Submission to EPA hearing on ‘carbon pollution’ standards

Currently no scientific or logical basis for regulation of CO2 emissions, logician tells EPA

Guest essay by Terry Oldberg

Submitted to the EPA’s Public Listening Session on 111(d) Carbon Pollution Standards For Existing Power Plants  November 5, 2013 in San Francisco, California:

I’ve come to this hearing to play the role of logician. Logicians are interested in whether or not arguments reach valid conclusions. Consideration by the EPA of carbon pollution standards for existing power plants is based upon an argument whose conclusion is that an intolerable level of global warming would result from continued emissions of carbon dioxide into the atmosphere from combustion of fossil fuels. Earlier this year, I published a peer-reviewed article which proves this conclusion to be scientifically and logically unfounded.

The title of this article is “A Common Fallacy in Global Warming Arguments”; the article is available on the World Wide Web at http://wmbriggs.com/blog/?p=7923 .

In brief, the above referenced conclusion is drawn from an “equivocation,” that is, an argument in which a term changes meaning in the midst of this argument. By logical rule, to draw a conclusion from an equivocation is logically improper. To draw such a conclusion is the “equivocation fallacy.”

The equivocation fallacy is the source of the conclusion that an intolerable level of global warming would result from continued emissions of carbon dioxide into the atmosphere from combustion of fossil fuels. Scientific research is not the source of this conclusion though this is commonly assumed.

Currently, there is neither a logical nor a scientific basis for regulation of greenhouse gas emissions by the EPA. The EPA’s staff can and should learn the logical basis for this conclusion by reading the article at http://wmbriggs.com/blog/?p=7923 and carefully digesting its content. Then it should reverse regulations already on the books. Finally, it should halt efforts toward promulgating new regulations until a basis in science and in logic exists for them.

The federal government has spent 100 billion dollars on global warming research without producing a product that is useable for its intended purpose. Federally supported researchers have, however, made it seem to political leaders, journalists and members of the general public as though there is a useable product; they have done so through applications of the equivocation fallacy. Massive amounts of money have been spent on the assumption that the basis for federal, state and local regulation of greenhouse gas emissions is both scientific and logical. This state of affairs suggests the need for changes among the ranks of those individuals who plan and manage global warming research for the federal government.

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38 Responses to Submission to EPA hearing on ‘carbon pollution’ standards

  1. Chris Marrou says:

    A prime example of this equivocation occurred in the US last night on the “CBS Evening News.” The anchor (news reader) mentioned a report that carbon dioxide levels were now at the highest level in history (not true unless history started a hundred years ago), mentioned the spectre of global warming due to high CO2 levels, and then introduced a report on — air pollution in China, showing video of a smoggy Beijing and kids being forced to play in air-cleaned areas. Of course, we know CO2 levels have no direct link to smog, smog has no connection to atmospheric warming, and that CO2 is an invisible gas which doesn’t affect seeing, so CBS is either stupid or equivocating in finding an atmospheric problem and then blaming it on carbon dioxide. But with no warming for 17 years, whattaya gonna do?

  2. Theo Goodwin says:

    Excellent work, Professor Oldberg. And thanks for submitting your work at the EPA hearing.

    Your reasoning is excellent. I believe that you would agree that you have identified one among many equivocations commonly used by climate modelers. For some time, I have explained that climate modelers treat their models as if they were scientific theories. You get at the same point in a concise and useful way.

  3. sergeiMK says:

    “The federal government has spent 100 billion dollars on global warming research without producing a product that is useable for its intended purpose. ”

    Can you justify this statement with a breakdown of projects and grants given please?

  4. RMB says:

    Logic at last. If you fire warm gas from a heat source such as a paint stripping heat gun, at the surface of water. the heat will be blocked, presumably by surface tension. It is not possible to heat a gas and have that heat affect the surface of water. Radiation will penetrate the surface of water, physical heat will be blocked. For this reason the ocean cannot absorb “additional” heat from the atmosphere. AGW is complete nonsense. The blockage of heat is emphatic everybody should check it out.

  5. gaw858jf says:

    I expect the EPA to do want they want to do regardless of public comment.

  6. Theo Goodwin says:

    sergeiMK says:
    November 7, 2013 at 8:23 am
    “Can you justify this statement with a breakdown of projects and grants given please?”

    No need to. Just identify the grants that specify use of a supercomputer for climate modeling, that specify time-series analysis as the main tool of scientific research, or that fail to specify some natural regularity as the object of empirical investigation and throw them in the trash bin. None of them could possibly qualify as science.

