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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[snip – “Flanagan”, since this is a USA issue, and since you are not a US Citizen, this is one post where I can confidently say that your opinion is not needed, not wanted, and not relevant. Sit this thread out. Anthony ]
This article, by Dr. Economides, should be required reading by the pseudo/slogan/sound-bite scientists populating the EPA.
Princess Nancy is understandable in that she has a vested interest in T. Boone’s methane/wind turbine enterprise.
————————————————————-
Obama Adminstration’s Energy Radicalism
By Dr. Michael J. Economides
http://icecap.us/images/uploads/ObamaEnergyRadicalism.pdf
The Obama Administration seems to be unmoved by the fact that according to almost all estimates, by the year 2030, while the world energy demand will increase by 50 percent, oil, gas and coal will still account for 87 percent of world energy. While international pressure is often cited for the recent government actions, in this era of American self-flagellation, one thing should be made abundantly clear: global warming rhetoric has always been largely a full frontal attack on the United States, its lifestyle and its apparent success compared to other countries, especially in Europe. It is clearly ironic that Pravda, the former official instrument of the Soviet communist party has implored the United States to stop “carbon communism”.
The EPA of course does not offer solutions to the 87 percent problem and it defers to Congress to do so. Surely Congress will find the right solution from a position of knowledge as demonstrated by the honorable Nancy Pelosi who on NBC’s Meet the Press said “I believe in natural gas as a clean, cheap alternative to fossil fuels,” and lest one thought she misspoke, she went on to say in the same interview that natural gas “is cheap, abundant and clean compared to fossil fuels.”
I’m not a US resident (I live in Sweden) but I’d like to contribute with my view on the total irrationality in the following which seems to be central in AGW science (the exact quote is from skepticalscience.com):
“The key point is that all the models fail to predict recent warming without taking rising CO2 levels into account. Noone has created a general circulation model that can explain climate’s behaviour over the past century without CO2 warming.”
This is a very clever statement, but it actually means nothing more than exactly what it says. That climate science can’t recreate historic climate without using CO2 as a factor in the computer models.
It does not in fact mean that the real world has the same limitation.
And, since NASA now is well on their way of explaining the infamous rise in temp. using aerosols in their models, there could very well come a day when all models can recreate past climate without CO2 as a major player.
The aerosols might not be it either, even if they constitute a much more easily handled problem than CO2.
The key point is in reality that the science is far from settled. Very important.
Vodoo: No, watch the remaining vestiges of our electronics industry move to China and India where the politicians are semi-sane.
No!. They are absolutely sane, they and the rest of world governments, as Peter Huber said: “It has proved only that with carbon, governments will say and sign anything—and then do less than nothing. The United States should steer well clear of such treaties because they are unenforceable, routinely ignored, and therefore worthless.
http://www.city-journal.org/2009/19_2_carbon.html
I hereby invite all US companies dealing with those chemicals, to come on this side of the boarder (Canada) and continu their business as usual.
Anthony,
This whole “why isn’t the EPA regulating water vapor” thing is rather silly, and detracts from the other points you are making. The fact that absolute humidity increases with temperature (while relative humidity stays constant) is not particularly complicated, since the saturation vapor pressure is a function of temperature. To put it in simple (though not quite technically correct terms), warmer air “holds” more water than cold air, so on balance a warmer atmosphere would have a greater volume of water vapor. If you want to critique climate feedbacks, your efforts are better focused on things like clouds where considerable uncertainty actually exists.
As far as the weight of hexaflouride goes, carbon dioxide is also heavier than most other gases in our atmosphere, yet somehow we do not all suffocate from a cloud of it hanging around the surface of the planet. See http://www.agu.org/pubs/crossref/1997/97JD00130.shtml for example.
REPLY: Zeke, I’m really not the least bit interested if you think it is silly or not. You are part of the CO2 regulation cheerleading team, so your bias precedes you.
You do have one point worth discussing though. Can you show me a measurement of SF6 in the stratosphere? Can you show that given its cost (and recycling efforts due to that cost) that significant amounts are making it into the atmosphere?
