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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Ask Dr Meier how he feels about changing our entire economy based on a computer model. Does he feel that his work justifies a completely new system of taxes that are game changers. Are we really in that much danger from a gas that man contributes only about 5% of the total emitted each year. If we reduce our output by 20% then we will go down to what 4.9%? Come on you’re kidding me aren’t you? This is not about saving the planet it’s about politics and control and grant money.
oMan (19:36:45) :
ya, sounds good–but who’s got the money and time?
I knew this day would come … it’s time to ban marathons and the Tour de France.
jae (19:31:08) :
I didn’t read all the comments, but I hope someone noted that the stupid diagram shows C2O2, instead of CO2. LOL.
I wish the AGW movement were something to laugh at.
And if it were limited to some stupid erros it would be.
Oh well. The skull face works.
Now back to the backlash!
We have the head of NOAA, Jane Lubchenco claiming ocean dead zones are caused by AGW and that climate models are now sufficiently “robust” to help scientists forecast where wind patterns will be 100 years from now.
Energy Secretary Steven Chu claiming AGW is bringing more intense hurricanes.
EPA declaring CO2 is a pollutant.
jae (19:31:08),
I noticed that too. This is what they should have shown: click
That evil carbon sure gets around!
Should we only be writing the EPA, or should we also consider efforts to write our Congressmen and have them write the EPA?
I would think the Congressman (or Congresswoman) would carry the greater effect with 10,000 voters behind them.
Robert Bateman (19:53:06),
Excellent suggestion! click
Anthony,
I sent my letter. It was polite and cited sources.
But what is EPA going to do? Their political masters have already dictated the course that they will take. Who in EPA is going to stand up to the president and volunteer for career suicide?
Unless the Senate can put the brakes on, this president will have his way. He will damage the economy even further and weaken America in the eyes of her enemies. In four years, his replacement will come in with a mandate to reverse this nonsense; assuming that the Republican party can find a leader.
Cynical I know. But in my heart of hearts, this is how I see this unfolding.
–Mike Ramsey
The link provided in the article does not point me to the right page.
If you can’t provide the right link – can you at least provide the search terms I should use in order to comment on the specific proposal.
Even using the search term “Carbon Dioxide” the search results say, “21,896 Documents found”
I can’t wade through all this to make a comment.
The ever-expanding general welfare clause has now become a hang-man’s noose. We are going to be turn into serfs by the very government our distant relatives instituted to “secure the blessings of liberty” for us.
John F. Hultquist (19:16:44) :
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.
________________________________________
Here’s what I think is a better analogy John, better because it’s real. I lost my house in the 1991 Oakland Hills fire, so I know that of which I speak:
In the Berkeley/Oakland Hills, regulations are that we cut back trees and scrub at least 90 feet away from our houses. This is mandated. Now remember, Berkeley is generally considered to be a relatively left wing, liberal kinda place. Eucalyptus trees are a no no (exploding, burning oil is not good for fire control), so they are becoming a dying breed in this area.
In Australia, I gather from reading about their fires that the clown science went along the following lines:
You can’t cut down the trees around your house because they take carbon dioxide out of the atmosphere. Carbon dioxide causes global warming. Global warming causes a greater risk of fire. Therefore, cutting trees down around your house causes a greater risk of fire.
I think the Berkeley/Oakland method is best. It almost certainly involves less time spent identifying the charred bodies of relatives, which I happen to believe is a good thing.
The only two in the Senate I know of who can put the brakes on this are Mitch McConnell and Lindsay Graham. Such a working could also be costly.
I too have my doubts about personal letters to the EPA, but I tried anyways.
Should the EPA not listen, there might be a Plan B.
Just thinking ahead here.
Hoping that Lisa Jackson has a change of heart.
Today on the Diane Rheam show on NPR featured “experts” on the issue of the EPA proposing to include CO2 as a hazardous substance.
