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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April 19, 2009 12:45 am

>>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
.

April 19, 2009 1:07 am

.
>>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
.

GailC
April 19, 2009 7:32 am

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

Ellie in Belfast
April 19, 2009 9:11 am

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

Ellie in Belfast
April 19, 2009 9:14 am

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

Ron de Haan
April 19, 2009 10:24 am

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

April 19, 2009 11:51 am

>> 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.

Ellie in Belfast
April 19, 2009 12:53 pm

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).

Keith W
April 19, 2009 1:01 pm

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

Eric Anderson
April 19, 2009 4:28 pm

“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 . . .

old construction worker
April 19, 2009 5:57 pm

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.

SG
April 19, 2009 6:14 pm

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…

Tom in Florida
April 19, 2009 7:16 pm

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!!

Ron de Haan
April 19, 2009 7:32 pm
carlbrannen
April 19, 2009 7:55 pm

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.

Rick Gibbs
April 20, 2009 5:05 am

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

Jim Cudahy
April 20, 2009 8:56 am

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.

Bill from Pittsburgh
April 20, 2009 12:19 pm

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.

April 21, 2009 5:50 am

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.

April 21, 2009 5:54 am

>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.”

Jon W
April 21, 2009 6:02 am

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?

May 2, 2009 7:27 pm

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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