I should think that it would be useful to have a clearinghouse of submissions and/or talking points held centrally. I don’t know if any of the more popular climate blogs is up for holding that, but I’d be delighted to help.
My submission will probably focus on the following points: As global warming / climate change and anthropogenic contributions are global in both nature and effect, U.S. policy would be better served by foreign aid assisting the 2 billion people in the developing world to liberate themselves from burning wood and getting access to electricity. Counter-intuitive as it may sound, given the inefficiency of wood and the vast numbers of people dependent upon it for fuel, it would be more cost-effective to give them access to electricity even if the fuel source proved (as would most likely be the case) to be coal. I am developing this line of thought over at http://newsfan.typepad.co.uk/liberals_can_be_skeptics_/ and would welcome some help there.
REPLY: As a UK resident, your opinion to the USA EPA would be for naught. – Anthony
Dave D (13:19:21) :
“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”
The CO2 proposed finding is not yet open to comments. The proposed finding must first be published in the Federal Register, then there are 60 days for public comments. The publication should happen any day now.
However, you can make comments on other EPA issues shown on the link I gave above, just scroll down to an issue you like, click on the “Send a comment or Submission” link, and the comment form should pop up.
Am i the only one to notice that even if it says CO2 in the picture, the image is C2O2?
But i would think the atoms would bind more like O=C=C=O to make sense.
Zeke: perhaps you could explain why any increase in water vapor must come from temperature change, instead of, say, changes in transpiration? Would not such a change be a climate “forcing” not “feedback”? If the EPA wants to regulate human climate forcings, why not landuse or soot? The answer is because following the EPA’s logic to its proper conclusion results in asininity.
Hi Anthony,
Recently relocated back to SF, my old home town, so hopefully the EPA will have to find another reason to ignore my thinking…
Anthony,
Does http://www.atmos.washington.edu/~beckya/Stratospheric%20paper%20(GRL).pdf work as a reliable reference for SF6 in the stratosphere? In general, since halocarbons are “heavy” particles, there would never have been an ozone depletion problem if they were not present in the stratosphere in a meaningful quantity.
REPLY: As I read it: 3 parts per trillion of SF6 in the area of greatest concentration (and the coldest) on the planet. Gosh. How about the tropics where LW interaction is really ramped up? Any measurements there?
Sulfur Hexafluoride (SF6) has a GWP of 22,000 over 100 years but 15,100 over 20 years (IPCC TAR). The GWP value depends on how the gas concentration decays over time in the atmosphere. This is often not precisely known and hence the values should not be considered exact.
So where does 3 parts per trillion get us in warming impact? Not very far
– Anthony
[snip – I’m not getting into this water vapor issue with you, I haven’t time right now as I’m off for the rest of today. Maybe another day, but you are welcome to take it up with other commenters who have raised issue with you.- Anthony]
Canadian Maurice Strong*, aka Mao Stlong, is the evil genius Man Behind the Curtain.
Strong was last reported to be somewhere in China.
…-
“Key Obama Climate Change Exchange Being Swayed by Top U.N. Officials
Five members of the Chicago Climate Exchange advisory board are present or former top-ranking U.N. officials — including one who received $1 million from a convicted South Korean lobbyist in the Oil for Food scandal.
A greenhouse gases trading system funded with the support of then-Illinois State Sen. Barack Obama, which is likely to play a major role in his $650 million cap-and-trade initiative, lists five present or former top-ranking U.N. officials on its advisory board who’ve had enormous influence over climate change matters — including one who received $1 million from a convicted South Korean lobbyist.
The most controversial figure of the five, Maurice Strong, was one of former Secretary General Kofi Annan’s key aides at the U.N. for years until the Iraq Oil-for-Food scandal forced him to leave. Since then Strong has lived mostly in China. Calls to the exchange for comment about Strong’s role, and that of other U.N. figures, were not returned.”
http://www.foxnews.com/politics/2009/04/20/key-obama-climate-change-exchange-swayed-officials/
*small dead animals: Maurice Strong Steps Down
Maurice Strong, a long-time Canadian businessman and currently the top UN envoy for North Korea, will suspend his work for the United …
http://www.smalldeadanimals.com/archives/001739.html
People making comments should note that under current law, “cost=benefit analysis” is required for a gas like CO2 which is indispensable to all human activity. See http://www.washingtonpost.com/wp-dyn/content/article/2009/04/01/AR2009040103717.html
The “endangerment” finding should likewise specifically analyze the elements of endangerment of the proposed reductions in this necessary metabolic gas to the same extent as the supposed elements of endangerment from further increases.
