Making your opinion on CO2 and climate change known to the EPA

The EPA view of CO2
The EPA view of CO2

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:

from chemsitryland.com - note the way Co2 is portrayed compared to water vapor and other more potent gases
from chemsitryland.com - note the way CO2 atmosphereic response is portrayed compared to water vapor and other more potent GHG's

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:

http://www.regulations.gov/search/search_results.jsp?css=0&&Ntk=All&Ntx=mode+matchall&N=8099&Ne=2+8+11+8053+8054+8098+8074+8066+8084+8055&Ntt=comments&sid=120B596A7935

I urge all readers to make teir opinions known to the EPA.

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EJ
April 20, 2009 4:43 pm

The scary part is that now, our mouths are now found to be modeled exactly the same as the exhaust pipe of our car.
If they can eliminate CO2, theoretically then they can eliminate us humans.
Just saying…………..

David S.
April 20, 2009 4:44 pm

[chemtrail = snip]
[chemtrail x 2 = delete]
~ charles the moderator

Kum Dollison
April 20, 2009 4:52 pm

And, Sean, you’re misunderstanding the 15% proposition. The mandated max for “Corn” ethanol remains 15 Billion Gallons (approx 10%.) However, some areas will have a hard time complying (think Alaska, for ex.) Also, “Cellulosic” is coming on. Also, we import a sizable amount from Brazil.
The EPA is considering raising the arbitrary 10% limit for any particular blend, in any particular area. Ex. If Valero wanted to sell an E15 blend in Iowa, and an E5 blend in Wy, and Idaho it would be acceptable.

Robert Wood
April 20, 2009 4:59 pm

Today, in my kneck of the woods, Eastern Ottawa and Ontario, we had a massive electricity supply failure. I live and work in the same locale, so I walked to work and said, aloud, in stentorian voice, to a score of employees:
“Welcome to your low-carbon future. No electricity; no lighting; no heating; no refrigeration; no work”
“Welcome to the world powered by windmills and solar panels”
I think I made rhetorical game, set and match. For those who “don’t believe” it is necessary to speak out, as I did.
(Note to Ed: I really did do this).

Robert Wood
April 20, 2009 5:08 pm

After my previous O/T post, I avow to make a serious submission the the Evil PA, and will publish it here. However, I have 60 days for my blood to cool and ideas precipitate, so please be patient.
Reply: It was borderline, but I allowed it. ~ charles the moderator.

Ranger Joe
April 20, 2009 5:25 pm

I know this is off topic [snip–so post in another thread] ~ charles the moderator

Mike Bryant
April 20, 2009 5:28 pm

“Robert Coté (16:27:51) :
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.”
Seriously, Robert I’d rather die quietly in my sleep like my grandfather, than screaming hysterically like the people in his car.
But really seriously, industry has become a very bad thing just as CO2 has.
Odd since industry, which means:
1: diligence in an employment or pursuit ; especially : steady or habitual effort
2 a: systematic labor especially for some useful purpose or the creation of something of value b: a department or branch of a craft, art, business, or manufacture ; especially : one that employs a large personnel and capital especially in manufacturing c: a distinct group of productive or profit-making enterprises d: manufacturing activity as a whole
all of which are good and admirable things. Industry has brought America, you and me, a wealth of goods, possibilities and learning beyond the dreams of all the potentates of history.
The motorcar or automobile has brought freedom along with that wealth. We have the freedom to travel that, again, no one in history has enjoyed. The internet, whoever invented it, has brought the libraries of the earth into our homes. Knowledge is available to this generation that, again, is unprecedented in all of history.
Industry brought the world wealth, freedom and knowledge. But it has come too easily since there are so many who imagine that a step bacwards into the past would be preferable to the riches we enjoy. I hope not too many of our travelers here will forget where we have come from and what we have wrought. There will be no hospitals, no automobiles, no videogames, no heat or light or air conditioning, no longevity, no knowledge, no wealth or freedom in the collective paradise we are heading toward.
CO2 is a marker of freedom and wealth on this earth, it makes the earth thrive just as it does her people. When that marker is despised and removed, wealth and freedom will take their leave just as early death and disease reappear. Where CO2 is embraced humanity will thrive.
Only our diligence and our industry will save us from the coming bad times.