The “experts” consisted of two attorneys, and a couple of journalists. No major controversy was raised…as they ALL were of the consensus that we “have to do something about “climate change.”
It was a really disappointing discussion about an EPA decision that could send modern civilization back to the stone age.
Here is the email that I typed out to the show hoping that it would be read on the show. Of course it wasn’t…
“Dear Diane,
I am a fan of your show but your panel today is ill-equipped to speak on the issues of the new proposed EPA addition of CO2 to the blacklist, or “climate change”…
Also….what the audience needs to know here is that we are talking about TWO separate arguments here: 1) The NATURAL cycles of weather. 2) HUMAN-induced pollution of the planet [the latter on which we can all agree on drastic measures need to be taken in some cases, especially in regards to our oceans].
This panel today should consist of SCIENTISTS on both sides of the controversial AGW issue…NOT attorneys and journalists [sorry guys].
Speaking of attorneys, the one remark about that the “science on global warming has been crystal clear for a number of years now” is either a) an uninformed comment, b) a misrepresentation, or c) a boldface lie. Let’s hope that his comment was under the “a” category…as the other two categories are inexcusable for a juris doctorate.
A HANDFUL of dissenting scientists, Margaret??? A “fringe”, David??? http://www.petitionproject.org
Show the hard evidence [HARD evidence] that AGW is occurring [but you can not, can you?]
In turn, I will show you the hard evidence of tens of thousands of meteorologists, physicists, climatologists, paleoclimatologists, engineers, solar scientists, oceanographers, et al….who, like Gallileo before the Inquisition, are saying “HELL NO”.
TWO Separate arguments here: 1) Should we clean up our grossly polluted planet and stop raping the environment and the oceans??? YES, by all means.
2) Can humans influence NATURAL cycles that have been occurring for BILLIONS of years? NO. That is ludicrous.
Please do a show with REAL scientists debating the issue and I will tune back in.”
It was unfortunate because a debate whether CO2 should be blacklisted by the EPA….was hijacked and turned into a yes-men “well the AGW-deniers are a “fringe” or a “handful”….argument.
No one there to hold their feet to the fire for their inaccuracies. So much for “public” radio.
Chris
Norfolk, VA
Robert I am all ears about your Plan B.
Writing government bureaucrats who are entrenched in their positions (and their tenure and their salaries) may not be the most effective.
Hopefully something will work before the EPA bites the CO2 that feeds us!
Chris
Norfolk, VA
Thank you Bill from Pittsburgh. Your suggestions are directly on point and well-taken.
May I suggest a wiki collaboration for comments on this proposed rule-making?
Clearly numerous informed persons intend to comment, and a collaboration may result in a more comprehensive, well-supported comment. Of course, no one would be precluded from submitting an individual comment. I don’t know how to start such a wiki, nor am I inclined to learn how. Perhaps someone with experience could take the lead.
May I further suggest that comments be narrowly tailored to refute EPA’s specifically proposed action. A general opining on the lack of merit of AGW would be counter-productive and disregarded. EPA will not feel compelled to respond to a general rant but will be compelled to respond to peer-reviewed papers supported by hard data. Identifying specific science that refutes the proposed action is most helpful.
Hard copy comments are perhaps best if a comment relies on an obscure paper. Attach a copy of the reference if you can; otherwise, you rely on EPA tasking someone to track down and read your reference. If it is difficult to procure and seldom cited in other references, how much weight should it be given anyway?
A final note. If someone truly has the means and inclination to go litigating after the fact, that someone must submit a comment that includes the specific point and science to be litigated. If not, that someone will lack legal standing to challenge the EPA rule-making.
It runs counter to my optimistic nature to think of this rule making as fait accompli. Nevertheless, given the regulatory climate, anticipating the end while something can still be done is necessary. The proposed wiki collaboration should be intended to persuade EPA completely away from its proposal.
Public comments are not restricted to U.S. citizens. International comments will not be excluded.
