LAST DAY: The June 23rd EPA CO2 endangerment public comment deadline is TODAY

epa_logo_1I 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–endangerment-docket@epa.gov

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: ghg-endangerment-docket@epa.gov

– 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.

Some examples:

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:

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, some excerpts from my submission, sans photos are listed below.

=========================================

To: ghg–endangerment-docket@epa.gov

From: Anthony Watts

[address]

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.

Issue Summary

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

http://cdiac.ornl.gov/epubs/ndp/ushcn/ts.ushcn_anom25_diffs_pg.gif

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:

http://wattsupwiththat.com/2009/05/10/a-report-on-the-surfacestations-project-with-70-of-the-ushcn-surveyed/

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.”

TSD.22-23

“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).

Comments

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.

http://www.ejournal.unam.mx/atm/Vol21-2/ATM002100202.pdf

See the Climate Reference Network Site Handbook (National Climatic Data Center PDF 2002) including explanation of the CRN 1-5 rating system used by surfacestations.org

http://www1.ncdc.noaa.gov/pub/data/uscrn/documentation/program/X030FullDocumentD0.pdf

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

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90 thoughts on “LAST DAY: The June 23rd EPA CO2 endangerment public comment deadline is TODAY

  1. It’s a great comment Anthony, I hope they pay attention.
    Eventually they will be forced to, science doesn’t play favorites.
    REPLY: But politics does, and when making law, politics trumps science. Which is why we have to make our voices known. The only thing that trumps both is nature, but that may take awhile. – Anthony

  2. Thank you for your patriotism Anthony.
    I let the EPA know that we know that it is impossible to tax the temperature of the planet down. I let them know that this is a fraudulent attempt for government mandated gas price gouging. I also let them know they WILL BE held responsible for this perversion of science.

  3. Excellent comment, but I think it is already decided, based on the settlement with California over auto emissions. The deal assumes an EPA finding.

  4. “It ain’t over ’till the fat lady sings”
    It’s vital that as many people voice their concerns to the EPC, as the evidence is good that AGW is a myth.
    With what looks like colder weather round the corner, every comment will count.

  5. A particular website I subscribe to (which won’t be mentioned here) attempts to anticipate the future. By monitoring terms in use and relationships to other terms, it creates an “anticipation map”. This map is now showing something very interesting, that is a heat-based currency. Without going into too much detail, it seems that rather than trade carbon credits, it is further abstracted into heat units. This will coincide with the decline of the dollar and provide a universal currency. I believe the first step is to regulate CO2, then bring other chemicals in (methane, etc), much like gold and silver of old. Eventually it will be abstracted into heat units. We will be paid in, and buy things with, heat units. This will better reflect environmental costs, while incorporating local labor costs and shipping. No more cheap stuff from China at the expense of the environment. The cost will be better in proportion to the environmental impact. Just something to think about as we dip our toe in the water…

  6. a “heat based currency” will become reality about the same time the entire human race begins speaking Esperanto. When does the “anticipation map” book that one into our future?
    That website’s analysis ignores the most important factor in any evaluation of fiat currency – Power. Meaning, the power of the issuer to defend that currency, to prevent counterfeiting of the currency, and to create trust in that currency. For a practical example, suppose there was such a heat based currency. Who – very specifically, who?? – is going to stop me from going to Aruba, claiming I have a special heat sink based on my perpetual motion machine, and to begin printing all of the “heat based” currency I can print and passing it out? Who has the level of force to stop that? If you cannot answer the question, the proposed currency will fail immediately. Who backs it? Who enforces it? Who trusts it?
    Without those three interlocking aspects of power, a fiat currency is nothing but cheerios boxtops. The utopians generally assume that this will all happen the day the UN becomes the One True World Government. Yeah right – we’re back to Esperanto with that one.
    Since you mentioned the decline of the dollar, there is a very real possiblity that we may be seeing the long term breakdown of all of the fiat currencies due to massive overleveraging. If this happens (and it’s not guaranteed yet, but looking more likely every day) then we will in fact go back to gold, silver, and other physical mediums of exchange – and for the simple reasons that they are one of the only things trusted implicitly by every nation, they cannot be counterfeited, and governments can’t decide to double the supply one morning because they’ve spent all of their money on foolish promises.

  7. Jason said:

    I believe the first step is to regulate CO2, then bring other chemicals in (methane, etc), much like gold and silver of old. Eventually it will be abstracted into heat units. We will be paid in, and buy things with, heat units. This will better reflect environmental costs, while incorporating local labor costs and shipping.

