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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anna v
April 21, 2009 1:08 am

Dear US friends,
Do please respond in droves to this request. If only 34% believe in AGW this leaves 66% of you against King Canute laws.
Maybe the gods will be kind to us and this summer will be cool and the next winter will be even colder than the past. I think that is the only wake up call for the emperor to realize he is wearing no clothes.

Vinnster
April 21, 2009 3:38 am

My grandfather told me as a child…if the Democrats could figure out a way to tax the air we breath, they would do it. They figured out how…

Peter Jones
April 21, 2009 4:48 am

This is great to let us know how to provide commentary. Please let everyone know when the comments may begin.

Tom in Florida
April 21, 2009 5:27 am

Craig (19:44:49) : “I knew this day would come … it’s time to ban marathons and the Tour de France.”
Why stop there, how about banning all those football stadiums full of screaming fans every Saturday and Sunday? Don’t forget about all the tailgating before each game (“charcoal burning everywhere”). How about all those arenas full of screaming fans several times a week for basketball and hockey? How about banning political conventions …. OK I’ll go along with that one!

Joel Shore
April 21, 2009 6:55 am

Jack Green says:

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%?

Jack, far be it for me to suggest what arguments you might use if you were to write the EPA to express your opinion, but I will just warn you that if you send them points like this your letter will not be taken at all seriously because it will just show them that you do not understand the science. Yes, there are large exchanges that occur between the oceans and the atmosphere and the biosphere and the atmosphere. However, these are very closely balanced exchanges back-and-forth involving carbon that is readily available to the atmosphere. The CO2 that we are releasing into the atmosphere by contrast is from a store of carbon (fossil fuels) that has long been locked away from the atmosphere and represents a new source. Hence, the rise in CO2 in the atmosphere since the industrial revolution is entirely…or nearly entirely…due to humans.
An analogy is too a fountain where all of the water that goes down the drain is pumped backed up and squirted out the fountain again. If the basin of the fountain is filled to the brim, it will not overflow from this process because the water is just being recycled. However, now if you come along and turn on a water spicket and attach a hose to it going into the basin, you will cause it to start to overflow. And, the overflow will be due entirely to you even if the rate at which water comes out of the hose is considerably less than the rate at which the fountain shoots out the water.

Joel Shore
April 21, 2009 7:03 am

Law of Nature says:

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!?

I think you are confused here. Scientists already understand that, all else being equal, as one increases the amount of CO2 in the atmosphere, more goes into the oceans. And indeed, that is what is being observed. In fact, only about half of the CO2 that we have been putting into the atmosphere through the burning of fossil fuels has remained there; much of the other half, is going into the oceans (although some is also going into the biosphere).
So, scientists indeed understand that as you increase the partial pressure of CO2 gas in the atmosphere, some of it goes into the oceans. The argument about sinks involves the extent to which this will continue to occur at the same rate that it does now. I.e., scientists are not saying that the oceans won’t continue to be a sink for CO2, but what they are saying is that they may not continue doing so at the same rate. I think part of this effect is due to the fact that as the ocean waters warm they do tend to release some CO2 and part is due to other effects involving the mixing of surface waters down to deeper levels and such.

Tim F
April 21, 2009 7:06 am

I had some difficulty finding the site–the links provided above take the reader to the government website, but not the specific EPA proposal at issue.
Opening the link, I used the column on the left side to narrow mt search. I selected EPA, and then I selected Proposed Rule under document type.
9 entries down on this search is “Mandatory Reporting of Green House Gases; Proposed Rule”. If it helps your search, the docket ID is EPA-HQ-OAR-2008-0508. The entry has a link to a pdf of the proposed rule. It also has the link to the on line form where you may submit comments.
I will read and see if there is a specific point of contact in the event you also want to send your comment as hard copies.
I believe that this is the rule about which we are talking. If it is not, please advise me so I do not spread inaccurate information.
Thanks
Tim

April 21, 2009 7:13 am

Joel Shore,
Your major blunder is to assume that carbon dioxide is harmful, when it is in fact beneficial.
Even politicians are starting to question AGW globaloney: click.
It is the CO2=AGW gang’s position that the climate never changed until the SUV came along. Skeptics know the climate always fluctuates within its normal and natural historical parameters. Cognitive dissonance is required to assume otherwise.