O/T
I’ve only recently discovered Wattsupwiththat, and the numerous, well-informed comments are heartening indeed. I am awed at the professional and amateur expertise on climate expressed on this site. Thanks to Anthony, moderators, and commentors all.
That so many wish to influence government based on science is a welcome affirmation of the good and honest in humanity.
DS
Thomas Donlon (20:37:08), please see my (13:46:37) comment above.
Has anyone noticed advertisements on TV and in magazines from “Supreme Master Ching Hai”, the subject at this point being “Go Green, Go Veg, Save the Planet” ?
In Australia the SBS TV channel is carrying this advert. at least twice a night in prime time, pushing the message of going vegetarian to reduce methane and livestock levels.
The material eminates from “Supreme Master TV”, which is broadcast from multi satellite sources and Internet TV. The internet site can very easily be found by Googling – “Supreme Master”, where you will find amongst a lot of myth information, Dr James Hansen on Man Made Global Warming and all the tipping points. Dr Barry Brook from the University of Adelaide on the dangers of methane, as the result of ruminant animals being farmed as a food source. You also have all the Carbon Dioxide is “pollution” rhetoric presented.
Also an interview with Dr Pachauri of the UN on reducing meat consumption, for the above reasons, methane, greenhouse gases, Climate Change.
If you look at the format of presentation on the Supreme Master website, you will find it disturbing, not only with it’s content but the method of presentation, with rapidly changing scenes, including disasters (calving glaciers, raging forest fires).
Wikipedia also has a good examination of ‘Supreme Master – Ching Hai’, the cult and it’s following.
If it looks like propaganda, and smells like propaganda, it probably is propaganda.
This law is simply a tool to instigate ‘carbon rationing’ this in effect will allow central government to set up and control a ‘central planning/command economy’ similar to the USSR model.
The fact that no state controlled economy has ever worked seems to have escaped those who have worked for years to build this system.
We hear much talk by the supporters and instigators of the soviet command economy model Mk11 they tell us of the post democratic age and that capitalism has failed and is dead, now we know why.
Imagine a future where a central government controls industrial output,economic activity,consumer demand and where a central beaurocracy dictates what a person can buy,when they can buy it and if they need it at all… hey, havent we seen this before somewhere? Oooh yes, we saw what happened to the empire that tried it and it was not a pretty sight was it?
The goal is complete control of economic activity and the central control of the harmless by product of using fossil fuels gives the instigators complete control of the entire industrial/economic cycle.
A beaurocrat can decide whether you need a fridge/car/washing machine/computer/telecoms etc, he can decide how long you wait, what you pay and if you are entitled in the first place, food production can be controlled from a central beaurocracy, where has this been tried before? it didnt work out too well then did it?
If there was ever a single mechanism that could be seen as essential to building this soviet style command economy it is the above law, the goal has always been to recreate and build a post democratic Marxian state where the dominant force is the all powerful state monolith, did you ever wonder where all the marxist/leftist/socialist/communist cheerleaders for the USSR went when it collapsed?
The fact is that most changed their clothes from red to green, all those students who were in love with the USSR are now in positions of power and they are using that power to subvert and destroy democracy using the disguise of enviromental concern.
The legions who have pushed and struggled for this end result have no real love for humanity, they have a burning desire to control and rule its destiny with a rod of iron, once they have control they will use their power with all the hard and fanatical fury any of historys despots.
The so called enviromentalists will be hard task masters, they will treat the masses very harshly indeed, human rights mean nothing to them if they stand in the way of their new peoples paradise, they are chomping at the bit to criminalise deniers and given the chance thats exactly what what they would do, they actually state it openly, a fanatical desire to rule and control coupled with a deep seated and violent hatred of their idological enemies and an absolute belief in the rightness of their cause makes them very dangerous to humanity indeed.
JeffT (21:36:57) :
Has anyone noticed advertisements on TV and in magazines from “Supreme Master Ching Hai”, the subject at this point being “Go Green, Go Veg, Save the Planet” ?