    Funny, I could have sworn that money already did that, plus allowed us to handle the notion that heat units might become cheaper at some time in the future as we find more efficient ways to harness energy.

  8. Anthony
    I just attempted to send comments to:
    ghg-endangerment-docket@epa.gov
    But I got this error message:
    Your message did not reach some or all of the intended recipients.
    Subject: Docket ID No. EPA–HQ– OAR–2009–0171
    Sent: 6/17/2009 12:42 PM
    The following recipient(s) could not be reached:
    ‘ghg–endangerment-docket@epa.gov’ on 6/17/2009 12:42 PM
    The requested operation failed.
    Any idea as to why that might have happened?

  9. Lovely stuff !
    I have always been impressed with the way that democracy is run in the US; particularly the formal process where any citizen’s reasoned views are actively solicited, recorded, and accounted, by the civil service. It ensures that the truth comes out in the end.
    I wish we had such proper formal open democratic processes in the UK, instead of our quasi-system of informal lobbying (aka ‘trousering’) which permits inconvenient truths to be elided for decades.

  10. “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.”
    Should that be ‘not be used’
    At least you get to air your views in the US, wish we could get comments included in the Uk.

  11. Hi Anthony
    “In your letter you state: 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. ”
    Later you correctly refer to: University of Arizona, Tucson.
    Maybe you can rectify that error

  12. OT, but I wonder if Dr. Roy has sent in his opinion…
    Ice Ages or 20th Century Warming, It All Comes Down to Causation
    Musings on the Vostok Ice Core Record
    http://www.drroyspencer.com/2009/06/ice-ages-or-20th-century-warming-it-all-comes-down-to-causation/
    I believe that the interpretation of the Vostok ice core record of temperature and CO2 variations has the same problem that the interpretation of warming and CO2 increase in the last century has: CAUSATION. In both cases, Hansen’s (and others’) inference of high climate sensitivity (which would translate into lots of future manmade warming) depends critically on there not being another mechanism causing most of the temperature variations. If most of the warming in the last 100 years was due to CO2, then that (arguably) implies a moderately sensitive climate. If it caused the temperature variations in the ice core record, it implies a catastrophically sensitive climate.
    But the implicit assumption that science knows what the forcings were of past climate change even 50 years ago, let alone 100,000 years ago, strikes me as hubris. In contrast to the “consensus view” of the IPCC that only “external” forcing events like volcanoes, changes in solar output, and human pollution can cause climate change, forcing of temperature change can also be generated internally. I believe this largely explains what we have seen for climate variability on all time scales. A change in atmospheric and oceanic circulation patterns could easily accomplish this with a small change in low cloud cover over the ocean. In simple terms, global warming might well be mostly the result of a natural cycle.

  13. Of course, Jason, China will not comply with any of the terms of a future CO2 treaty. They will cheat on everything. There is no moral code guiding that govt. They don’t even believe such a thing can exist. So they will cheat as they have in the past on various international agreements.
    The result: More Western manufacturing will move to China as a result of an unbalanced playing field where the Chinese sign agreements but only the most naive western countries obey (read here: USA).

  14. Jeff Id- “Science doesn’t play favorites.”
    I have a bridge for you, Jeff, it takes you to the planet where ‘science doesn’t play favorites’!:] On this planet, those who guard the grant money and power in the sciences, do indeed play favorites and this is why Global warming will be so hard to defeat, it is a religion backed by the state and the Fed.

  15. THIS IS THE HEADLINE ON WEATHER.GOV
    “…U.S. Temperature Warmer than Average for May…
    The May 2009 temperature for the contiguous United States was above the long-term average, based on records going back to 1895, according to an analysis by NOAA’s National Climatic Data Center in Asheville, N.C”
    Now, I went through one of the MO weather stations here http://agebb.missouri.edu/weather/history/index.asp
    Now, indeed the AVG temp for may is the highest, at least since their easily accesible records started in 2000. HOWEVER IT”S NOT BECAUSE OF THE HIGH TEMPS. THE HIGH TEMPS ARE STATIC, IT’S BECAUSE OF WARMER LOWS.
    I think this goes right in with the theory that clouds are a temperature control mechanism.
    Can somebody PLEASE help out with this???????????
    I think we are being gamed on temps.
    Oh, and there’s a parallel temp system outside of GSS. That University of MO link is a seperate set of stations, most of them in truly rural areas. Are they a part of GISS?
    If not, the Land grant universities might give us a check.
    LOOK AT THE DATA YOURSELF.
    MU’s data is downloadable and easily accessible.

