowell, Eric Anderson, Dane Skold, Ed Scott and ‘anonymous (again)’, I offer the following suggestions when making comments:

    1. No rants. Stick to the facts and science. Be respectful. Otherwise, you risk having your comments ignored or readily dismissed.
    2. Both general comments and specific comments should be made.
    3. The more specific you can be when making a comment, the better, such as Steven Goddard’s excellent dissection of Steig, et al’s paper regarding temperatures on Antarctica.
    4. Courts are a poor forum to resolve scientific questions but are much better at procedural and constitutional issues. On the procedural front, one line of attack is that the EPA’s proposed finding violates the PRESIDENTIAL MEMORANDUM ON SCIENTIFIC INTEGRITY. (See http://www.whitehouse.gov/the_press_office/Fact-Sheet-on-Presidential-Memorandum-on-Scientific-Integrity/ ) I would encourage comments regarding how much of the cited science has not followed the scientific method including some of the many excellent posts I’ve read here about how science is not done by “consensus”. However, I will note that Courts like to “weigh” evidence and so could be swayed by the “weight of the evidence” and the so-called consensus that has developed. But a procedural attack would find a more willing audience. As for any kind of constitutional attack, I’ll have to give that some more thought.
    5. Another potential line of attack is on the lack of specific public health effects and that such alleged effects are speculative at best.

    While submitting comments may not carry the day, I believe they can have an impact at least in two ways. You may actually be able to persuade someone of the merit of your thoughts. More importantly, each comment must be responded to as pointed out by one of the other commenters. That’s why the more specific you can be, the less likely it can be lumped in with another comment. And the more comments deserving of a response, the more time it takes to conclude the administrative process. The fact that the EPA took such great pains in its Proposed Endangerment Finding to point out that it will follow the ordinary administrative process tells me that they are not fully committed to a rulemaking under the Clean Air Act. Any such rulemaking requires at least the development and publication of a Proposed set of regulations with a notice and comment period (such as for the Proposed Endangerment Finding) and then a similar rulemaking procedure for a Final rule. Further, the Clean Air Act is unsuited for this type of a new regulatory approach and the Administration knows it. For this and other reasons, the Administration prefers Congress to act. Also, don’t discount the value of writing directly to Lisa Jackson, the EPA Administrator. As an environmental attorney working for a Fortune 200 company, I’ve met with her when she was with the New Jersey DEP and have found her intelligent, thoughtful and responsive to well articulated arguments. While I have no illusions that few, if any, of such correspondence would ever be read by her directly, she will be made aware of the more thought-provoking comments.

  163. Korla Pundit says:

    Will this slow strangling of our civil liberties finally culminate in a civil war? Because it won’t stop with this. They will control every facet of your life. They will take all your property. They will force you to work in the job they decide you should work in. They will take away your children, since obviously you as an individual can’t be trusted to take proper care of them.

    This is what comes with a Dem supermajority and a Marxist President. Congratulations all you alleged libertarians out there who thought Hopey would be good for this country, and all you conservatives who thought you would “punish” the GOP for choosing that ~snip~ McCain.

    Now you have Stalin.

  164. Korla Pundit says:

    >Remember…without Jimmy Carter there would have not been a Ronald Regan…

    And we wouldn’t have had mullahs running Iran, or a Soviet invasion of Afghanistan, all of which led to where we are now. A pretty heavy price to pay for a Reagan.

    We may not survive this “Carter.”

  165. Jon W says:

    Global warming is a farce. I wish the EPA would act responsibly and non-partisan rather than kowtow to leftist nutcases.

    Btw, CO2 is a naturally occurring gas. Trees breathe CO2.. why, who’da thunk it?

  166. Roger Sowell says:

    tarpon (09:56:37) :
    ” “…six key greenhouse gases—carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6)” — From the original page.

    Isn’t this a serious turn of events to include all these other chemicals in one subject of GHG emissions? Is this to just obfuscate and deflect attention from what they really want, control over energy use? Or is this the result of they know that the CO2 argument is so seriously debunked that it needs support?

    So can someone address these other gases that have just mysteriously appeared in the report.”

    The six gases are referred to as the Kyoto gases, because those were named in the Kyoto Protocol (or treaty) as the primary causes of man-made global warming, now renamed climate change. Each gas has been assigned a number, or multiplier, by which it acts in a manner greater than CO2. Thus, we have CO2-equivalents.

    On the link below, scroll down to Annex A, and the six gases are listed there.

    http://unfccc.int/essential_background/kyoto_protocol/items/1678.php

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