  7. John Whitman says:

    Guest essayist Terry Oldberg said [in a submission] to the EPA’s Public Listening Session on 111(d) Carbon Pollution Standards For Existing Power Plants November 5, 2013 in San Francisco, California,

    “I’ve come to this hearing to play the role of logician. Logicians are interested in whether or not arguments reach valid conclusions.”

    - – - – - – - – -

    Terry Oldberg,

    I think it is wonderful you have engaged in the formal public evaluation process wrt the EPA.

    You are on the right intellectual path.

    John

    Personal Note: And I add that a central fallacy of the logic behind the harmful fossil fuel efforts by government bodies is begging the question (aka- avoiding an unfounded fundamental premise).

  8. R. de Haan says:

    Logican? Bwahhahhahhah, Science: Bwahahhahhh.

    The submission will be treated like “cursing in the church” and remain without any effect.

  9. john robertson says:

    Very logical thank you, I particularly agree with the last line, changes required in the ranks of our federal employes.
    These policy making bureaucrats, all occupy watchdog agencies created to act as buffers against the madness of mobs.To protect the public from the excesses of popular delusions and protect the individual citizen from the excesses of democracy.
    Yet in their activism for the great fear of the moment, they have abandoned reason,logic and their responsibilities, cost the taxpayer billions and attempted to imprison the individual in their regulations.
    If the watchdogs are useless, why should they continue to exist?
    When they turn rabid and attack, shall we still feed them?
    The legacy of this CAGW hysteria will be interesting, I am a taxpayer who feels betrayed by my government, particularly the bureaucracy, the academics,media and functionaries at the UN who have attempted to mug my wallet.Tax the air we breathe.
    The fallout as I see it will be simple;”Get a job”.
    Those three words every one of these freeloaders needs to hear.
    Ironically their attacks upon civl society have impoverished us taxpayers to the point we can no longer afford the luxury of government funded parasites.
    I think support for the UN may collapse as well.

  10. Merrick says:

    OK. While I may agree with many of the arguments put forth here, I’m a little concerned that the work is refereced to a “published … peer-reviewed article” which I can follow the link to but which has no indiciation of peer review at that location nor can I find any reference to this article (or any other my Mr/ Oldberg) appearing in the peer reviewed literature.
    That’s not a minimum requirement for consideration by any stretch of the imagination, but can someone point out where this article was published subject to peer revew or can we fix that claim if not?

    Thanks.

  11. Peter Miller says:

    Unfortunately, in the ivory towers of the EPA, an entrenched bureaucracy where the search for reasons for furthering internal growth is the greatest priority, the irritating submissions of outsiders are neither welcome, nor heeded.

    Entrenched bureaucracies do not seek truth or facts, but dedicate themselves to providing their gullible political masters with ‘proof’ of the need for further funds to accelerate their growth.,

  12. Jack O'Fall says:

    The climate models do make predictive inference:
    Given a CO2 level of XX and increasing a dX per year, aerosol particles of YY, sun activity of ZZ, and CH4 levels of WW, then we will see future temperature levels of ABCDEFGH.
    That seems to fit your definition of a ‘model’. And it can be evaluated: did the conditions it used as input happen? If so, was the result in line with the observations.
    Now, that doesn’t mean they are accurate, but I think they don’t fit your logical analysis.

  13. fhhaynie says:

    These public hearings are most likely political rather than scientific. They will simply count the for and against comments and hope that there are more in favor of “saving the world from CAGW”. I hope there will be enough against to signal it politically expedient to at least delay the regulations.

  14. MarkW says:

    RMB says:
    November 7, 2013 at 8:24 am
    —–
    Yet, somehow, the ice water on my desk still warms.

  15. Willis Eschenbach says:

    Terry, while I appreciate you submitting this, I fear that once again you are using unclear terms.

    Once again, as in your comments here in the past, you are appealing to the lack of a “statistical population” … I’ve asked you over and over for a definition of this term without success. For example, are all of the temperature measurements taken anywhere in Canada on June 13th, 2011 a “statistical population”? And if not, why not?

    You also distinguish between what you call a “model” and a “modele”. You say that the difference is that a “model” makes predictions and no projections … while a “modele” makes projections and no predictions. Here is your “disambiguation” of prediction and projection:

    This relationship follows because a “predictive inference” is a conditional prediction, like these:

    Given that it is cloudy: the probability of rain in the next 24 hours is thirty percent.

    Given that it is not cloudy: the probability of rain in the next 24 hours is ten percent.

    A “prediction” is an unconditional predictive inference. For example, “The probability of rain in the next 24 hours is thirty percent.” Notice there is no condition.