Is our government really going to make breathing illegal. Maybe they’ll lets us inhale and not exhale. (The inverse Clinton rule?)
Has anyone but me seen Lord Moncktons letter to Congress? It is from March 30 and totally comprehensive. I am not a US citizen, but could someone in the US please send a copy to the EPA? Link is: http://scienceandpublicpolicy.org/images/stories/papers/reprint/markey_and_barton_letter.pdf
Yep, that SF6 is scary stuff. Especially since it comes in at a Whopping 6.5 part per TRILLION. Yep, you heard it right. 6.5 ppt. The approx. equivalent of 140 parts per Billion of CO2. It seems to be increasing at about 60%/decade, so in 100 years it will be equivalent to approx 1 part per million of Co2.
Terrifyin it is. Yep
Maybe slightly off topic, but I second Jim Cripwell’s question:
“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?
Or SF6, or N2O, or O3, for that matter? The most abundant of these ultratrace gases is CH4, somewhere around 1 or 2 ppm, the others are ppb or less. How can they possibly matter compared to H2O at percent levels, or CO2 in the hundredths of a percent? This chemist wants to know.
It probably should be pointed out that Zeke Hausfather is on the payroll of the Grantham Foundation for the Protection of the Environment — and being a recipient of their financial largesse, he must dance to the tune they call. If Zeke honestly admitted that CO2 has a negligible effect on the climate, Grantham’s payola would go elsewhere.
The Grantham Foundation for the Protection of the Environment has a very heavy pro-AGW agenda, as you can guess from their name. They pay organizations like Zeke’s to be a front for their alarmist agenda.
Since Zeke isn’t telling you this, I thought I would.
[snip -religion and prophesy is not relevant to this topic]
The new head of NOAA Jane Lubchenco is making up things.
“climate models are now sufficiently “robust” to help scientists start to do the same with climate, to help businesses, elected officials and regulators make good decisions on issues like where to put buildings or roads or wind farms. ”
http://www.thescienceforum.com/A-meaningful-consensus-on-global-warming-17612t.php
Dr. Lubchenco said, one of her goals at NOAA is to establish a climate information service modeled on the National Weather Service, which is part of the agency. The weather service provides “just a phenomenal service” in making information available in ways ordinary people can understand it and act on it, she said. Dr. Lubchenco believes climate models are now sufficiently “robust” to help scientists start to do the same with climate, to help businesses, elected officials and regulators make good decisions on issues like where to put buildings or roads or wind farms.
“It is no longer enough to know what the wind patterns were for the last hundred years,” she said. “You want to know what they will be for the next hundred years — and they undoubtedly won’t be the same. So there are huge opportunities to provide services to the country.”
The idea, which she said had been broached by the National Academy of Sciences, would have to be a joint effort with other agencies involved in the issue, like the Environmental Protection Agency, NASA or the United States Geological Survey, she said.”
Jane Lubchenco has a history of fabricating science.
As an OSU professor and researcher Jane fabricated a connection bewteeen ocean dead zones and AGW.
But her own research found NO Connection to AGW.
“””””Researchers at OSU said the erratic wind patterns of recent years are consistent with changes predicted in computer models that attempt to simulate the effects of global warming.
But they caution that at this point it is unclear what — if any — link the dead zone has to climate change.
“We can say that what we are seeing is totally consistent with the changes predicted by the models,” said Jane Lubchenco, OSU marine ecologist”””””””.
The sum total of here basis for spreading her farce is their characterizing wind patterns as erratic and therefore consistent with computer models.
