I just sent my comments in, and have included excerpts from them below for structure and ideas. If you have not done it yet, get your comments in. I did mine via email. Some excerpts from my commentary are listed below. You can send public comments here: ghg–endangerment-docket@epa.gov
To submit a comment, identify them with Docket ID No. EPA-HQ-OAR-2009-0171 and submit them online, by email, by facsimile, by mail or by hand delivery.
The docket # is Re: Docket ID No. EPA–HQ– OAR–2009–0171 Be sure to include that number in email
They must be received by EPA by June 23. TODAY
ADDRESSES: Submit your comments, identified by Docket ID No. EPA-HQ-OAR-2009-0171, by one of the following methods:
– Federal eRulemaking Portal: http://www.regulations.gov. Follow the online instructions for submitting comments.
– E-mail: ghg-endangerment-docket@epa.gov
– Fax: (202) 566-1741.
– Postal Mail: Environmental Protection Agency, EPA Docket Center (EPA/DC), Mailcode 6102T, Attention Docket ID No. EPA-HQ-OAR-2009-0171, 1200 Pennsylvania Avenue, NW, Washington, DC 20460. TOO LATE
– Hand Delivery: EPA Docket Center, Public Reading Room, EPA West Building, Room 3334, 1301 Constitution Avenue, NW, Washington, DC 20004. Such deliveries are only accepted during the Air Docket’s normal hours of operation, and special arrangements should be made for deliveries of boxed information.
Instructions: Direct your comments to Docket ID No. EPA-HQ-OAR-2009-0171. EPA’s policy is that all comments received will be included in the public docket without change and may be made available online at http://www.regulations.gov, including any personal information provided, unless the comment includes information claimed to be CBI or other information whose disclosure is restricted by statute. Do not submit information that you consider to be CBI or otherwise protected through http://www.regulations.gov or e-mail.
The http://www.regulations.gov Web site is an “anonymous access” system, which means EPA will not know your identity or contact information unless you provide it in the body of your comment. If you send an e-mail comment directly to EPA without going through http://www.regulations.gov your e-mail address will be automatically captured and included as part of the comment that is placed in the public docket and made available on the Internet. If you submit an electronic comment, EPA recommends that you include your name and other contact information in the body of your comment and with any disk or CD-ROM you submit. If EPA cannot read your comment due to technical difficulties and cannot contact you for clarification, EPA may not be able to consider your comment. Electronic files should avoid the use of special characters, any form of encryption, and be free of any defects or viruses.
Some examples:
This Climate Audit post can also be useful for ideas.
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, some excerpts from my submission, sans photos are listed below.
=========================================
To: ghg–endangerment-docket@epa.gov
From: Anthony Watts
[address]
Re: Docket ID No. EPA–HQ– OAR–2009–0171
Please find the following comments related to EPA’s April 24, 2009 Proposed Endangerment and Cause or Contribute Findings for Greenhouse Gases Under Section 202(a) of the Clean Air Act (EF).
These comments also address issues in the April 17, 2009 Technical Support Document (TSD) that includes many of the detailed references to science, data, and models used to justify comments in the Endangerment Finding.
Issue Summary
The official record of temperatures in the continental United States comes from a network of 1,221 climate-monitoring stations overseen by the National Weather Service, a department of the National Oceanic and Atmospheric Administration (NOAA). Until now, no one had ever conducted a comprehensive review of the quality of the measurement environment of those stations.
During the past few years a team of more than 650 volunteers visually inspected and photographically documented more than 860 of these temperature stations. We were shocked by what we found. We found stations located next to the exhaust fans of air conditioning units, surrounded by asphalt parking lots and roads, on blistering-hot rooftops, and near sidewalks and buildings that absorb and radiate heat. We found 68 stations located at wastewater treatment plants, where the process of waste digestion causes temperatures to be higher than in surrounding areas.
In fact, we found that 89 percent of the stations – nearly 9 of every 10 – fail to meet the National Weather Service’s own siting requirements that stations must be 30 meters (about 100 feet) or more away from an artificial heating or radiating/reflecting heat source. In other words, 9 of every 10 stations are likely reporting higher or rising temperatures because they are badly sited.
For example, here is a climate station of record located in a parking lot, at the University of Tucson, operated by the Atmospheric Sciences Department.
Above: official USHCN weather station, Atmospheric Science Dept. University of Arizona, Tucson. more on that station here. Photo: Warren Meyer
It follows that if Atmospheric Scientists at an institution of higher learning cannot measure temperature correctly, then there is little expectation that it will be elsewhere. In fact, that is what I found.