    I fear this definition doesn’t help, because it is simply not true that there is “no condition” in the final example. It is a prediction/projection which is made given the current conditions … and if there were different current conditions there would be a different forecast. How does that lack a condition?

    As a result, I’ve read your piece over at Briggs (which I cannot find in a peer reviewed form as you claim), and I’ve read this piece here, and I’ve come away knowing nothing more than when I started.

    w.

    PS—Here is a useful definition of a “statistical population”:

    Definition

    A population consists of everything or everyone being studied in an inference procedure. Populations can be large in size, although this is not necessary. What is important is that a population includes all of what we are curious about.

    Examples

    To make the concept of a population clear, we will look at a few examples:

    If we want to know the mean weight of all 20 year olds in the U.S., then the population is all individuals who are 20 years old and living in the U.S.
    If we want to know the proportion of middle aged men who do not have a heart attack after taking a certain drug, then the population is the set of all middle aged men.
    If we want to determine the mean I.Q. score of all ten year olds in Canada, then the population is all ten year old who are in Canada.

    OK, if we want to determine the mean temperature of all meteorological stations in Canada on June 13th 2011, then the statistical population is all of the temperature stations in Canada on that date, no? Yes?

  16. Rud Istvan says:

    The EPA hearing are for show, since required under the rules for setting regulations. Won’t change the outcome, because the EPA is clearly doing what Obummer wants.
    Let’s hope the narrow but important climate reg challenge SCOTUS has agreed to hear will open more avenues of attack to all the extra legislative fiat going on.

  17. Box of Rocks says:

    You, Sir, area a Heretic.

  18. Bob Greene says:

    I fully agree with the logic and the arguments. However, one of the things I’ve learned in 3 decades of dealing with the EPA and state regulatory agencies is that when I start to believe the regulations and policies should be based on facts and logic, I’m much better off drinking cheap whiskey until I get over it.

  19. A.D. Everard says:

    The EPA won’t listen, we all know that. The important thing here is that this fine article goes on the record, and that counts for something.

    Excellent work.

  20. Gail Combs says:

    Peter Miller says: @ November 7, 2013 at 9:07 am

    Unfortunately, in the ivory towers of the EPA, an entrenched bureaucracy where the search for reasons for furthering internal growth is the greatest priority, the irritating submissions of outsiders are neither welcome, nor heeded.
    >>>>>>>>>>>>>>>>>>>>>>>
    You are correct.

    Farmers fought tooth and nail against the National Animal Identification System (NAIS) It was even one of the top ten concerns floated at Moveon.org? just before Obama’s first election. We even managed to get the most comments ever seen on the Federal Register. 99% said not only NO! but HE!! NO. (I read most of them)

    This did not stop the WTO who was behind the traceability idea. The regulation hit the federal register a couple more times and then finally we get from the USDA “We heard you” and they changed the name and implemented it anyway!

    They have the time, money, man power and control of the MSM and most of all the infinite patience to shove through the legislation and regulations they want. We are stuck with no money, our limited spare time, the internet and a public with the attention span of a gnat who would rather follow the fashionable trend than bother to rub to brain cells together.

  21. Gail Combs says:

    sergeiMK says: @ November 7, 2013 at 8:23 am
    ………Can you justify this statement with a breakdown of projects and grants given please?
    >>>>>>>>>>>>>>>>>>>>>>>
    See: The climate industry wall of money, http://joannenova.com.au/2010/03/the-climate-industry-wall-of-money/

    Nearly $1 billion a day to change the climate… the invisible vested elephant in the room: http://joannenova.com.au/2013/10/nearly-1-billion-a-day-to-change-the-climate-the-invisible-vested-elephant-in-the-room/

    Or Jo’s Published paper Climate Money Appendix #1 page 17: http://scienceandpublicpolicy.org/originals/climate_money.html

    Oh and speaking of money, everyone should read “The story of one of the largest private wagers on the climate. A real climate bet.” http://joannenova.com.au/2013/10/want-a-real-bet-on-the-climate-the-story-of-the-largest-private-wager-on-the-climate/
    David Evans, the skeptic devoted six years to carbon accounting, building models for the Australian government to estimate carbon emissions from land use change and forestry. He was a believer but when new evidence was turned up he was ready to put money where his mouth is.

  22. Mr Lynn says:

    Sorry, but Terry Oldberg’s argument is just pettifoggery to me. The problem with the Alarmists’ argument is that it is pure speculation: there is no empirical evidence that anthropogenic CO2 can cause a dangerous, or even significant, level of “global warming” (assuming that term can be defined meaningfully). CO2 is a necessary and beneficial trace gas, and all evidence suggests that the Earth in general and humanity in particular would benefit from higher atmospheric quantities.

