I just sent my comments in, and have included excerpts from them below for structure and ideas. If you have not done it yet, get your comments in. I did mine via email. Some excerpts from my commentary are listed below. You can send public comments here: ghg–email@example.com
To submit a comment, identify them with Docket ID No. EPA-HQ-OAR-2009-0171 and submit them online, by email, by facsimile, by mail or by hand delivery.
The docket # is Re: Docket ID No. EPA–HQ– OAR–2009–0171 Be sure to include that number in email
They must be received by EPA by June 23. TODAY
ADDRESSES: Submit your comments, identified by Docket ID No. EPA-HQ-OAR-2009-0171, by one of the following methods:
– Federal eRulemaking Portal: http://www.regulations.gov. Follow the online instructions for submitting comments.
– E-mail: firstname.lastname@example.org
– Fax: (202) 566-1741.
– Postal Mail: Environmental Protection Agency, EPA Docket Center (EPA/DC), Mailcode 6102T, Attention Docket ID No. EPA-HQ-OAR-2009-0171, 1200 Pennsylvania Avenue, NW, Washington, DC 20460. TOO LATE
– Hand Delivery: EPA Docket Center, Public Reading Room, EPA West Building, Room 3334, 1301 Constitution Avenue, NW, Washington, DC 20004. Such deliveries are only accepted during the Air Docket’s normal hours of operation, and special arrangements should be made for deliveries of boxed information.
Instructions: Direct your comments to Docket ID No. EPA-HQ-OAR-2009-0171. EPA’s policy is that all comments received will be included in the public docket without change and may be made available online at http://www.regulations.gov, including any personal information provided, unless the comment includes information claimed to be CBI or other information whose disclosure is restricted by statute. Do not submit information that you consider to be CBI or otherwise protected through http://www.regulations.gov or e-mail.
The http://www.regulations.gov Web site is an “anonymous access” system, which means EPA will not know your identity or contact information unless you provide it in the body of your comment. If you send an e-mail comment directly to EPA without going through http://www.regulations.gov your e-mail address will be automatically captured and included as part of the comment that is placed in the public docket and made available on the Internet. If you submit an electronic comment, EPA recommends that you include your name and other contact information in the body of your comment and with any disk or CD-ROM you submit. If EPA cannot read your comment due to technical difficulties and cannot contact you for clarification, EPA may not be able to consider your comment. Electronic files should avoid the use of special characters, any form of encryption, and be free of any defects or viruses.
This Climate Audit post can also be useful for ideas.
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:
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, some excerpts from my submission, sans photos are listed below.
From: Anthony Watts
Re: Docket ID No. EPA–HQ– OAR–2009–0171
Please find the following comments related to EPA’s April 24, 2009 Proposed Endangerment and Cause or Contribute Findings for Greenhouse Gases Under Section 202(a) of the Clean Air Act (EF).
These comments also address issues in the April 17, 2009 Technical Support Document (TSD) that includes many of the detailed references to science, data, and models used to justify comments in the Endangerment Finding.
The official record of temperatures in the continental United States comes from a network of 1,221 climate-monitoring stations overseen by the National Weather Service, a department of the National Oceanic and Atmospheric Administration (NOAA). Until now, no one had ever conducted a comprehensive review of the quality of the measurement environment of those stations.
During the past few years a team of more than 650 volunteers visually inspected and photographically documented more than 860 of these temperature stations. We were shocked by what we found. We found stations located next to the exhaust fans of air conditioning units, surrounded by asphalt parking lots and roads, on blistering-hot rooftops, and near sidewalks and buildings that absorb and radiate heat. We found 68 stations located at wastewater treatment plants, where the process of waste digestion causes temperatures to be higher than in surrounding areas.
In fact, we found that 89 percent of the stations – nearly 9 of every 10 – fail to meet the National Weather Service’s own siting requirements that stations must be 30 meters (about 100 feet) or more away from an artificial heating or radiating/reflecting heat source. In other words, 9 of every 10 stations are likely reporting higher or rising temperatures because they are badly sited.
For example, here is a climate station of record located in a parking lot, at the University of Tucson, operated by the Atmospheric Sciences Department.
Above: official USHCN weather station, Atmospheric Science Dept. University of Arizona, Tucson. more on that station here. Photo: Warren Meyer
It follows that if Atmospheric Scientists at an institution of higher learning cannot measure temperature correctly, then there is little expectation that it will be elsewhere. In fact, that is what I found.
It gets worse. We observed that changes in the technology of temperature stations over time also has caused them to report a false warming trend. We found major gaps in the data record that were filled in with data from nearby sites, a practice that propagates and compounds errors. We found that adjustments to the data by both NOAA and another government agency, NASA, cause recent temperatures to look even higher.
Note that the graph above shows NOAA’s own adjustments to temperature over time.
Reference URL for the above graph from Carbon Dioxide Information and Analysis Center
Below are my findings of the state of quality for the USHCN network of Stations:
The conclusion is inescapable: The U.S. temperature record is unreliable. The errors in the record exceed by a wide margin the purported rise in temperature of 0.7C (about 1.2F) during the twentieth century.