It gets worse. We observed that changes in the technology of temperature stations over time also has caused them to report a false warming trend. We found major gaps in the data record that were filled in with data from nearby sites, a practice that propagates and compounds errors. We found that adjustments to the data by both NOAA and another government agency, NASA, cause recent temperatures to look even higher.
Note that the graph above shows NOAA’s own adjustments to temperature over time.
Reference URL for the above graph from Carbon Dioxide Information and Analysis Center
http://cdiac.ornl.gov/epubs/ndp/ushcn/ts.ushcn_anom25_diffs_pg.gif
Below are my findings of the state of quality for the USHCN network of Stations:
The conclusion is inescapable: The U.S. temperature record is unreliable. The errors in the record exceed by a wide margin the purported rise in temperature of 0.7C (about 1.2F) during the twentieth century.
My report is available in full as this PDF document here:
I request that it also be entered into the official record as well, as part of this document.
Consequently, this record should not be by the Administrator as evidence of any trend in temperature that may have occurred across the U.S. during the past century. Since the U.S. record is thought to be “the best in the world,” it follows that the global database is likely similarly compromised and unreliable.
The many problems with the surface temperature record that have been demonstrated both photographically and by a national census suggest that the supposed linkage between carbon dioxide levels and surface temperature is likely not correlated by global climate models that use the surface temperature record as data input or as a means of calibration.
All models that use this flawed data for validation must be rejected by the Administrator as non-compliant with the Federal Information Quality Act.
Specific Errors in the EF/TSD
EF.18898. column 3-18899.column 1
“Like global mean temperatures, U.S. air temperatures have warmed during the 20th and into the 21st century. According to official data from NOAA’s
National Climatic Data Center:
• U.S average annual temperatures are now approximately 1.25 °F (0.69 °C) warmer than at the start of the 20th century, with an increased rate of warming over the past 30 years The rate of warming for the entire period of record (1895–2008) is 0.13 °F/decade while the rate of warming increased to 0.58 °F/decade (0.32 °C/decade) for the period from 1979–2008.
• 2005–2007 were exceptionally warm years (among the top 10 warmest on record), while 2008 was slightly warmer than average (the 39th warmest year on record), 0.2 °F (0.1 °C) above the 20th century (1901–2000) mean.
• The last ten 5-year periods (2004– 2008, 2003–2007, 2002–2006, 2001–2005, 2000–2004, 1999–2003, 1998– 2002, 1997–2001, 1996–2000, and 1995– 1999), were the warmest 5-year periods in the 114 years of national records, demonstrating the anomalous warmth of the last 15 years.
TSD Executive Summary
“[OE 3] Warming of the climate system is unequivocal, as is now evident from observations of increases in global average air and ocean temperatures, widespread melting of snow and ice, and rising global average sea level Global mean surface temperatures have risen by 0.74°C (1.3ºF) (±0.18°C) over the last 100 years. Eight of the ten warmest years on record have occurred since 2001. Global mean surface temperature was higher during the last few decades of the 20th century than during any comparable period during the preceding four centuries.
“[OE 4] Most of the observed increase in global average temperatures since the mid-20th century is very likely due to the observed increase in anthropogenic GHG concentrations. Climate model simulations suggest natural forcing alone (e.g., changes in solar irradiance) cannot explain the observed warming.
“[OE 5] U.S. temperatures also warmed during the 20th and into the 21st century; temperatures are now approximately 0.7°C (1.3°F) warmer than at the start of the 20th century, with an increased rate of warming over the past 30 years. Both the IPCC and CCSP reports attributed recent North American warming to elevated GHG concentrations. In the CCSP (2008g) report the authors find that for North America, “more than half of this warming [for the period 1951-2006] is likely the result of human-caused greenhouse gas forcing of climate change.”
TSD.22-23
“Global Surface Temperatures
Surface temperature is calculated by processing data from thousands of world-wide observation sites on land and sea. Parts of the globe have no data, although data coverage has improved with time. The long-term mean temperatures are calculated by interpolating within areas with no measurements using the collected data available. Biases may exist in surface temperatures due to changes in station exposure and instrumentation over land, or changes in measurement techniques by ships and buoys in the ocean. It is likely that these biases are largely random and therefore cancel out over large regions such as the globe or tropics (Wigley et al., 2006). Likewise, urban heat island effects are real but local, and have not biased the large-scale trends (Trenberth et al., 2007).