    The EPA will pay no more attention to this argument than they will to Terry Oldberg’s, but it makes the point, while his just obscures it.

    /Mr Lynn

  23. Dr. Bob says:

    I would guess that RMB has never run a Bomb Calorimeter. In that simple device, gas and solid/liquids are combusted within a closed system and the exothermic reaction is measured by the increase in temperature of a water bath of known volume. Thus heat energy is transferred to water so efficiently that at equilibrium one can measure fairly accurately the heat of combustion of essentially any substance. Blowing hot air at the surface of a liquid is just a very inefficient means of transferring energy from one source to another. It doesn’t mean that there is no heat transfer.

  24. Gary Pearse says:

    Making a submission is the right thing to do and you did that. However,Terry, this is thin porridge and easy to ignore by the EPA. We’re not even told what term changed in the middle of the argument (I couldn’t find it). A submission with any chance of having an affect should pick apart the statement that CO2 is dangerous pollution at levels so much lower than historical concentrations or levels in submarines that don’t harm health. If it is not dangerous, then the EPA has no business regulating it. You instead got into the main CO2/global warming argument – even the warmists weren’t calling it a dangerous pollutant before the EPA promulgated it. This is a terminal tactical mistake because, with the complex chaotic system that is climate, we aren’t able to categorically state that CO2 cannot cause significant global warming – it may be being masked at present by complex unrelated dynamics (I don’t believe this to be the case but I also can’t show that my belief holds water).

    I can state with 100% certainty that this pedantry will have no effect. This is definitely nowhere near the most worrisome presentation EPA will have received.

    “Earlier this year, I published a peer-reviewed article which proves this conclusion to be scientifically and logically unfounded.”

    This hand waving statement (and unnecessarily doubling up on “scientifically and logically” – lets hope there isn’t a scientifically but illogically sound conclusion or vice versa) reads like you are the only one in the world that has come up with this opinion (another reason to reject it). Your follow-up with what they are to do now that you have straightened them out takes even more away from your submission. Sorry, but anything less than a gritty presentation that forces them to have to deal with it really has the effect of not opposing their plans.

  25. don says:

    I’m confused. I thought logic deals with deductions that are necessarily true given the rules of inference and axioms (definitions) used, while science deals with induction about matters of fact that are not necessarily true? In other words, all black cats are black is necessarily true, but apparently from empirical observations not all cats are black is also true because there are white cats, and it may be the case that other different colored cats exist with more sampling. It further does not logically follow that because there are more black cats than white cats that we can logically deduce that we should prefer black cats over white cats (is never implies ought); or since warm temperatures seems to facilitate more active black cats while cold temperatures seem to correlate with more sedate white cats, it logically does not follow that we should (ought to) prefer policies that promote warm temperatures that favor aggressive black cats to the detriment of pacific white cats. In other words, there is no strictly logical basis for picking one course of action over another based on the facts, regardless of any equivocations about the nature of the facts.

  26. Lauren R. says:

    Unhelpful argument. The EPA has already determined that it can and should regulate carbon dioxide emissions. The hearings were only to determine the regulation methods and amounts. These arguments should have been presented 3 years ago (and were) during the “endangerment finding” phase. What the EPA needs to hear at this point is that carbon dioxide emissions have dropped dramatically since 2009 and continue to do so despite a growing economy and no regulation to date. It’s likely that’s why the EPA postponed their regulations for a year. We’re on track to achieve all the Kyoto Protocol goals (CO2 emissions 6% less than 1998 levels) in the next few years if the trend continues; something no nation that signed the treaty can say. With this in mind, does it make sense for the EPA to enact anything more than very modest restrictions on CO2 emissions? The argument should be made, if it can be, that anything more aggressive than what is already taking place by itself may have an adverse effect and result in increasing CO2 emissions. My suggestion would be that the EPA adopts minimal regulations that can be met with very little expense and no (costly and unproven) carbon-capture requirement, then adopt a wait-and-see approach.

  27. Pippen Kool says:

    “Currently, there is neither a logical nor a scientific basis for regulation of greenhouse gas emissions by the EP
    The equivocation fallacy is the source of the conclusion that an intolerable level of global warming would result from continued emissions of carbon dioxide into the atmosphere from combustion of fossil fuels. Scientific research is not the source of this conclusion though this is commonly assumed.”

    Models show that when more CO2 is added to the atmosphere the temperature will get warmer.
    The temperature in recent years has gotten warmer.