Brian Dodge
April 21, 2009 7:54 am

All the commenting about water vapor, a tax on breathing, cow farts, and soot and emissions from third world dung fires is counterproductive. Warmists will point here to say “see, the willfully ignorant denialists don’t even know the difference between fossil fuel and biofuel emissions, no wonder they get the science wrong”. Or, “so-called AGW skeptics can’t tell the difference between CONTROLLABLE human CO2 emissions by excess fossil fuel consumption and NATURAL water vapor emissions on a planet whose surface is 71% oceans; they’re not true skeptics, they’re just plain ignorant”.
I agree with Dane Skold, “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.” I suggest googling the following scientists and organizations for some peer reviewed science to support comments about GHG regulation to the EPA; Lindzen, Soon, Baliunas, Balling, Singer, Seitz, Christy, Monckton, Heartland Institute, OISM, and Science & Environmental Policy Project.

matt v.
April 21, 2009 8:04 am

The EPA is being advised by “Influential Sources” who provide Influential scientific and statistical information about the “public endangerment” that in their opinion CO2 presents, namely unprecedented global warming. It would appear from the IPCC reports, that this endangerment was determined by the extension of the temperatures and conditions that existed from 1976-2008 into the future plus the adding the impact of more CO2. Since global warming was only possible because AMO and PDO were both peaking on warm, all this translates to extending the past positive AMO and PDO conditions [which no longer exist ] into the future for the next 100 years. Here is a comparison of what happened in the past when PDO and AMO were positive and what happened when they were both negative . The latter is what most skeptics are now predicting for the next 30 years on this blog.The former is what AGW scientists predict.
UNITED STATES
. At least 52% of all the droughts in the US are attributable to PDO and AMO effects. Another 22% are attributable to a complex spatial pattern of positive and negative trends. So 74% of all droughts in United States seem to have nothing to with global warming.
PDO and AMO both positive or warm [like 1925-1945] and [1994 -2008]
Record warm and rising temperatures and significant droughts in 2/3 of northern and central high plains US, California, and Southeast
The very hot spell and dust bowl of the 1930’s
Explains the so called rapid global warming period of 1976-2008
More El Nino events
PDO and AMO both negative or cool [like 1964 -1976] and again [1915-1925]
We are in a similar period since Sept ember 2007[PDO] and January 2009[AMO]
Record Cold temperatures especially in the Northern states
Lot of snow and precipitation
More spring floods especially northern states
Lesser droughts and restricted to central or mid plains, southern California, central US east coast and Maine, southern Florida
More strong –to –violent tornadoes [F3-F5] [see1973]
More La Nina events occur in parallel with negative PDO’S
Of 20 most significant Red River floods in terms of discharge or flow rates [1950m3/sec or more], 14-15 happened during NEGATIVE PDO.
It would appear to me that the real “public endangerment” is telling people to prepare for the wrong future and all the risks that this entails. Instead of warning and advising people to prepare for different [and possibly sometime hazardous] weather conditions and the need for better flood controls, more disaster relief, farming changes, etc [that cool AMO and PDO may bring ]they are telling the people the opposite and spending our borrowed money for the wrong things for the wrong reasons.Its like being told to go out and wear Bremuda shorts , only to find a blizzard outside.

Mike Bryant
April 21, 2009 8:10 am

“The word spigot for an indoor faucet spreads southward and westward out of Pennsylvania, where it yields to the New England term faucet in the northernmost counties. To the west, faucet and tap are usual in the Inland North. In the Upper Midwest and Western states, the form spicket reflects Midland and Southern influence.”
If we can’t agree on this how will we ever agree on AGW?