The following trends in global surface temperatures have been observed, according to the IPCC (Trenberth et al., 2007):
• Global mean surface temperatures have risen by 0.74°C ±0.18°C when estimated by a linear trend over the last 100 years (1906–2005) as shown by the magenta line in Figure 4.2. The warmest years in the instrumental record of global surface temperatures are 1998 and 2005, with 1998 ranking first in one estimate, but with 2005 slightly higher in the other two estimates. 2002 to 2004 are the 3rd, 4th and 5th warmest years in the series since 1850. Eleven of the last 12 years (1995 to 2006) – the exception being 1996 – rank among the 12 warmest years on record since 1850. Temperatures in 2006 were similar to the average of the past 5 years.
• The warming has not been steady, as shown in Figure 4.2. Two periods of warming stand out: an increase of 0.35°C occurred from the 1910s to the 1940s and then a warming of about 0.55°C from the 1970s up to the end of 2006. The remainder of the past 150 years has included short periods of both cooling and warming. The rate of warming over the last 50 years is almost double that over the last 100 years (0.13°C ± 0.03°C vs. 0.07°C ± 0.02°C per decade).
Comments
Supporting peer reviewed papers for my analysis of errors in the siting of USHCN climate monitoring stations include:
Yilmaz et al (PDF 2008 ) which cites temperature differentials of up to 11.79C between asphalt/concrete and grass. Grass is the preferred surface over which temperature should be measured according to World Meteological Organization (WMO) standards.
http://www.ejournal.unam.mx/atm/Vol21-2/ATM002100202.pdf
See the Climate Reference Network Site Handbook (National Climatic Data Center PDF 2002) including explanation of the CRN 1-5 rating system used by surfacestations.org
http://www1.ncdc.noaa.gov/pub/data/uscrn/documentation/program/X030FullDocumentD0.pdf
An online database of the weather stations comprising the U.S. Historical Climatoilogy Network that have been surveyed thus far is available online at http://gallery.surfacestations.org
It’s a great comment Anthony, I hope they pay attention.
Eventually they will be forced to, science doesn’t play favorites.
REPLY: But politics does, and when making law, politics trumps science. Which is why we have to make our voices known. The only thing that trumps both is nature, but that may take awhile. – Anthony
Thank you for your patriotism Anthony.
I let the EPA know that we know that it is impossible to tax the temperature of the planet down. I let them know that this is a fraudulent attempt for government mandated gas price gouging. I also let them know they WILL BE held responsible for this perversion of science.
Excellent comment, but I think it is already decided, based on the settlement with California over auto emissions. The deal assumes an EPA finding.
“It ain’t over ’till the fat lady sings”
It’s vital that as many people voice their concerns to the EPC, as the evidence is good that AGW is a myth.
With what looks like colder weather round the corner, every comment will count.
Hi, the link to make comments is not working, as soon as it does, i’ll chime in.
A particular website I subscribe to (which won’t be mentioned here) attempts to anticipate the future. By monitoring terms in use and relationships to other terms, it creates an “anticipation map”. This map is now showing something very interesting, that is a heat-based currency. Without going into too much detail, it seems that rather than trade carbon credits, it is further abstracted into heat units. This will coincide with the decline of the dollar and provide a universal currency. I believe the first step is to regulate CO2, then bring other chemicals in (methane, etc), much like gold and silver of old. Eventually it will be abstracted into heat units. We will be paid in, and buy things with, heat units. This will better reflect environmental costs, while incorporating local labor costs and shipping. No more cheap stuff from China at the expense of the environment. The cost will be better in proportion to the environmental impact. Just something to think about as we dip our toe in the water…
a “heat based currency” will become reality about the same time the entire human race begins speaking Esperanto. When does the “anticipation map” book that one into our future?
That website’s analysis ignores the most important factor in any evaluation of fiat currency – Power. Meaning, the power of the issuer to defend that currency, to prevent counterfeiting of the currency, and to create trust in that currency. For a practical example, suppose there was such a heat based currency. Who – very specifically, who?? – is going to stop me from going to Aruba, claiming I have a special heat sink based on my perpetual motion machine, and to begin printing all of the “heat based” currency I can print and passing it out? Who has the level of force to stop that? If you cannot answer the question, the proposed currency will fail immediately. Who backs it? Who enforces it? Who trusts it?