  16. RE: “The only thing that trumps both is nature, but that may take awhile. ”
    Back when I was a eco radical, during the 1980s, there was a slogan I particularly liked:
    “Nature Bats Last.”
    At the time, I, like many of my cohorts, imagined the type of debased and dying world portrayed by Gore, Hansen, et al. I was a true believer, who felt that CO2 emissions and other “evils” would permanently tweak global temperatures to a higher band of operation, and, oddly, would also, in concert with desertification inducing human practices, dry up much of the world. A hot, dried up world, with a massive population of say, 10B people, was my nightmare at the time.
    Now I’ve a different sort of nightmare. Indeed, nature bats last, and Sol is in the batter’s box presently. In this new nightmare, the cold comes, and gets worse and worse. Ironically (but really not) dry also comes to many mid latitude places. Then comes the ice. During the early stages of this new epoch, the bedraggled remnant engage in the mother of all world wars. The war plus the failing food supply results in the deaths of some 2 to 3 billion souls. As the lights start to go out in one now quasi isolated community of refugees after another, a small fraction of the wise contemplate a ten thousand year dark age, unfolding.

  17. Nice effort….you tried anyway. Cap and Tax is on the way, the new dictator has spoken.
    Been looking at your weather stuff for my 8 year old!

  18. Supercritical (10:56:07) :
    I have always been impressed with the way that democracy is run in the US; particularly the formal process where any citizen’s reasoned views are actively solicited, recorded, and accounted, by the civil service. It ensures that the truth comes out in the end.

    It’s mostly lip service. They pretty much do what the administration wants.

  19. carbon cap and trade is a tax.
    a carbon treaty with china is a joke. They can’t make toys without poisionous paint and they knock off all our software as quickly as possible. what in the world benefits us with a carbon treaty? we should just borrow money from them and drop it by airplane over their rice paddies. Next issue is an unrealistic nuclear treaty with North Korea. Not in my lifetime.

  20. “Boston-area art appraiser refuses to work for global warming skeptic
    Climate of hatred: Prominent scientist refused service due to skepticism
    Prominent MIT physicist and global warming skeptic, Richard Lindzen, was recently refused the services of a Boston-area art appraiser because of global warming.
    As Lindzen described in an e-mail:
    In our recent house fire, an 18th century oriental rug was burnt, and we needed an appraisal of its value for our insurance. We were referred to a dealer, [name withheld], who agreed to do the appraisal. However, when my wife, Nadine, brought him the burnt rug, he rudely turned her away saying that he had sent me an email explaining his position…
    Here’s the text of the art appraiser’s e-mail to Lindzen:
    I am sorry to inform you that after some consideration, I’ve decided not to perform the appraisal service that you’ve requested. Your writing on the subject of global warming is offensive to me personally, and I feel that I would have difficulty being an impartial appraiser of value given my view on the subject.
    If you’re not familiar with Lindzen, here’s a clip from his bio:”
    http://canadafreepress.com/index.php/article/12056#When:11:36:01Z

  21. Money spontaneously arose in human economic interaction based on inherantly obvious needs. Anytime we allow government the power to create money out of thin air, we only invite government to print all it wants, and in the process steal our collective wealth through dilution.
    We are just going to curse the day when we allow government to add this new dimension to fiat money. The value of money must be based on what people judge it is worth. Government attempts to maniuplate this value by forcing interest rates up or down. This is bad enough. It is a form of economic serfdom that now will be tied to the whims of climate alarmism. We are the most highly educated fools in human history if we allow this.

  22. “stevsadlov”
    “The war plus the failing food supply results in the deaths of some 2 to 3 billion souls”
    Now all we have to do is make sure that it’s the 2-3 billion AGW/veggie/anal retentive souls that depart and that just leaves the 57 billion normal/skeptic/realists to rule the earth. Now what was that “B” Ark for exactly. They could be the ‘pioneers’ instead of departing from life. (As we know it Jim)