Just Want Truth...
April 20, 2009 5:50 pm

I don’t think the EPA would listen even if there was a Noah’s flood of emails sent to them. There is too much political momentum behind global warming.
Look at what Steven Chu, a powerful figure on President Obama’s cabinet, has said :
http://www.foxnews.com/politics/first100days/2009/04/19/energy-secretary-offers-dire-global-warming-prediction/
Pray for the Chu Effect.

jim papsdorf
April 20, 2009 5:51 pm

Dear EPA:
As it turns out that fat people are guilty of producing much more CO2 due to their huge annual caloric intakes, I hope you will consider a tax on poundage per annum per fat person !!!!
“Stay slim to save the planet ”
LONDON (Reuters) – Overweight people eat more than thin people and are more likely to travel by car, making excess body weight doubly bad for the environment, according to a study from the London School of Hygiene & Tropical Medicine.
“When it comes to food consumption, moving about in a heavy body is like driving around in a gas guzzler,” and food production is a major source of greenhouse gases, researchers Phil Edwards and Ian Roberts wrote in their study, published in the International Journal of Epidemiology.
http://www.reuters.com/article/healthNews/idUSTRE53I2RG20090419?feedType=RSS&feedName=healthNews&rpc=22&sp=true

old construction worker
April 20, 2009 6:17 pm

(For all you legal heads) Is the EPA complying with the DATA QUALITY ACT?

Mike Bryant
April 20, 2009 6:22 pm

Dear EPA:
As it turns out, people who breathe fast are guilty of producing much more CO2 due to their huge annual breath intakes, I hope you will consider a tax on breaths per annum for fast breathers !!!!
“Breathe slow to save the planet ”
LONDON (Reuters) – Fast breathers are usually thin people and are more likely to travel by bike, making excess CO2 which is doubly bad for the environment, according to a study from the London School of Hygiene & Tropical Medicine.
“When it comes to oxygen consumption, moving about quickly in a skinny body is like driving around in a gas guzzler,” and CO2 production is, of course, a major source of greenhouse gases, researchers Ed Phillips and Robert Ian wrote in their study, published in the International Journal of Stupidemiology.
Get Fat… Breathe Slow

Robert Bateman
April 20, 2009 6:32 pm

There is but one thing I can knowingly and confidently say to the EPA:
I cannot for the life of me after 50 years see any rise in the ocean.
None whatsoever.
The tides drown out whatever meager change there might be (a few inches ??).
I have written Lisa Jackson, as someone gave the link to her email.
I did also listen to the interview with her on NPR, and my heart sank.
I will keep trying.

Bill from Pittsburgh
April 20, 2009 6:32 pm

Pieter F (13:30:02) :
Bill from Pittsburgh (12:37:58) :
Good idea. Do you have the specific address for Lisa Jackson, the EPA Administrator?
Pieter. sorry about the delay but here is Lisa Jackson’s address:
USEPA Headquarters
Ariel Rios Building
1200 Pennsylvania Avenue, N. W.
Mail Code: 1101A
Washington, DC 20460
Again, my limited experience with Ms. Jackson is that she will listen to well reasoned, intelligent and well articulated viewpoints.
Also, Anthony, may I suggest that it actually would be useful to have citizens of other nations submit comments? The Obama Adminsitration is rather enamored of European viewpoints and the EPA, I believe, will accept written comments from non-citizens.

Gary Alperin
April 20, 2009 6:34 pm

Please help me e-mail the EPA as I would like to sent my thoughts on the EPA’s regulation of C02, however once I get the this site, I do not know what to do next:
http://www.regulations.gov/search/search_results.jsp?css=0&&Ntk=All&Ntx=mode+matchall&N=8099&Ne=2+8+11+8053+8054+8098+8074+8066+8084+8055&Ntt=comments&sid=120B596A7935\
Does anybody know where on this site to send your opinion?

John F. Hultquist
April 20, 2009 6:37 pm

Paul Linsay (15:46:08) : Modtran
I’d like a basic Modtran 101 thread. Can you, Anthony, and others do that here. It is probably something the EPA ought to know about, Charles, so if you snip this, pass it on first.

REPLY:
I’ll think about it – Anthony

Ed Scott
April 20, 2009 6:42 pm

An alarming scientist speaks out on the coming catastrophe. Fore warned is fore armed.
————————————————————-Energy Secretary Offers Dire Global Warming Prediction
Speaking at the Summit of the Americas in the Caribbean nation of Trinidad and Tobago, Steven Chu says some islands could disappear if water levels rise as a result of greenhouse-gas induced climate change.
http://www.foxnews.com/politics/first100days/2009/04/19/energy-secretary-offers-dire-global-warming-prediction/
“very, very scary”
“there’s a reasonable probability we can go above 4 degrees Centigrade to 5 and 6 more.”
“So imagine a world 6 degrees warmer. It’s not going to recognize geographical boundaries. It’s not going to recognize anything. So agriculture regions today will be wiped out,”
“I think the Caribbean countries face rising oceans and they face increase in the severity of hurricanes. This is something that is very, very scary to all of us. The island states in the world represent — I remember this number — one-half of 1 percent of the carbon emissions in the world. And they will — some of them will disappear,”
“Let me state what the official IPCC (the United Nations Intergovernmental Panel on Climate Change) prediction is: It (sea levels) could go up as much as three-quarters of a meter in this century, but there is a reasonable probability it could be much higher than that,”
“Lots of area in Florida will go under. New Orleans at three-meter height is in great peril. If you look at, you know, the Bay Area, where I came from, all three airports would be under water. So this is — this is serious stuff. The impacts could be enormous,”

April 20, 2009 6:44 pm

Gary Alperin, please see my (13:46:37) comment above.