Bill Junga
April 21, 2009 8:52 am

I most definitely will write to the EPA and I am going to write a well thought out letter to the editor of my local newspapers urging people to do the same.
There are many people out there that question AGW.From what I have read in the original interviews such as Waxman’s ‘North Pole Evaporating’ and exposing the tundra, and then The Honorable Nancy Pelosi saying “natural gas is an alternative to fossil fuels”, a toolmaker, carpenter, highschool gym teacher or electroplater whose hobby is weather and/or gardening just might know more about what is going on with the climate than our elected officials and he should be encouraged to voice his opinion. After all, he’s going to be paying for this.
C2O2? I remember the day when in high school study hall a French teacher would point out that error as he passed your desk! That site seems to have something for global warming but just how accurate is that site to learn Chemistry judging from that error.

anonymous (again)
April 21, 2009 11:01 am

EPA has a related rule out for public comment so now is a good time to practice!
Docket ID: EPA-HQ-OAR-2008-0508
Docket Title: Greenhouse Gas Mandatory Reporting
Document ID: EPA-HQ-OAR-2008-0508-0139
Document Title: Mandatory Reporting of Greenhouse Gases; Proposed Rule
http://www.regulations.gov/fdmspublic/component/main?main=DocumentDetail&o=090000648094dac4
This is the link to the detail page for the rule document as published in the federal register.
Click the PDF icon next to the “Views” label to see the pdf of the rule as published in the federal register.
Click the yellow bubble icon next to the “Add Comments” label to go to the page where you can type or upload your comments on the rule.
Click on the Docket link at the top “EPA-HQ-OAR-2008-0508” to see the details of the Docket. This is where you will find the supporting materials that EPA has posted (100+) and the posted public submissions (comments) to date. This pages has filtering on the list of documents and may not return anything until you hit the “Go” button by the filtering.
“Show Me All” and “Posted within the Past” are the filtering options.
You will notice that supporting materials only have the pdf icon for viewing, but “public submissions” also have the yellow comment bubble icon. This is where you can comment on a comment.
This rule only has about 100 comments to date. This is may favorite one so far:
“You people are depending on the ignorance and stupidity of regular people, who
are the mainstream masses, to believe this out and out LIE, about mankind
controling the temerature of the earth. I know you know, how stupid you sound,
but when you try to scare people who do not know any better, or have no facts, or
knowledge of all of this, they just say, hey, there has to be something to this, or
why would the whole world come up with this? BECAUSE ALL OF YOU GREEDY
PIGS WANT, IS MORE AND MORE, OF ALL THE PEOPLES MONEY, IN THE
FORM OF TAXES, FOR YOUR SO CALLED CARBON CREDITS. ANOTHER
FAKE THING, WHERE MONEY ONLY GOES TO YOUR DUMD ASS,
ORGINIZATION AND THE DUMB ASS, THAT IS, FAT ASS, AL GORE. WE ARE,
BUT, A SPECK ON THIS PLANET. AND WE DO NOT CHANGE THE
TEMURATURE OF THE EARTH. WE DO NOT NEED, OR , CAN WE AFFORD,
YOUR COSTLY PLAN, TO RAISE UTILITY RATES, IN THE LEAST. YOU ARE
DANGEROUS TO MANKIND. WE ALL HAVE TO LIVE ON THIS PLANET. SO,
WHEN YOU PLAN TO RAPE US ALL, FINANCIALLY AND DESTROY ALL OUR
LIVES AND THERE IS NO POINT IN TRYING TO MAKE A LIVING, BECAUSE,
ALL YOUR GREEDY CAUSES, GET ALL OUR MONEY and there is nothing left
here to take, who will you rape next? China is not that stupid, so, forget them.
You cannot fool mother nature. It is NOT US raising the tempurature of the earth.
She knows better. YOU ARE LYING DIRTY PIGS.”

John in L du B
April 21, 2009 1:25 pm

To Ray (13:40:46) and Allan M R MacRae (19:34:10), I am uncertain of your optimism concerning the Canadian situation. I think President Obama expects Canada and Mexico to go along with any EPA ruling or face renegotiation of NAFTA, which brings me to a question. Will the EPA consider foreign submissions?

pkatt
April 21, 2009 1:59 pm

have you seen this site? Sounds to me its all settled … http://www.epa.gov/captrade/index.html

April 21, 2009 3:10 pm

Just out of curiosity, has anyone ever estimated the CO2 concentration during any part of the Carboniferous period? For the profundity of coal we can tap today, it must have been very high to support so much vegetation.

old construction worker
April 21, 2009 4:28 pm

Joel Shore (07:03:19) :
‘scientists are not saying that the oceans won’t continue to be a sink for CO2, but what they are saying is that they may not continue doing so at the same rate. ‘
I bet you got that from a computer model.

