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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Here is the page for submitting comments:
This Link
Click on “Send a Comment or Submission” to make your comments.
You may also click on “Notification,” fill out the form, and check the box for “Public Submissions” to receive automatic notices of comments.
Section 202 of the Clean Air Act, that EPA’s proposed finding is to modify, requires EPA to consider “the availability and costs of the technology, and noise, energy, and safety factors…”
With all due respect to Dr. Roy Spencer’s arguments, found here, costs must be considered.
Also, the safety factors requirement could be used to argue that capturing and sequestering CO2 creates more danger than allowing the gas to mix into the atmosphere. Concentrated CO2 can leak, displacing oxygen from an area, and cause death to people and animals. People and animals require oxygen to breathe, and will die if breathing high concentrations of CO2.
Further, reducing CO2 will increase energy consumption, so this could be used as an argument against, especially for capturing CO2 from coal-fired power plants.
Anthony,
Please keep those daily updates on WUWT.com as it is enjoyable to read and learn about the current issues facing us today. Recently, you informed us on the desire for the EPA to include CO2 into the Clean Air Act at:
http://wattsupwiththat.com/2009/04/20/making-your-opinion-on-co2-and-climate-change-known-to-the-epa/
However, at the time of you sent it to us, some important details were missing such as a) the exact e-mail address to send our public comments, and, b) the exact science on why the EPA believes this law is needed. After a long search, I have found both of these documents.
a) Docket ID: EPA-HQ-OAR-2009-0171, Docket Title: Proposed Endangerment Finding for Greenhouse Gases under the Clean Air Act (CAA), Document ID: EPA-HQ-OAR-2009-0171-0377
Send public comments to this e-mail address:
http://www.regulations.gov/fdmspublic/component/main?main=SubmitComment&o=0900006480968e17
b) The EPA Science Fact Sheet on why CO2 needs to be included in this law:
http://www.epa.gov/climatechange/endangerment/downloads/ScienceFactSheet.pdf
Please share this with your readers so that their opinions can be heard on this important change. Here are the key points on the EPA science “facts” on CO2 according to this document:
Key Points About Climate Change:
1) Heat-trapping greenhouse gases are now at record-high levels in the atmosphere compared to the recent and distant past.
2) These high atmospheric levels are the clear result of human emissions of carbon dioxide and other greenhouse gases.
3) Warming of the climate system is now well documented, as is evident from increases in global average air and ocean temperatures, widespread melting of snow and ice, and rising global average sea level. Eight of the 10 warmest years on record have occurred since 2001.
4) The buildup of greenhouse gases in the atmosphere is very likely the cause of the observed increase in average temperatures and other climatic changes. Most of the warming cannot be explained by natural variability such as variations in solar activity.
5) Future warming over the course of the 21st century, even when assuming emissions growth will be low, is very likely to be greater than observed warming over the past century.
6) The effects of climate change observed to date and/or projected to occur in the future include, but are not limited to: more frequent and intense heat waves, more wildfires, degraded air quality, more heavy downpours and flooding, increased drought, greater sea level rise, more intense storms, harm to water resources, harm to agriculture, and harm to wildlife and ecosystems.
7) The changes to our climate may increase the likelihood of extreme and high-impact events such as more intense hurricanes.
Health Effects Associated With Elevated Greenhouse Gas Concentrations in the United States Temperature Effects:
1) There is evidence that extremely hot days are already increasing. Severe heat waves are projected to intensify, which can increase heat-related mortality and sickness. A possible benefit of moderate temperature increases includes fewer deaths from exposure to extreme cold.
Air Quality Changes:
2) Climate change is expected to worsen regional ozone pollution, with associated risks in respiratory infection, aggravation of asthma, and premature death. The impact on particulate matter remains less certain.
Extreme Events:
3) Storm impacts are likely to be more severe, especially along the Gulf and Atlantic coasts. Heavy rainfall events are expected to increase, increasing the risk of flooding, greater runoff and erosion, and thus the potential for adverse water quality effects. These projected trends can increase the number of people at risk from suffering disease and injury due to floods,
storms, droughts and fires.