  23. Attached is a except from my letter to EPA. Perhaps this aspect of “modeling error” could be the subject of investigation by you or one of your esteemed contributors.
    3) Models are very susceptible to the biases of the individuals who develop the models. Models must contain various assumptions and estimates because not all information is factually known. It is quite common for professionals to agree that these assumptions should fall within a “range of reasonableness”. However because many of these variables interact, they can be highly sensitive to the magnification effect (resulting forecast error) that can happen when even slight biases occur within each of these ranges of reasonableness. Thus a model can profess to be reasonable and none of the individual variables may appear to be extreme, and yet oftentimes the outcomes are not reasonable and are in fact extreme.
    Clearly monetary reward most likely influenced the model assumptions that were used by investment banks to assess the risks related to financial products. I suggest that environmental scientists are also likely influenced by their sincere desire to protect the environment. Regardless of how noble this desire is, the consequences are that their forecast models can and likely do magnify their biases, thereby resulting in inaccurate projections and outcomes.”
    In a “real life example”, I negotiated with a major company the costs of infrastructure improvements, including an offset from toll revenues generated by traffic to the company’s facilities. Our modelers and their modelers prepared independent forecasts of traffic and revenue. While each model used the same professional standards, the results were wildly different based on biases and the compounding effects of small differences in assumptions regarding interdependent variables. While I wouldn’t know a climate model if you put one in front of my face, I do understand human behavior and general modeling concepts and I suspect the same types of modeling bias exists. This is one of the primary reasons I am skeptical of the climate model results. This and the fact that I have NEVER witnessed a model that could forecast any aspect of the future with any degree of certainty.

  24. This is a battle between the new internet information era and old fashion government spin. Can’t wait to see which side will wins this fight. 🙁 not hopeful unless there is some kind of major back lash against Obama.

  25. The endangerment finding is coming, it is the last leverage to pass the cap and trade nonsense and timing is everything. IT is a game of regulatory chicken with a beefed up EPA with a an extra 10 Billion over two years in the bank 7.2B of it courtesy of the Stimzilla package (hey how did that get in there? Maybe we should have read it first?).
    You do not arm your stormtroopers and then leave them at home.
    If the Cap and Trade freezes on the vine ala Grapes in Brazil the EPA will be there with the Clean Air Act in hand because they do not require any Congressional approvals to levy fines and shut down companies. So the hacks on the Hill will pass the Cap and Trade bill on the delusional basis that then they will be able to control the legislation and the implementation if they pass the legislation.
    Unfortunately that will not be true because the EPA will be enforcing the Cap and Trade reporting and will still have the CAA in their back pocket in case some people try and fight back or a future Administration wants to undo the damage.
    These enviros have the best politicians and lawyers that money can buy on their side and they played this one perfectly, via the courts and using the regulatory framework that was in place and they are only two moves away from checkmate.
    I cannot see a way out of this one …

  26. Looking at historical global CO2 emissions estimates over the last 50 years, and comparing this to the Mauna Loa Chart, why isn’t there a larger acceleration?
    These are the changes that I get from 1959 for each decade
    8, 12, 17, 15, 19(14.6 for 2007)
    while the CO2 megaton emissions for the decades are
    29500, 45200, 54200, 63000, 72900(thru 2006)
    So 1959-1969 increase is proportional when compared to 69-79 increase
    8/12 = 29500/45200
    but then there is a 41% increase while emissions only rose 20%,
    a 12% decrease while emissions rose 17%, and a similar mismatch for the last decade. We can estimate about 90000 thru 2008, so that would be a 40% increase , with only a 20% increase in the rate of change.

  27. Congratulations Anthony!. It is a most valuable effort trying to convince with sound scientific arguments those who are deaf and blind.
    History will recognize this endeavour.

  28. These enviros have the best politicians and lawyers that money can buy on their side and they played this one perfectly, via the courts and using the regulatory framework that was in place and they are only two moves away from checkmate.
    I cannot see a way out of this one

    Yep, write in all you want, it may make you feel better, but the fix is in.

  29. RE: “I cannot see a way out of this one …”
    Don’t worry, nature bats last. Within a few years none of this will matter any more.

  30. “Steven Hill (12:40:25) :
    People in Government better take a look at Iran…it could happen here next.”
    Where is here?
    Are you talking about the riots or the fixed elections. Here in the uk we are on the edge of this. We have the most unpopular (unelected) prime minister (ever… probably) who wants to change the voting system before the next election (allegedly) to try to stay in power.
    So now we have: Mugabe, Ahmadinejad, Gordon Brown.
    Sad world we live in.
    Absolute power corrupts absolutely.

  31. Big Government relies on voter apathy, and uses the media to instill a sense of powerlessness and futility. Take hold of your own destiny and combine forces to resist dishonesty and greed in it’s attempt to subvert the constitution of your country!
    Follow Anthony’s example and give it your best Endeavour. This is the beginning, not the end.