John H.- 55
April 20, 2009 6:47 pm

Juat want truth posted
Look at what Steven Chu, a powerful figure on President Obama’s cabinet, has said :
http://www.foxnews.com/politics/first100days/2009/04/19/energy-secretary-offers-dire-global-warming-prediction/
“I think the Caribbean countries face rising oceans and they face increase in the severity of hurricanes. This is something that is very, very scary to all of us”
I guess he never read the IPCC reports or talked to any IPCC hurricane experts?
http://sciencepolicy.colorado.edu/prometheus/archives/science_policy_general/000318chris_landsea_leaves.html
“The IPCC assessments in 1995 and 2001 also concluded that there was no global warming signal found in the hurricane record.”

John F. Hultquist
April 20, 2009 7:16 pm

Will you folks lay of the “humans produce CO2” song. They may ban all the products of fermentation, such as booze, beer, and wine. Cheese. Yogurt. Ok, I don’t care about yogurt but I’ll stand up for it anyway.
Go to Roy Spencer’s page and read his latest Q & A paper. He’s got a section on human CO2 inputs. It is the second question after the pictures of the polar bear chasing the guy around his truck. Read it and realize the futility of trying to play CO2-god. Tell the EPA, congress, and the president that if they see a problem – work directly on that problem. It might do some good.
Here is an analogy. Suppose your neighbor lost her job and she and two kids are short of food. Strategy A: Send $50 to the UN-IPCC and expect their efforts to save Earth, improve agriculture, and lower the cost of food. Strategy B: Buy $50 of staple food items and give them to her. Send a note to the UN and tell them you are sorry they couldn’t help your neighbor, so you did.

Just Want Truth...
April 20, 2009 7:17 pm

With cabinet choices like these it looks like the EPA will have the full backing of the White House—or— maybe these type of moves in the EPA originate in the White House.
Video of President Obama’s choices :
http://www.viddler.com/explore/ceivideo/videos/24/

April 20, 2009 7:24 pm

Bill Illis (14:59:18) :
I don’t see how they are going to enforce this at all.
————————————————————-
Bill the answer is this, they are going to use a computer model to regulate emissions, it is not feasible to “measure the emissions” directly as emitted by Industries such as cement and ranching.
The model takes the input fuel/source and applies an emission level based upon the averages as tested in labs as to the measure of emissions produced via processing. So you supply the EPA with the documented levels of fossil fuel and other inputs such as gravel and talc, any distillates and any trapped carbon sources such as wood as inputs and they run a simulation and tell you what amount of permits you need to have based on the computer model.
If they determine you do not have enough allowances available you pay a fine… Sorry you Purchase a Carbon Credit Offset, or they take them from the first purchase of the following auction.
This is why heavy Industry and Refining are the first targets as they are usually low number of inputs and high volume consumers of fossil fuels, all industry and assemblers will be hit with heating and transportation excise tax on the base fuel calculated as a price per weighted GHG GWP (global warming potential), there is no other way to do it.
So for example you will need to provide all the propane consumed by forklifts, diesel from trucks, gas from fleet vehicles as well as manufacturing inputs.
Methane will be on a per head of livestock based on type (cow, sheep, chicken,hog,etc).
Any changes in procedues or equipment to mitigate emissions will need to be inspected and audited by the EPA and new factors entered for your reporting.
These models are completed and ready to go at the EPA and the base factors have been kindly supplied by the DOE and various environmental agencies, and bodies such as the IPCC and NAS.
Now here is the really cool part, the EPA will calculate you a per unit Emission number, you will have to pass this on to any sub assembler or industry using your output as an input including electricity from fossil fuels, They will calculate their per unit number and add in yours, and so on and so on until the packager adds the EPA Total Emissions Regulated to the labeling showing the total emissions generated for GHGs in question for the product.
Products without this label will be subject to tariffs and taxes depending on the State Level of Regulation.
Simple easy and completely fabricated via computer model, that is how the system will be regulated and enforced. Which is fitting because computer models started the insanity in the first place.

jae
April 20, 2009 7:31 pm

I didn’t read all the comments, but I hope someone noted that the stupid diagram shows C2O2, instead of CO2. LOL.

