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.
Fun stuff: http://news.nationalgeographic.com/news/2009/01/090113-alien-earth-frozen.html
Zeke Hausfather (13:40:51) : “ The fact that absolute humidity increases with temperature (while relative humidity stays constant) is not particularly complicated, …”
AH is the mass of water vapor in a volume of air. (aka volumetric humidity) I don’t see temperature in this definition.
Did you mean Maximum absolute humidity in your statement?
RH is defined as the ratio of the partial pressure of water vapor in a gaseous mixture of air and water vapor to the saturated vapor pressure of water at a given temperature. During a day with rising temperature the RH decreases; evening brings cooling and RH increases.
What am I missing? This is so complicated.
Zeke-how can models possibly represent water vapor well when it is so tied up with cloud processes? And why do you make claims about water vapor being “constrainted” by temperature when, for feedback to be correct it needs to be ~determined~ by temperature, not merely “constrained”? But I notice you didn’t challenge my statement that regulation of something simply because it is a human climate forcing leads to asinine results. And I notice you still fail to understand that regional climate is way more important than global.
For non-US residents, I received this e-mail from the EPA:-
Thank you for your email to ghgendangerment@epa.gov. While it is not possible to submit evidence to the public hearings fromthe UK, you are welcome to submit written comments to the public Docket,docket ID No. EPA-HQ-OAR-2009-0171. Written statements and supportinginformation submitted during the comment period will be considered withthe same weight as any oral comments and supporting informationpresented at the public hearings. Although EPA’s proposed finding has not yet been published in theFederal Register, a pre-publication version is available atwww.epa.gov/climatechange/endangerment.html. Comments can be officiallysubmitted upon publication in the Federal Register, using instructionstherein. Again, thank you for your email.
So my comments will concentrate on the IPCC climate model. Dr. Syun Akasofu’s recent post seems like a good starting point.
http://wattsupwiththat.com/2009/03/20/dr-syun-akasofu-on-ipccs-forecast-accuracy/
With some background on CO2 and greenhouse effect:-
http://brneurosci.org/co2.html
Something on feedbacks in the climate system:-
http://wattsupwiththat.com/2009/03/30/lindzen-on-negative-climate-feedback/#comment-107722
And CO2 over geological history:-
http://www.pnas.org/content/99/7/4167.full
The final point
http://wattsupwiththat.com/2009/04/16/consensus-climate-science-what-would-thomas-huxley-say/
Specifically
Extreme claims require extreme proof
.
It is a canon of common sense, to say nothing of science, that the more improbable a supposed occurrence, the more cogent ought to be the evidence in its favor.
-Science and the Christian Tradition, “An Episcopal Trilogy,” p. 135
I don’t see how they are going to enforce this at all.
Are they going to close coal-fired power plants (the new vehicles suggestion is just a red herring – you don’t declare something a danger and then only regulate one little part of the emissions).
How are they going to regulate N20? Almost all of it comes from the break-down of nitrogen fertilizer after it is used by farmers – are they going to regulate fertilizer usage?
How are they going to regulate Methane? We don’t even know where it is coming from right now (although the oil and gas industry was partly responsible for the run-up in Methane in the 1970s and 1980s when they just released Methane (natural gas) into the atmosphere). The latest increases in the Methane are somewhat of a mystery.
How do we stop the bureaucracy in this case when it starts finding how much power they have now.
What bothers me, aside from the massive transfer of power from individuals to bureaucrats and special interests, that this legislation will support, is the simplistic chemistry that is portrayed in these ‘Greenhouse effect’ diagrams.
I don’t know the actual numbers, but I believe the biomass of microbes and plant species is massive in comparison to atmospheric CO2, and all those plants and microbes produce small organic molecules which have significant vapor pressure and will be released into the atmosphere — a plethora of short chain alcohols, aldehydes, acetylenes, hydrocarbons etc are products of life on the planet. These compounds individually don’t account for much and probably have a short lifetime in the atmosphere, but they are strong infrared absorbers and taken as a whole are probably more significant in their impacts than the amounts of ‘bad’ man-made chemicals (mainly man-made CO2) that are constantly being blamed for every(negative)thing under the sun.
I don’t believe any models take them into account.