Climate-Sensitive Diseases:
4) Potential ranges of certain diseases affected by temperature and precipitation changes, including tick-borne diseases, are expected to increase.
Welfare Effects Associated With Elevated Greenhouse Gas Concentrations in the United States Under the Clean Air Act, “welfare” includes impacts such as effects on soils, water, crops, vegetation, man-made materials, animals, wildlife, weather, visibility, and climate; damage to and deterioration of property and hazards to transportation; as well as effects on economic
values and on personal comfort and well-being.
1) The global sea level gradually rose in the 20th century and is currently rising at an increased rate, exacerbating storm-surge flooding and shoreline erosion.
2) Rising temperatures will diminish snowpack in the Western U.S., affecting seasonal availability of water.
3) Climate change will likely further constrain already over-allocated water resources in some areas of the U.S., increasing competition amongagricultural, municipal, industrial, and ecological uses.
4) Modest climate change, plus elevated CO2, may bring agricultural yield increases in the near term. But, as temperatures continue to rise, these crops will increasingly begin to experience failure. Increases in regional ozone levels will also adversely impact certain crops.
5) Climate change has very likely already increased the size and number of forest fires, insect outbreaks, and tree mortality in the interior West, the Southwest, and Alaska, and will continue to do so.
6) Changes in climate will cause species to shift north and to higher elevations and fundamentally rearrange U.S. ecosystems.
7) Ocean acidification is projected to continue, which can affect the productivity of marine life such as corals.
8) Climate change impacts in certain regions of the world may exacerbate problems that raise humanitarian, trade, and national security issues for the United States.
Thanks for the heads up, Anthony!
The deadline for getting comments in is June 23, 2009, 60 days after the publication of the proposed regs in the Federal Register 4/24/09.
The best link for information on commenting is http://www.epa.gov/climatechange/endangerment.html. This has the 26 page full proposal, a convenient 2-page “Summary of the Science…”, and detailed (3 page typescript) instructions for submitting comments.
The earlier your comment is in, the more attention it will get. Over 600 comments are already in, and are accessible via http://www.regulations.gov, with search for docket EPA-HQ-OAR-2009-0171. Otherwise the http://www.regulations.gov site is hard to navigate.
Touching on specific points in the 2-page “Summary of the Science…” is probably the most effective and concise way to comment.
I’ve finally posted my 5-page comments on the proposed regulations. They haven’t been logged yet, but meanwhile are available via my site at http://www.econ.ohio-state.edu/jhm/AGW/.
As I mentioned above, the best link for information on the regs is http://www.epa.gov/climatechange/endangerment.html . The deadline for comments is June 23, 2009.
As Roger Sowell notes in the original post, although it’s ideal to write your own comment, its still very effective just to agree with an earlier comment.
Although the EPA regs do not relate to the pending Cap and Trade legislation, the flow of opinions on the regs may indirectly affect the legislation.
This thread looks pretty dead, but FWIW, my comment finally showed up on http://www.regulations.gov on June 1, about a week after I sent it to the EPA e-mail address provided. The document ID is EPA-HQ-OAR-2009-0171-1616.1.
Remember comments are due by June 23!
OMG! FUCK YOU GUYS! All of the evidence points toward AGW! You guys are idiots! You selfish pigs will burn in hell! Stupid motherfucking SUV drivers, stupid retards that mar beautiful landscapes with oil drilling and destroy the arctic with unprecedented rapid warming! Almost every year, temperature records are tied-and you retards only pay attention to the few cold months or years that occur! GO FUCK YOURSELVES YOU PATHETIC, SELF-OBSESSED, REPUBLICAN, HOMOPHOBIC LOSERS!
REPLY: Such a nice young man. click I wondered about the “homophobic” comment, since that topic doesn’t get discussed here. With a little searching it is clear why now. click
Unfortunately for you, sometime in the future a potential employer will probably Google your name and find this comment and the foul language you uttered. Such is the risk of ranting on a public forum. – A