Without those three interlocking aspects of power, a fiat currency is nothing but cheerios boxtops. The utopians generally assume that this will all happen the day the UN becomes the One True World Government. Yeah right – we’re back to Esperanto with that one.
Since you mentioned the decline of the dollar, there is a very real possiblity that we may be seeing the long term breakdown of all of the fiat currencies due to massive overleveraging. If this happens (and it’s not guaranteed yet, but looking more likely every day) then we will in fact go back to gold, silver, and other physical mediums of exchange – and for the simple reasons that they are one of the only things trusted implicitly by every nation, they cannot be counterfeited, and governments can’t decide to double the supply one morning because they’ve spent all of their money on foolish promises.
Jason said:
Funny, I could have sworn that money already did that, plus allowed us to handle the notion that heat units might become cheaper at some time in the future as we find more efficient ways to harness energy.
Anthony
I just attempted to send comments to:
ghg-endangerment-docket@epa.gov
But I got this error message:
Your message did not reach some or all of the intended recipients.
Subject: Docket ID No. EPA–HQ– OAR–2009–0171
Sent: 6/17/2009 12:42 PM
The following recipient(s) could not be reached:
‘ghg–endangerment-docket@epa.gov’ on 6/17/2009 12:42 PM
The requested operation failed.
Any idea as to why that might have happened?
Lovely stuff !
I have always been impressed with the way that democracy is run in the US; particularly the formal process where any citizen’s reasoned views are actively solicited, recorded, and accounted, by the civil service. It ensures that the truth comes out in the end.
I wish we had such proper formal open democratic processes in the UK, instead of our quasi-system of informal lobbying (aka ‘trousering’) which permits inconvenient truths to be elided for decades.
“Consequently, this record should not be by the Administrator as evidence of any trend in temperature that may have occurred across the U.S. during the past century.”
Should that be ‘not be used’
At least you get to air your views in the US, wish we could get comments included in the Uk.
Hi Anthony
“In your letter you state: For example, here is a climate station of record located in a parking lot, at the University of Tucson, operated by the Atmospheric Sciences Department. ”
Later you correctly refer to: University of Arizona, Tucson.
Maybe you can rectify that error
OT, but I wonder if Dr. Roy has sent in his opinion…
Ice Ages or 20th Century Warming, It All Comes Down to Causation
Musings on the Vostok Ice Core Record
http://www.drroyspencer.com/2009/06/ice-ages-or-20th-century-warming-it-all-comes-down-to-causation/
I believe that the interpretation of the Vostok ice core record of temperature and CO2 variations has the same problem that the interpretation of warming and CO2 increase in the last century has: CAUSATION. In both cases, Hansen’s (and others’) inference of high climate sensitivity (which would translate into lots of future manmade warming) depends critically on there not being another mechanism causing most of the temperature variations. If most of the warming in the last 100 years was due to CO2, then that (arguably) implies a moderately sensitive climate. If it caused the temperature variations in the ice core record, it implies a catastrophically sensitive climate.
But the implicit assumption that science knows what the forcings were of past climate change even 50 years ago, let alone 100,000 years ago, strikes me as hubris. In contrast to the “consensus view” of the IPCC that only “external” forcing events like volcanoes, changes in solar output, and human pollution can cause climate change, forcing of temperature change can also be generated internally. I believe this largely explains what we have seen for climate variability on all time scales. A change in atmospheric and oceanic circulation patterns could easily accomplish this with a small change in low cloud cover over the ocean. In simple terms, global warming might well be mostly the result of a natural cycle.
I don’t know if this will be useful or not. Americans for Prosperity have a setup for submitting comments on the EPA proposal that I found very easy to use. They have a boilerplate letter, but it’s easy to do what I did–erase it and write your own. The link is
http://capwiz.com/americansforprosperity/issues/alert/?alertid=11825801&type=CU
Of course, Jason, China will not comply with any of the terms of a future CO2 treaty. They will cheat on everything. There is no moral code guiding that govt. They don’t even believe such a thing can exist. So they will cheat as they have in the past on various international agreements.
The result: More Western manufacturing will move to China as a result of an unbalanced playing field where the Chinese sign agreements but only the most naive western countries obey (read here: USA).
AT 2:36 pm IN time, link still isn’t working
Jeff Id- “Science doesn’t play favorites.”
I have a bridge for you, Jeff, it takes you to the planet where ‘science doesn’t play favorites’!:] On this planet, those who guard the grant money and power in the sciences, do indeed play favorites and this is why Global warming will be so hard to defeat, it is a religion backed by the state and the Fed.