Incidentally, I believe we should be putting as much CO2 (and H2O) into the atmosphere as we can and should be developing the lowest cost most efficient sources of energy we can. I don’t find living a primitive lifestyle particularly appealing — I also don’t look forward to longer colder winters which appears to be the goal of the AGW crowd. I also don’t think governments should be imposing secular evironmental religions — which is what AGW is — on the populace.
Slightly OT but I heard today on the, infamous, BBC that the “botty burps” of insects are estimated to account for 20% of all methane produced on the planet.
What action do the AGWers intend to take to correct that?
Enjoy.
At 6.5 part per Trillion I’d say that the industry has a good control over the emission of SF6. But controlling naturally occuring molecules like those of CO2, N2O and CH4, which human contribution is relatively insignificant… good luck to us all!
Don’t you remember somebody with this kind of voice?
Yeah, but I quit hanging out at those places. 🙂
Zeke said (14:39:37) :
‘To be perfectly honest‘?? I advise you to stop digging that particular hole, Zeke.
The home page of your own blog states quite clearly:
I guess I don’t blame you for trying to hide the fact that you’re on Grantham’s payroll. It’s very embarrassing when it’s discovered that you’re shilling for a pro-AGW climate alarmist foundation [they fund treehugger.com, and many similar blogs, too]. But trying to cover it up here was a mistake.
Just a thought…. is it not possible that the concentrations of some of the major gases such as Nitogen or water vapour may have decreased slightly in the atmosphere, which would increase the concentrations in percentage terms or ppm as a whole of some of the smaller gases such as CO2?
Whenever anyone says “to be perfectly honest” or “to tell the truth”, it’s a good bet that there will be more than a little prevarication that follows… At least that’s what my Dad said.
Ouch for Zeke
Might it be wiser to NOT warn the EPA of the stupidity of what they’re considering? If we let the EPA make complete asses of themselves, then when the whole AGW bubble bursts, the end result will be all the more useful.
If we make good points now, they will be cool their inflammatory rhetoric (avoid calling us “flat Earthers” and the like.) Then when the arctic sea ice has fully recovered and it is undeniable that the whole thing was misguided, they can wiggle out. They could claim they were just trying to be cautious and didn’t really plan to screw up the whole economy to limit an essential gas.
This thread is going to be more tightly moderated than others. The topic is addressing the EPA. OT posts, troll posts, or posts not deemed appropriate for the thread will be snipped or deleted wholesale.
Murray Carpenter (15:23:30) :
The percentage of “gases” in the atmosphere is a relative one. Nitrogen and oxygen are the most abundant gases in the atmosphere and is not affected significantly by changes of temperature. However, water vapor is affected by temperature. The air at the poles is quite dry and of course if in fact the amount of CO2 is somewhat homogenous in the atmosphere, it’s concentration will be higher in the atmosphere at the pole than at the equator.
Bill Illis (14:59:18) :
“I don’t see how they are going to enforce this at all.”
As I have been writing for months, California via AB 32 has already begun regulating GHGs. There is a measurement and reporting requirement, even down to the type and quantity of fuel burned in furnaces and boilers (a minimum size applies to that). Several enforcement regulations are on the books, with emission reports being verified by independent third-party auditors.
“Are they going to close coal-fired power plants (the new vehicles suggestion is just a red herring – you don’t declare something a danger and then only regulate one little part of the emissions).”
They cannot close all the coal-fired plants right away, as that would lead to an electric power crisis. They can, though, require carbon capture with sequestration (CCS) modifications. CCS will increase the cost of electric power by 50 percent or more, depending on the age of the coal-fired plant.
California (as usual! ) took a novel approach: legislated that no coal-fired plants are allowed in this state. Further, no imported power produced by coal is allowed, after current contracts expire. Then, California added a renewable energy requirement, so the effect is that wind and solar and geothermal will replace coal power within 15 to 20 years or so.
“How are they going to regulate N20? Almost all of it comes from the break-down of nitrogen fertilizer after it is used by farmers – are they going to regulate fertilizer usage?”
The regulations can first regulate non-fertilizer sources, and could conceivably require a change to alternate fertilizers, that emit less or none at all — I am no fertilizer expert but that is their usual line of attack.
“How are they going to regulate Methane? We don’t even know where it is coming from right now (although the oil and gas industry was partly responsible for the run-up in Methane in the 1970s and 1980s when they just released Methane (natural gas) into the atmosphere). The latest increases in the Methane are somewhat of a mystery.”