    I would say that the this does not support the hypothesis that CO2 does not cause warming.

    Water is necessary for life. Tell that to someone who is drowning.

    “Earlier this year, I published a peer-reviewed article which proves this conclusion to be scientifically and logically unfounded.
    The title of this article is “A Common Fallacy in Global Warming Arguments”; the article is available on the World Wide Web at http://wmbriggs.com/blog/?p=7923 .”

    Is this some sort of joke? Peer reviewed? By yourself? Am I missing something here? Where was it peer reviewed? A peer reviewed article without a bibliography? Come on, wuwt, what’s up?

  28. prjindigo says:

    It’s not a model unless it can be wrong in both directions. Error must exist both in an additive AND subtractive form. Most of the “model” lines I’ve seen in the charts NEVER go down.

  29. dbstealey says:

    Pippen Kool says:

    “Models show that when more CO2 is added to the atmosphere the temperature will get warmer.
    The temperature in recent years has gotten warmer.”

    Wrong, as always. The real world shows that as CO2 rises, temperatures are flat to declining.

    But since the alarmist crowd is composed of True Believers like Pippen, facts mean nothing to them. They Believe. That is enough.

  30. Solomon Green says:

    Pippen Kool
    “Models show that when more CO2 is added to the atmosphere the temperature will get warmer.
    The temperature in recent years has gotten warmer.”

    Two separate statements. If Pippen Kool understood logic he would know that even if both his statements were true the second statement does not validate his “models”. Nor even if it did would it validate CAGW.
    I have devised a model which stipulates that when continents move the weather will get warmer. The temperature in last 150 years has gotten warmer. And continents have moved during this period. Would any rational person give any credence to my model?

  31. Its very nice explanation. I’m only afraid that the last thing EPA wants and understands is logic. Oh, perhaps one logic they follow well after all, the logic of power.

  32. “The equivocation fallacy is the source of the conclusion that an intolerable level of global warming would result from continued emissions of carbon dioxide into the atmosphere from combustion of fossil fuels. Scientific research is not the source of this conclusion though this is commonly assumed.”

    Intolerable? No, but there would be serious implications to human civilization if/when ocean levels rise to the point where land is reduced by just 5%. I’m not talking about rich people losing their summer homes on the Jersey shore, but rather low-lying countries (i.e. Bangladesh, Japan, Indonesia, etc.) that would have to be evacuated en masse and/or see most of their farm lands destroyed.

  33. Scute says:

    I read the link on equivocation. Very interesting. It gets worse though, because in the recent IPCC Working Group 1 press conference for AR5, the SPM.10 graph they presented showed the ‘historical’ portion of the temperature plot which climbed a nice, healthy 0.33 degrees between 2000 and 2010 before being projected to 2100:

    http://www.bbc.co.uk/news/science-environment-24292615

    (SPM.10 presented at 1:30)

    That ‘historical’ plot was not the instrument record as you might reasonably expect as you sat there taking in their carefully crafted 30 second sound bite on the news. It’s a hindcast, a model projection from 1860 to the present. It’s patently inaccurate, especially over the last 17 years but was left in there because they could swipe out the fig leaf excuse that they are projecting to 2100 and the ‘historical’ plot is the ‘historical’ portion of that 240 year plot.

    That press conference was seen all over the world and that graph has indoctrinated hundreds of millions of viewers who don’t have the time to check the details.

    Scute

  34. M E Wood says:

    The water on the desk will warm because the glass it is contained in warms from the air.
    The sea is not surrounded by glass so how it warms from air I do not know

  35. Mario Lento says:

    Pippen Kool says:
    November 7, 2013 at 6:43 pm “Am I missing something here?”
    +++++++++++
    YES YES YES YES YES…
    There now get lost. You’re unable to have a cogent conversation when you make such wrong headed claims.

  36. RMB says:

    You are spot on. A warmer atmosphere does not warm the ocean because surface tension blocks physical heat. Only radiation penetrates the surface.

  37. RMB says:

    If you try to heat uncovered water you will find that the heat is emphatically rejected by the surface of the water. If you cover the surface of the water with a floating sauce pan and apply the heat through the sauce pan, the heat readily enters the water. The fact is that uncovered water is protected by surface tension and the tension is cancelled by the floating. The bomb thing is not relevant. Because of surface tension AGW is nonsense its just that simple. Also because you can’t store heat in the ocean, you can’t boil it away, neat eh!

  38. RMB says:

    The heat goes through the glass not through the surface. Get a heat gun and try putting heat through the surface of water in a bucket.

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