M
April 22, 2009 1:47 am

Very very offtopic, but a more nice CO2-image than that skull in this post. I made it in Paintbrush… 😉
http://farm4.static.flickr.com/3011/3037794375_3a46f721c9_o.jpg

Jay
April 22, 2009 10:06 am

Superb testimony here from William Happer of Princeton. This is an elegant framing of the situation.
http://www.capmag.com/article.asp?ID=3382

April 22, 2009 11:15 am

Humans should stop exhaling CO2 and we should put a cap on all 362 Volcanoes and forbid all mammals from farting, then, we impend lightning from causing fires,then and only then we will REDUCE somewhat CO2.
We must recognize the dynamics of nature and adapt,not CONTROL.
,

Law of Nature
April 22, 2009 8:04 pm

Joel Shore (07:03:19) :
Hi Joel,
thanks for your answer
> I think you are confused here.
Maybe, but your answer does not help not much, sorry!
> Scientists already understand that, all else being equal, as one increases
> the amount of CO2 in the atmosphere, more goes into the oceans.
Okay, that’s what I said plus I added as long as the ocean’s CO2 amount is mostly constant and paramters in the water do not change an increase of CO2 in the atmosphere cannot result in a reduction of the sinks.
You say to that:
> [..] In fact, only about half of the CO2 that we have been putting into the
> atmosphere through the burning of fossil fuels has remained there;
Well, that is very nice, but completly unrelated. If if the sinks would not reduce, but getting slightly bigger every year (which they should, if the oceans are unchanged in the last decades), you would observe the same behavior with a slightly different time constant: some of the anthropogenic CO2 would dissolve in the oceans every year and some would stay there for a while. This has nothing to do with my point:
A change of the sink rate means the oceans change, which means they are a (big?) part of the rise of CO2 in the Atmosphere.
The change of the sink rate is contadictonary to the standard assumption of a pure anthropogenic cause.
> I think part of this effect is due to the fact that as the ocean waters warm
> they do tend to release some CO2 and part is due to other effects
> involving the mixing of surface waters down to deeper levels and such.
Aha, now you spit my question back at me . .
But yes, you seem to see it my way (but without understanding what you are saying). A warming of the oceans for example tends to release additional CO2. (so does in a much stronger dependence the change of the pH-value lets say due to sulphoric acid) , so how big is this amount compared to the human CO2 production?
All the best,
LoN

Paul
April 22, 2009 8:52 pm

Anyone here catch the Frontline special on Chesapeake Bay? It’s amazing to me that the EPA seems to think it has nothing better to do than chase far-flung theories based on the dangers of exhalation while an irreplaceable ecosystem and national treasure are being destroyed by industrial pollution.

April 25, 2009 9:22 am

The Federal Register published EPA’s proposed finding that CO2 endangers public health and welfare on Friday, May 24, 2009. The clock has started for comments.
http://sowellslawblog.blogspot.com/2009/04/co2-endangerment-finding-published-in.html

April 25, 2009 9:47 am

Dear Mr. Watts et al:
I discovered this site today…great information. I have been developing and implementing clean technology employing CO2 for the past 25 years. I (and my customers) have witnessed first-hand the many green benefits of using CO2 as an alternative manufacturing agent. I am really concerned that the hysteria and non-sense promulgated by the politicos will damage this great green manufacturing opportunity for industry.
BTW…I read a blog entry about CO2 (in the EPA-CO2 picture) being a linear molecule. This is not always the case. The CO2 structure will bend when it complexes with various organic molecules. Perhaps CO2 is “bent” when combined with the mindset of the EPA? David Jackson.

April 26, 2009 10:19 am

I will comment on the deplorable lack of Software Quality Assurance in regards the GCM codes and other software used in the IPCC process.
http://danhughes.auditblogs.com/2009/04/26/epa-docket-id-no-epa-hq-oar-2008-0508/

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