THIS IS THE HEADLINE ON WEATHER.GOV
“…U.S. Temperature Warmer than Average for May…
The May 2009 temperature for the contiguous United States was above the long-term average, based on records going back to 1895, according to an analysis by NOAA’s National Climatic Data Center in Asheville, N.C”
Now, I went through one of the MO weather stations here http://agebb.missouri.edu/weather/history/index.asp
Now, indeed the AVG temp for may is the highest, at least since their easily accesible records started in 2000. HOWEVER IT”S NOT BECAUSE OF THE HIGH TEMPS. THE HIGH TEMPS ARE STATIC, IT’S BECAUSE OF WARMER LOWS.
I think this goes right in with the theory that clouds are a temperature control mechanism.
Can somebody PLEASE help out with this???????????
I think we are being gamed on temps.
Oh, and there’s a parallel temp system outside of GSS. That University of MO link is a seperate set of stations, most of them in truly rural areas. Are they a part of GISS?
If not, the Land grant universities might give us a check.
LOOK AT THE DATA YOURSELF.
MU’s data is downloadable and easily accessible.
RE: “The only thing that trumps both is nature, but that may take awhile. ”
Back when I was a eco radical, during the 1980s, there was a slogan I particularly liked:
“Nature Bats Last.”
At the time, I, like many of my cohorts, imagined the type of debased and dying world portrayed by Gore, Hansen, et al. I was a true believer, who felt that CO2 emissions and other “evils” would permanently tweak global temperatures to a higher band of operation, and, oddly, would also, in concert with desertification inducing human practices, dry up much of the world. A hot, dried up world, with a massive population of say, 10B people, was my nightmare at the time.
Now I’ve a different sort of nightmare. Indeed, nature bats last, and Sol is in the batter’s box presently. In this new nightmare, the cold comes, and gets worse and worse. Ironically (but really not) dry also comes to many mid latitude places. Then comes the ice. During the early stages of this new epoch, the bedraggled remnant engage in the mother of all world wars. The war plus the failing food supply results in the deaths of some 2 to 3 billion souls. As the lights start to go out in one now quasi isolated community of refugees after another, a small fraction of the wise contemplate a ten thousand year dark age, unfolding.
Nice effort….you tried anyway. Cap and Tax is on the way, the new dictator has spoken.
Been looking at your weather stuff for my 8 year old!
People in Government better take a look at Iran…it could happen here next.
It’s mostly lip service. They pretty much do what the administration wants.
carbon cap and trade is a tax.
a carbon treaty with china is a joke. They can’t make toys without poisionous paint and they knock off all our software as quickly as possible. what in the world benefits us with a carbon treaty? we should just borrow money from them and drop it by airplane over their rice paddies. Next issue is an unrealistic nuclear treaty with North Korea. Not in my lifetime.
“Boston-area art appraiser refuses to work for global warming skeptic
Climate of hatred: Prominent scientist refused service due to skepticism
Prominent MIT physicist and global warming skeptic, Richard Lindzen, was recently refused the services of a Boston-area art appraiser because of global warming.
As Lindzen described in an e-mail:
In our recent house fire, an 18th century oriental rug was burnt, and we needed an appraisal of its value for our insurance. We were referred to a dealer, [name withheld], who agreed to do the appraisal. However, when my wife, Nadine, brought him the burnt rug, he rudely turned her away saying that he had sent me an email explaining his position…
Here’s the text of the art appraiser’s e-mail to Lindzen:
I am sorry to inform you that after some consideration, I’ve decided not to perform the appraisal service that you’ve requested. Your writing on the subject of global warming is offensive to me personally, and I feel that I would have difficulty being an impartial appraiser of value given my view on the subject.
If you’re not familiar with Lindzen, here’s a clip from his bio:”
http://canadafreepress.com/index.php/article/12056#When:11:36:01Z
Money spontaneously arose in human economic interaction based on inherantly obvious needs. Anytime we allow government the power to create money out of thin air, we only invite government to print all it wants, and in the process steal our collective wealth through dilution.
We are just going to curse the day when we allow government to add this new dimension to fiat money. The value of money must be based on what people judge it is worth. Government attempts to maniuplate this value by forcing interest rates up or down. This is bad enough. It is a form of economic serfdom that now will be tied to the whims of climate alarmism. We are the most highly educated fools in human history if we allow this.