My report is available in full as this PDF document here:
I request that it also be entered into the official record as well, as part of this document.
Consequently, this record should not be by the Administrator as evidence of any trend in temperature that may have occurred across the U.S. during the past century. Since the U.S. record is thought to be “the best in the world,” it follows that the global database is likely similarly compromised and unreliable.
The many problems with the surface temperature record that have been demonstrated both photographically and by a national census suggest that the supposed linkage between carbon dioxide levels and surface temperature is likely not correlated by global climate models that use the surface temperature record as data input or as a means of calibration.
All models that use this flawed data for validation must be rejected by the Administrator as non-compliant with the Federal Information Quality Act.
Specific Errors in the EF/TSD
EF.18898. column 3-18899.column 1
“Like global mean temperatures, U.S. air temperatures have warmed during the 20th and into the 21st century. According to official data from NOAA’s
National Climatic Data Center:
• U.S average annual temperatures are now approximately 1.25 °F (0.69 °C) warmer than at the start of the 20th century, with an increased rate of warming over the past 30 years The rate of warming for the entire period of record (1895–2008) is 0.13 °F/decade while the rate of warming increased to 0.58 °F/decade (0.32 °C/decade) for the period from 1979–2008.
• 2005–2007 were exceptionally warm years (among the top 10 warmest on record), while 2008 was slightly warmer than average (the 39th warmest year on record), 0.2 °F (0.1 °C) above the 20th century (1901–2000) mean.
• The last ten 5-year periods (2004– 2008, 2003–2007, 2002–2006, 2001–2005, 2000–2004, 1999–2003, 1998– 2002, 1997–2001, 1996–2000, and 1995– 1999), were the warmest 5-year periods in the 114 years of national records, demonstrating the anomalous warmth of the last 15 years.
TSD Executive Summary
“[OE 3] Warming of the climate system is unequivocal, as is now evident from observations of increases in global average air and ocean temperatures, widespread melting of snow and ice, and rising global average sea level Global mean surface temperatures have risen by 0.74°C (1.3ºF) (±0.18°C) over the last 100 years. Eight of the ten warmest years on record have occurred since 2001. Global mean surface temperature was higher during the last few decades of the 20th century than during any comparable period during the preceding four centuries.
“[OE 4] Most of the observed increase in global average temperatures since the mid-20th century is very likely due to the observed increase in anthropogenic GHG concentrations. Climate model simulations suggest natural forcing alone (e.g., changes in solar irradiance) cannot explain the observed warming.
“[OE 5] U.S. temperatures also warmed during the 20th and into the 21st century; temperatures are now approximately 0.7°C (1.3°F) warmer than at the start of the 20th century, with an increased rate of warming over the past 30 years. Both the IPCC and CCSP reports attributed recent North American warming to elevated GHG concentrations. In the CCSP (2008g) report the authors find that for North America, “more than half of this warming [for the period 1951-2006] is likely the result of human-caused greenhouse gas forcing of climate change.”
“Global Surface Temperatures
Surface temperature is calculated by processing data from thousands of world-wide observation sites on land and sea. Parts of the globe have no data, although data coverage has improved with time. The long-term mean temperatures are calculated by interpolating within areas with no measurements using the collected data available. Biases may exist in surface temperatures due to changes in station exposure and instrumentation over land, or changes in measurement techniques by ships and buoys in the ocean. It is likely that these biases are largely random and therefore cancel out over large regions such as the globe or tropics (Wigley et al., 2006). Likewise, urban heat island effects are real but local, and have not biased the large-scale trends (Trenberth et al., 2007).
The following trends in global surface temperatures have been observed, according to the IPCC (Trenberth et al., 2007):
• Global mean surface temperatures have risen by 0.74°C ±0.18°C when estimated by a linear trend over the last 100 years (1906–2005) as shown by the magenta line in Figure 4.2. The warmest years in the instrumental record of global surface temperatures are 1998 and 2005, with 1998 ranking first in one estimate, but with 2005 slightly higher in the other two estimates. 2002 to 2004 are the 3rd, 4th and 5th warmest years in the series since 1850. Eleven of the last 12 years (1995 to 2006) – the exception being 1996 – rank among the 12 warmest years on record since 1850. Temperatures in 2006 were similar to the average of the past 5 years.
• The warming has not been steady, as shown in Figure 4.2. Two periods of warming stand out: an increase of 0.35°C occurred from the 1910s to the 1940s and then a warming of about 0.55°C from the 1970s up to the end of 2006. The remainder of the past 150 years has included short periods of both cooling and warming. The rate of warming over the last 50 years is almost double that over the last 100 years (0.13°C ± 0.03°C vs. 0.07°C ± 0.02°C per decade).
Supporting peer reviewed papers for my analysis of errors in the siting of USHCN climate monitoring stations include:
Yilmaz et al (PDF 2008 ) which cites temperature differentials of up to 11.79C between asphalt/concrete and grass. Grass is the preferred surface over which temperature should be measured according to World Meteological Organization (WMO) standards.
An online database of the weather stations comprising the U.S. Historical Climatoilogy Network that have been surveyed thus far is available online at http://gallery.surfacestations.org