Again, they regulate known emission sources, such as natural gas producers, pipelines, natural gas users, and refineries. They also require bio-gas collection systems for areas that spontaneously generate methane such as from dairy cattle manure.
“How do we stop the bureaucracy in this case when it starts finding how much power they have now.”
The bureaucracy can be stopped only by legal challenges, IMHO. As others have written before, the threshold is so low in agency regulations that it is virtually impossible to stop once they have some science (no matter how bad) to point to that supports their regulation.
There are many, many, avenues for legal challenges, though. Some are procedural, and a few are substantive.
In fact, the EPA gets sued rather regularly. A google search on the keywords “lawsuits against EPA” turned up more than 1,500,000 entries. A search on “sued” AND “EPA” turned up 560,000 entries. (It keeps a substantial number of lawyers busy…)
Methane has almost no effect because it’s spectral lines are either swamped by H2O (same for CO2!) or are at shorter wavelengths where it’s irrelevant since there is no thermal flux there. I don’t know where the hysteria about it comes from.
Anthony, email me and I’ll send you a nice Modtran 5 PowerPoint slide with the atmospheric absorbance of all the infrared absorbing gases on it. SF6 doesn’t rate.
Can the EPA be sued to provide proof that these gases are pollutants and provide a danger to humans or has the government created an environmental dictatorship called the EPA?
Excuse me for being dense here, according to information I copied earlier, this e-mailaddress: “ghgendangerment@epa.gov.” has this qualifier: ” Please use this contact information for general questions only. ” Although it is noted in comment(s) above as being used to send comments. Is this the correct email?: “GHG-Endangerment-Docket@epa.gov“
Thank you
The Ethanol Bubble Pops in Iowa
More evidence the fuel makes little economic sense.
http://online.wsj.com/article/SB124000832377530477.html
The National Oceanographic and Atmospheric Administration noted in July 2007 that the ethanol boom rapidly increased the amount of fertilizer polluting the Mississippi River. And this week, University of Minnesota researchers Yi-Wen Chiu, Sangwon Suh and Brian Walseth released a study showing that in California — a state with a water shortage — it can take more than 1,000 gallons of water to make one gallon of ethanol. They warned that “energy security is being secured at the expense of water security.”
For all the pain ethanol has caused, it displaced a mere 3% of our oil usage last year. Even if we plowed under all other crops and dedicated the country’s 300 million acres of cropland to ethanol, James Jordan and James Powell of the Polytechnic University of New York estimate we would displace just 15% of our oil demand with biofuels.
But President Barack Obama, an ethanol fan, is leaving current policy in place and has set $6 billion aside in his stimulus package for federal loan guarantees for companies developing innovative energy technologies, including biofuels. It’s part of his push to create “green jobs.” Archer Daniels Midland and oil refiner Valero are already scavenging the husks of shuttered ethanol plants, looking for facilities on the cheap. One such facility may be the plant in Dyersville, which is for sale. Before we’re through, we’ll likely see another ethanol bubble.
Smokey,
In the interests of honoring the wishes of the moderator to limit off topic discussion, I’ll be brief. You may not believe me, but I didn’t even notice that little disclaimer on the Yale Forum until a commenter here at WUWT mentioned it a few months back. I certainly don’t run the place, I just contribute an occasional article, so I know next to nothing about who pays for website development and hosting. I know nothing of good nor bad about the Grantham Foundation, and they certainly have no sway over editorial content. Regardless, in scientific arguments people should be judged on the merits of their argument rather than the institutions or foundations that support their work, and that applies equally to folks be they at Yale, Cato, the Discovery Institute, or anywhere else.
Reply: Enough of this. Do not respond Smokey. The topic is responding to the EPA ~ charles the moderator
The ethanol bubble may have popped but the same EPA that finds CO2 a danger and has blinders for the environmental impact of corn to ethanol production is seriously considering increasing the ethanol from corn content from 10% to 15% to try and re-inflate this bubble. I have not seen a clearer example of lobbying money trumping science AND the environment than I have in the last few weeks.
“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. ”
I thought that the basis for the Western legal system was that it was better that a guilty man walks free than an innocent man be found guilty. So why, and under what democratic, legalistic or scientific process, have the EPA created this “Dirty Half-Dozen” of trace atmospheric-gases that “threaten the public health and welfare of current and future generations”.
