As you may have already read about, the EPA is set to declare CO2 as a “public endangerment”. While the EPA declaration indicates “An endangerment finding under one provision of the Clean Air Act would not by itself automatically trigger regulation under the entire Act.” it will in fact open the door for future action.
* 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.
This 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.
It is curious that the EPA left off the most potent greenhouse gas, water vapor, yet included sulfur hexaflouride, which is so many times heavier than the other gases in our atmosphere one wonders how it would rise to heights to have any effect on longwave radiation return. Methane is 23 times more potent as a GHG than CO2, but like CO2 is also part of our natural cycle on earth. Yet even some science that should be cognizant of such facts portray’s CO2 as the worst offender:
As I read somewhere last week, “madness is afoot”.
While I think the EPA will probably ignore public comment in “expected amounts” they may in fact pay attention if the vast majority of comments are counter to the finding, and if they are well written, factual, and sans emotional diatribe.
Steve McIntyre of ClimateAudit has an excellent article on quality control issues with the EPA that is worth reading
I urge WUWT readers in the USA (no matter what side of the issue you are on) to exercise their right to a democratic process and to submit comments to the EPA, as well as to your state and federal representatives.
As a guide for doing this, WUWT reader Roger Sowell has some useful guidelines that I find helpful:
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:
I urge all readers to make teir opinions known to the EPA.
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SF6 is used extensively in the electronics industry and its price has tripled in the last ten years. I use it my lab and a standard size cylinder now costs on the order of $1400. Watch the price of all our cheap electronics skyrocket.
Yes, they completely ignore dihydrogen monoxide; THE FOOLS!!
http://www.dhmo.org/
Listen to Obama’s climate change hysteria in his answer to a 7 year old
Anthony, once again, you do me a great honor. Thank you.
I wonder if someone can enlighten me. “Methane is 23 times more potent as a GHG than CO2, but like CO2 is also part of our natural cycle on earth.” By what measure is methane 23 times more potent? Is it the value of the radiative forcing? I suspect the figure comes from the global warming potential, which, IIRC, has nothing to do with greenhouse effectiveness, but is a function of how long the gas stays in the air. Does anyone know enough to give me a definitive reference?
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.
6. Where possible, use studies prepared by a governmental agency or department that support your position. For instance, didn’t NOAA publish a study concluding that global warming does not contribute to greater intensity storms?
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.
And once again, you’ve probabaly saved me and those I already alerted from really pissing off the minions assigned to read our missives. As much as I wanted to let them have it, I will follow the sage advice presented by Roger. Dammit. I have updated my recent post so my small band of followers may do likewise:
http://cbullitt.wordpress.com/2009/04/19/agw-action-alert-the-epa-wants-our-opinion-let-them-have-it/
“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. ”
Perhaps we should just remove the catalytic converters from our cars to keep them from emitting that harmful CO2.
I applaud the civic mindedness of this post.
Maybe it will set the stage for repealing this in a future administration.
CO2 is linear. H20 makes a triangle, but CO2 ends up with O on either side of the C. The skull is wrong.
Also, the CO2 in the image has an extra C. [snip]
This is but a sympthom of the most absolute insanity, madness, craziness, the most clear expression of “Hollywood’ s science”.
My most sincere condolences for having reached such a preposterous level of development.
So much to rant about. How on earth do I decide what the most important point or two to make is?
Aron… in the video, our scientific president says:
“Our planet… has gone up two or three degrees, and the polar ice caps have melted, and the oceans have gone up…”
-Barack Obama
Over 42 spotless days in a row.
10.7 cm Flux stuck between 69 and 70.
Meanwhile, active oil & gas drilling rigs in the US have fallen by 50% in a year, and we’re fixin’ to tax to death the carbon that the remaining ones are drilling for.
Is ANYBODY getting just a little bit nervous yet?
I hate to say it, but at the current rate of “carbon contraction” in the midst of a solar minimum, within a couple of years folks are going to be freezing in the dark.
Mike Monce (12:20:11) Says:
SF6 is used extensively in the electronics industry and its price has tripled in the last ten years. I use it my lab and a standard size cylinder now costs on the order of $1400. Watch the price of all our cheap electronics skyrocket.
No, watch the remaining vestiges of our electronics industry move to China and India where the politicians are semi-sane.
Wow, and I thought our government here in the UK was stupid!
Maybe OT but in the area I think being part of the case for promoting the above and similar actions in other countries. Those in the government pay certainly know how to sing the song. Now Stern in the UK is ramping up the rhetoric against those that do not fall into line and doing so in a book. For more rhetoric and amazing “scientific evidence”
Climate change sceptics likened to those who denied HIV Aids link by Lord Stern
Climate change sceptics have been compared to those who denied the link between smoking and cancer or HIV and Aids by Government environmental adviser Lord Stern.