Allan M R MacRae
April 20, 2009 7:34 pm

Some resources below, from CCNet, for your letters to the EPA.
Spring may have finally arrived, after a long, freezing cold winter.
It is a time for optimism, despite your current travails.
You will ultimately win this war, because you are speaking the truth.
But in the meantime, how many more trillions of dollars will be wasted, how many more lives diminished, and how many more opportunities lost – squandered on this fraud of global warming?
Good luck and best wishes, my American friends.
Your neighbour,
Allan MacRae
Canada
IAN PLIMER’S SHORT COURSE ON CLIMATE SCIENCE
Hello Benny
In case you had not seen Ian Plimer’s 5 short videos on climate science:
The scaremongering, and over the top rhetoric about how soon we will fry ourselves off the surface of the Earth if we do not control our carbon emissions is distracting the attention of voters and policy makers away from issues such as immigration and overshoot of carrying capacity that we can actually influence. We will have to learn to adapt to the gradual natural climate change that is taking place and get on with modifying behaviours and philosophies that cause real damage to our supporting ecosystems.
Adelaide Geology Professor, Dr. Ian Plimer, has just published a well-received book ‘Heaven and Earth’.
I have pasted (below) Plimer’s short course in five videos (totalling ~48 minutes ) on Climate Change.
Human Induced Climate Change – Ian Plimer (part 1 of 5)

Human Induced Climate Change – Ian Plimer (part 2 of 5)

Human Induced Climate Change – Ian Plimer (part 3 of 5)

Human Induced Climate Change – Ian Plimer (part 4 of 5)

Human Induced Climate Change – Ian Plimer (part 5 of 5)

Peter Salonius
*********************************

oMan
April 20, 2009 7:36 pm

Regarding our ability to challenge the bureaucracy: we need to create positive incentives to do so. A “whistleblower” statute that rewarded those who called the scientific illiterates to task. What if somebody could get a check for winning a suit against EPA or CARB or similar, and the amount of the check was based on the delta in the GDP from the avoided regulation? Not thoroughly worked out yet of course; but we need heavier artillery than comments to the EPA. We need to mobilize human imagination and fact-finding, based on the prospect of financial gain. As the converse, we need to force the bureaucracy to put some skin in the game. If the EPA knew that its next-year budget might be forfeit if its “science” was de-pantsed in a courtroom, it might be just a tad more circumspect. Discuss amongst yourselves…

Joel Shore
April 20, 2009 7:40 pm

John H.- 55 says:

“I think the Caribbean countries face rising oceans and they face increase in the severity of hurricanes. This is something that is very, very scary to all of us”
I guess he never read the IPCC reports or talked to any IPCC hurricane experts?
http://sciencepolicy.colorado.edu/prometheus/archives/science_policy_general/000318chris_landsea_leaves.html
“The IPCC assessments in 1995 and 2001 also concluded that there was no global warming signal found in the hurricane record.”

Landsea’s statement may have been true at the time he said it as far as it goes (which is a statement about what had currently been detected, not what was predicted for the future). However, this field has been rapidly evolving in the last several years, and here are the statements regarding hurricanes from the IPCC AR4 Working Group 1 Summary for Policymakers (http://www.ipcc.ch/ipccreports/ar4-wg1.htm) issued in 2007:

There is observational evidence for an increase in intense tropical cyclone activity in the North Atlantic since about 1970, correlated with increases of tropical sea surface temperatures. There are also suggestions of increased intense tropical cyclone activity in some other regions where concerns over data quality are greater. Multi-decadal variability and the quality of the tropical cyclone records prior to routine satellite observations in about 1970 complicate the detection of long-term trends in tropical cyclone activity. There is no clear trend in the annual numbers of tropical cyclones.

Based on a range of models, it is likely that future tropical cyclones (typhoons and hurricanes) will become more intense, with larger peak wind speeds and more heavy precipitation associated with ongoing increases of tropical sea surface temperatures. There is less confidence in projections of a global decrease in numbers of tropical cyclones. The apparent increase in the proportion of very intense storms since 1970 in some regions is much larger than simulated by current models for that period.

This area of research remains very active and it is likely that our understanding will continue to evolve. However, while Chu’s statement about hurricanes would have been more accurate had it contained some caveats, I don’t think the gist of it is in contradiction with the IPCC’s latest conclusions.
Reply: Joel, you get this one post, everyone else do not respond. Further hurricane posts will be deleted. Back on topic please–Making your opinion on CO2 and climate change known to the EPA ~ charles the moderator