Is this the findings of a trial, held in camera, in which a careful selection of witnesses guarantees a guilty verdict?
Is the calling for public comment a genuine attempt to seek the truth or a cynical ploy to add a veneer of legitimacy to the findings!
Is this really the US in the 21st Century?
The deliberate linking of familiar chemicals such as carbon dioxide and methane with more sinister sounding substances such as nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride is an age old propaganda technique that seeks to demonize by association.
Once Stalin, Hitler, Mother Theresa and Pol Pot have been grouped together in the public perception then the planned process can proceed.
Carbon Dioxide is the primary target here. Like it or not, it is a chemical by-product of our ever-increasing need for energy to enrich and prolong our lives, and those of our children. The motive to target is taxation.
Forget the fact that mankind contributes only about 5% of global CO2 production while ‘natural’ processes make up the rest. Yup, we are merely tiny fleas on the back of a rather large elephant.
Ignore the overwhelmingly, greater role of water vapor in the ‘greenhouse’ gas mix when compared with oxidizes carbon. Motives anyone?
Rewrite history, so that inconvenient climatic changes of the past are peer-proven to be but mere legend. Ask those who offer evidence to the contrary, when was it when they stopped beating their wives.
Stifle debate by the repetitious chanting of defensive and offensive mantras. Peer-reviewed, everyone agrees, overwhelming evidence, denialist, flat-earthers, worse than predicted and so on. If the facts supported my side of any argument then debate would be the most powerful weapon in my arsenal. Respect to Mr Romm for doing just this recently with Mr Morano – Many say he came off second best but I’d say he’s a hero to his cause. He tried and that’s singularly heroic, unlike the chief protagonists of his point of view!
Change the goal-posts. When warming fails to materialize it becomes climate change. When people associate climate change with natural sources than turn it into climate chaos. If the words don’t work- re-work the words but keep hammering the message. If the data doesn’t support the models – change the data.
Carbon Dioxide is our treasure and, without it, life on this planet would be, not just poorer but non-existent. Turning it into the arch-villain is like hating your mother because she grounded you once.
Once we burned witches – how many would now support those actions? Yes, the peer-viewpoint, at that time supported those actions- and, yes, contrarians unless confident enough to voice dissent without retribution, would remain quiet.
How will the future judge us? Yes, I’m using the ‘precautionary principle’ here but maybe not as some would know it. What if we are wrong about the incompletely-understood, computer-projected dangers posed by increasing atmospheric CO2 concentrations and take actions that, however, well-intentioned, consign our children to a lifetime of poverty and a reversal of the expectation that successor generations will have it better?
Perhaps, this attempt to regulate CO2 is just a ploy to increase tax revenues dressed up as a noble cause? It may not be. It may indeed be the best thing we have ever embarked on. I don’t know – Yes, I suspect it is not, but that’s where I’m at just now.
Two years ago I really believed that AGW was killing the planet but then doubts started to creep in. These doubts first emerged when I visited pro-AGW sites – they just seemed so ill-mannered, intolerant and bad-tempered to posters who posited alternative viewpoints.
Anyway to cut a long story short – thank you gavin, tamino et al for guiding me to where I now find myself!
People produce CO2. I for one applaud the EPA taking on the out of control population explosions in developing nations.
Seriously, no proposal that ignores dHmO is credible. Heck I’d rather die peacefully of CO2 poisoning than violently drowning.
re: The Ethanol Bubble Pops in Iowa
Well, that’s certainly ON TOPIC.
Briefly, that 1,000 gal number comes from the fact that Ca corn is, mostly, irrigated. What’s NOT mentioned is that the irrigation is from surface, and ground water, NOT from aquifer water. Also, not taken into consideration is that an acre of corn “transpires” IIRC 4,000 Gallons of water, daily, which means a goodly amount of it ends up right back in the system.
And, the 3% number is just wrong. Ethanol, after allowing for the DDGS co-product, utilized 12.8 Million acres in 08′, which is approx 14.8% of corn acreage, and replace 7% of our gasoline supply.
Yields are increasing at such a rate that 10% ethanol will probably require no more than 16% of our corn acreage in 2016 (assuming we plant the same amount of corn as at present, approx. 86 million acres.)
By the way, we’re using Less Fertilizer than we did 10 years, ago. And, plowing a Lot less.