Lubchencho perpetrated a farce even when her own research could NOT establish “what — if any — link the dead zone has to climate changes.”
She is now contributing to the fabricatiion that climate models are robust enough to predict where wind will be.
This is the technique that has ushered along much of the AGW movement.
It’s called fabrication. Or finding data where none exists. And it travels far and wide by accomplices, the willing media and foolish activists.
http://en.wikipedia.org/wiki/Dead_zone_(ecology)
Chemical fertilizer is considered the prime cause of dead zones around the world.
Other natural oceanographic phenomena can cause deoxygenation of parts of the water column. For example, enclosed bodies of water such as fjords or the Black Sea have shallow sills at their entrances causing water to be stagnant there for a long time. The eastern tropical Pacific Ocean and Northern Indian Ocean have lowered oxygen concentrations which are thought to be in regions where there is minimal circulation to replace the oxygen that is consumed.
Oregon
Off the coast of Cape Perpetua, Oregon, there is also a dead zone with a 2006 reported size of 300 square miles.[2] This dead zone is unique in that it only exists during the summer, perhaps due to seasonal wind patterns.
Gulf of Mexico
Currently the most notorious dead zone is a 22,126 square kilometer (8,543 square mile) region in the Gulf of Mexico, where the Mississippi River dumps high-nutrient runoff from its vast drainage basin, which includes the heart of U.S. agribusiness, the Midwest, affecting important shrimp fishing grounds. This is equivalent to a dead zone the size of the State of New Jersey. A dead zone off the coast of Texas near Freeport was also discovered in July 2007.[3]
Reversal of dead zones
Dead zones are not irreversible The Black Sea dead zone, previously the largest dead zone in the world, largely disappeared between 1991 and 2001 after fertilizers became too costly to use following the collapse of the Soviet Union and the demise of centrally planned economies in Eastern and Central Europe. Fishing has again become a major economic activity in the region.[4]
While the Black Sea “cleanup” was largely unintentional and involved a drop in hard-to-control fertilizer usage, the U.N. has advocated other cleanups by reducing large industrial emissions.[4] From 1985-2000, the North Sea dead zone had nitrogen reduced by 37% when policy efforts by countries on the Rhine River reduced sewage and industrial emissions of nitrogen into the water.
The chemical Aluminium sulfate can be used to reduce phosphates in water.
http://seattletimes.nwsource.com/html/nationworld/2004182252_webdeadzone15m.html
Off the coast of Washington, the old numbers tell a different story, said University of Washington oceanographer Barbara Hickey. Zones of low-oxygen water have long been common in the summers.
“Definitely in the ’60s and ’70s we saw numerous examples of extremely low oxygen,” she said. For the past three years, Hickey and her colleagues have been collecting more detailed data from a research buoy off Kalaloch, on Washington’s coast. But it’s too early to say whether the dead zones are intensifying or spreading, Hickey said.
Hickey also cautioned against drawing conclusions about the role of global warming in Oregon’s dead zones. “It’s dangerous to project out too soon.”
[snip truly OT, let’s stick to the EPA here]
Who knows…Perhaps you were invaded by aliens who do not breath oxygen and consequently do not exhale CO2 and they need to change earth’ s atmosphere to a more friendly for them composition.
Link for my numbers on SF6
http://en.wikipedia.org/wiki/Sulfur_hexafluoride
timetochooseagain,
A net increase in transpiration would be balanced by an increase in precipitation, all things being equal. There certainly could be local effects where increasing transpiration could increase the humidity without reaching the dew point, but on larger scales the water vapor content of the atmosphere is constrained by the temperature.
Smokey,
To be perfectly honest, I’d never even heard of the Grantham Foundation before someone brought it up here awhile back. Good digging though. I blog in my spare time (or to procrastinate working on the energy use mapping project I’m currently involved with), just like the rest of you, and my views are certainly not influenced by the alumni or foundations that support the Yale Forum. If you complain (and rightly so) about people unfairly accusing skeptics of being on the “payroll of big oil” the least you could do is reciprocate the favor. Regardless, given that this is a science blog, shouldn’t our arguments focus on the content of our ideas?