For more rhetoric and amazing “scientific evidence”
http://www.telegraph.co.uk/earth/environment/climatechange/5188947/Climate-change-sceptics-likened-to-those-who-denied-HIV-Aids-link-by-Lord-Stern.html
The king is nude! but no one will tell it, as long as the “king” pays the bills.
You are making the ridicule as long as you don’t call the attention of your king about his nudity.
If the governmental site was really interested in receiving public comments, they would have made it more user friendly. I went to the link and could not register a comment. If any of you readers are more politically savvy and know how to leave comments to the EPA through a ready made link, I’d love the chance to be heard. Printing out a form and writing a comment and then mailing it seems a bit – low tech. Are there better options?
Dave
Anthony- Great logo! I’ll be sending in a love note to EPA. At least they are bound by law (I think) to read every submission.
Mike Monce-
Yep, SF6 was identified for the greenhouse gas (s) hit list since around 1995. Back then, I was using it as an insulating gas for high voltage equipment, for which it has spectacular properties. The prices at that time were about $200 per cylinder. In response to EPA rumors about regulating SF6, Allied Chemical discontinued production, creating a supply shortage. Prices went to well over $1000 by 2001 or 2002.
The funny thing about this gas being used by power utilities, primarily for Gas Insulated Bus and Switchgear like circuit breakers, is that the equipment is designed not to leak for at least 20 years. Utilities now recycle SF6 from breakers and buswork because of its cost. Claiming SF6 emissions into the atmosphere based on SF6 production would be an appalling error in book-keeping. Claiming it contributes non-trivially to mid troposphere warming is specious.
Also, SF6 is harmless as long as you don’t get trapped in an enclosed space. SF6 is so heavy that when it escapes from a port, it flows onto the floor. You can see this by watching the Schlieren patterns in the air next to the fill port. People have died from asphyxiation when working inside circuit breakers that were not properly vented of all SF6.
I don’t live in the US, but I often listen to NPR and today they were discussing the EPA’s proposal. I don’t remember who the guests were (was driving at the time), but they seemed directly or closely involved. Of course the usual reasons for capping CO2 emissions were: the sea-level is rising, ice-caps are melting, temperatures are rising, CO2 causes hurricanes, droughts and floods. Great.
Earlier today I watched a very informative CBC documentary called: Global Warming – Doomsday Called Off (available on youtube), which seemed to address a few of the AGW claims and provided clearly different opinions to the ones I heard on NPR. I especially liked the evidence that showed that the sea-level is not rising in the Maldives.
Here’s an article on a book called Heaven and Earth by one of Australia’s foremost Earth scientists
http://www.smh.com.au/opinion/beware-the-climate-of-conformity-20090412-a3ya.html?page=-1
While I’m a creationist and don’t believe in the whole ‘millions of years’ thing it does seem to point out (which I will agree with) the tremendous benefit to plant life as a whole that high CO2 levels bring. Also I already said I’m a creationist, but I believe there has been periods of significantly higher global temperatures 1000’s of years ago than today and that we likely have a bit higher amount of ice today than during periods thousands of years ago.
Just google ‘Co2 levels in greenhouses’ and you’ll find pages talking about Co2 pumps and benefits to growers among the other AGW links it lists here and there.
Bill from Pittsburgh (12:37:58) :
Good idea. Do you have the specific address for Lisa Jackson, the EPA Administrator?
Re SF6, and why the EPA wants to regulate it:
California has already regulated SF6. The Air Resources Board on Feb 26, 2009, adopted two regulations as follows: The Board unanimously approved resolution 09-22, which adopted the staff proposal for semi-conductor use, and the Board also unanimously approved Resolution 09-23 for non-semi-conductor use with direction for staff to add an exemption for military tracer gas use and research.
From the ARB staff report:
“Why Regulate Sulfur Hexafluoride?
Sulfur hexafluoride is a potent greenhouse gas with a lifetime of 3,200 years and a one-hundred year global warming potential (GWP) of 23,900, the most potent greenhouse gas the Intergovernmental Panel on Climate Change (IPCC) has evaluated (IPCC, 2007). In the last five years, atmospheric concentrations have been growing at a rate of 5% per year (NOAA, 2008). The growth rate could be the result of increasing emissions in any or all emission sectors.
Without intervention it is anticipated that the growth rate will continue at a similar rate for the next several years. Given these characteristics and the availability of alternatives, SF6 use warrants scrutiny, particularly in the emissive applications covered by this proposed regulation.”
More information on the California regulations is available here:
http://www.arb.ca.gov/regact/2009/nonsemi09/nonsemi09.htm
Scroll down to the Staff Report and Appendices.
http://online.wsj.com/article/SB123993344387627879.html
Related enough to be not off-topic. Sorry if this was already posted but, if it was, it’s probably worth another read anyway, just for the amusement value.
(For those with a wry sense of humor, that is).