In Australia the SBS TV channel is carrying this advert. at least twice a night in prime time, pushing the message of going vegetarian to reduce methane and livestock levels.
…
If it looks like propaganda, and smells like propaganda, it probably is propaganda.
Such propaganda only inspires my contrarian delight in eating meat.
I will never accept serfdom.
Remember folks, you have a constitutional right to a trial by jury. If the epa prosecutes you, but the jury aquits you, you win.
It technically only takes 1 out of 12 jurors to get a mistrial. What if 12 jurors started aqiuiting en masse those charged with dubious environmental crimes?
The laws would become moot and irrelevant.
In fact, beware that the whole legal system would collapse if everyone demanded a jury trial.
Let em pass all the laws they want. Just quit convicting anyone for violating such laws.
Dane Skold (21:18:10):
I unfortunately do not share your optimism about influencing the EPA in this finding. I truly wish I did.
As you will know, the evidentiary standard for such a finding is very low, and EPA will rely on published articles that support their finding. EPA can ignore publications that do not support their finding.
My experience over the years with EPA findings and rulings has been that EPA makes essentially any rule it likes, provided there is some science as support. Their findings and rulings are consistent with the President’s views (whoever that might be at the time).
Where the affected industries take their shots is over implementation timing issues, or difficulty in compliance, or adjusting the maximum emission levels, and sometimes in procedural issues.
I refer to the many EPA rulings that impacted the manufacturing and continuous process industries, such as steel, chemicals, petrochemicals, oil refineries, and natural gas plants. Just a few of these include lead phase-out from gasoline, benzene and toluene in gasoline, sulfur in diesel, SOx and NOx. There were many others under the MACT rules (maximum achievable control technology).
Even so, I believe there is value in sending carefully-reasoned and well-documented comments to EPA, not least of which, as you wrote, is to establish standing to sue.
For a list and quick summary of some of the MACT issues, click here:
http://www.epa.gov/air/toxicair/takingtoxics/p2.html
A key difference between MACT rules, and this proposed GHG rule, is that MACT is based on the lowest emissions from a facility that uses the latest control technology to reduce emissions. In contrast, this CO2-GHG rule (whatever its final form) will likely require a shift to completely new technologies, such as electric heaters rather than gas-fired furnaces, and electric cars rather than gasoline or diesel cars. The electricity will then be mandated to be derived from non-fossil sources, such as wind, solar, and waves.
What is the penalty for those unable to pay their breathing tax?
WOC – This is all about the green’s “WAR ON COMBUSTION”.
Dear Anthony and all,
it is not completly on topic – yet somehow reated.
You probalby remember me for my posts doubting the pure anthropogenic fault for the rise of the CO2 amount in the atmosphere.
I found another way to express one of my concerns:
Let’s assume a ballon full of air with a whole bunch of holes and different people blowing air into it. Everything is nice and stable until a little boy somehow mamages to blow some extra amount of air into it and increases the preasure in that ballon by 30%.
What would happen with the leak rate (as long the preasure of the atmosphere is more or less constant)?
What they say happens with the reservoirs for CO2 in real world?
“The oceans take less and less CO2, because the sinks get saturated” or so!?
And yet the amount of CO2 in the sea has not changed significantly due to human influence.
Can someone point an error in my little model?
I would conclude, if I increase the air preasure in a ballon by 30% and yet the leak rate is decreasing, well the preasure of the atmosphere must have changed . . . not bad for that little boy, is it!?
__
All the best regards,
LoN
I’m not a US citizen, but, having been struck by:-
Barry Foster (13:10:35) :
Wow, and I thought our government here in the UK was stupid!
I am very fearful that, unless you guys succeed in putting a stop to this nonsense, our government (which IS stupid in at least as many ways as yours) will blindly follow suit as our prime minister looks for even more ludicrous ways to stave off a heavy electoral defeat next year.
You have my support as that’s the only thing I can offer just now.