  32. chillybean (16:01:51) :
    Are you talking about the riots or the fixed elections. Here in the uk we are on
    the edge of this. We have the most unpopular (unelected) prime minister (ever… probably) who wants to change the voting system before the next election (allegedly) to try to stay in power.
    So now we have: Mugabe, Ahmadinejad, Gordon Brown.
    Don’t forget Kevin07, Ahmadinejad could have won the last Australian election against Howard. We have no choice and yet somehow our governments actually think they have some moral authority over nations like Iran.
    It’s pretty clear to me that these governments have been bestowed upon us to complete an objective as can be seen by this report by the ABC’s lateline. The Obama administration is hell bent on a “sweeping emissions trading scheme”.
    The video attached is worth a look because It’s pretty funny, they even have the water vapor from power station cooling towers disaster footage in there.
    http://www.abc.net.au/news/world/
    http://www.abc.net.au/lateline/content/2008/s2601255.htm?layout=popup

  33. Dang it. I keep forgetting to write up a riff on this. Thanks for the reminder, Anthony. I have to think hard about what exactly I’m gonna try and get across…

  34. maz2 (12:57:42) :
    I hope the identity of the appraiser will be disclosed. If he decides to let his political (yes, political) ideology get into his way of serving clients, be my guest. I, for one, will refuse to use his service. And I hope many will do the same.
    Thankfully so far the more important professionals, such as medical doctors, have not shown this type of ridiculous antic. Not that I have heard of, at least.

  35. We in Canada are on the cusp of implementing a cap and trade program. My hope is that the people will band together and refuse to pay the huge price tag associated with this. Tallbloke mentioned voter apathy as a tool of the government (paraphrasing). The people still have a voice, but they need to use it. Most people that I know are so sick to death of being lied to and misled that they do not even pay attention to politics They do not even watch the news (too depressing) and are unaware of world events of any kind. The fear instilled by the government and the MSM has driven most people into a cocoon like existence. We must encourage those around us to grab this thing by the nads. Let them know that the world is what we make of it. That we still have a choice in all this. I will not lie down. Whatever tomorrow brings. There must be no collective fetal position.

  36. On a lighter note, had to go for the dreaded digital exam today. Felt more like analog to me, ………. :^o

  37. Politicians didn’t listen when 93% of Americans didn’t want the Banks Bailout. They didn’t listen when people didn’t want the trillion dollar President Obama proposal in January. They aren’t listening to the record cold and snow that should be stopping them from cap n trade and carbon regulations. They wouldn’t let Monckton talk before them for fear (IMO) of the public seeing him on C-SPAN.
    To sum up :
    They aren’t going to pay attention to any email I send telling them co2 is good for the earth. I think they’ll just use it behind the scenes it to formulate rebuttals to the things I say.
    But maybe I’m jaded.

  38. I hope I don’t get too politically-oriented… but what will you do if the congress passes the Waxman-Markley bill, despite all the evidences against AGW?

  39. TomLama (09:26:13) : I let the EPA know that we know that it is impossible to tax the temperature of the planet down. I let them know that this is a fraudulent attempt for government mandated gas price gouging.
    Well, never underestimate the stupidity of a bureaucrat or their ability to tax anything that moves and some things that don’t.
    I once got a tax bill for dead people. Really.
    When I inherited the house in which I lived as a child, after a few years, there appeared a “special district tax” added for “cemetery costs” for a local cemetery. I was being taxed for dead people. Never mind that the cemetery was paid to burry the dead people and was supposed to invest the payment so as to pay for lawn mowing in perpetuity…
    California is presently debating a “balls tax”. If you would like your pet to retain it’s balls you will be required to pay a special tax. Failure to comply will result in severe penalties (one presumes for both the tax payor and the balls). This is NOT a joke… There will also be (though no doubt named differently) “balls police” who will be inspecting ANY outdoor animal for compliance with the special tax… One can only hope this fails, since if it passes one can only wonder how long before the scope is expanded…
    (The incredibly stupid part of this is that, as an economist, I was required to study population dynamics. ALL that matters is fertile females. One male or 10 makes little difference. You get the same total population increase with 10 fertile females and one very happy male as with 10 fertile females and 10 males fighting with each other… But the reality is not in compliance with the political need to hold males responsible.)
    What can be taxed, and on what pretext? There is no limit to how low they can go, really… 6 feet under or…

  40. wws (10:49:33) : a “heat based currency” will become reality about the same time the entire human race begins speaking Esperanto. When does the “anticipation map” book that one into our future?
    A google of: “anticipation map” future
    returns exactly 108 hits, high on the list being this posting in this blog. Whatever “it” is, it does not have much of a following…
    BTW, esperanto is so 1960’s… having been replaced by “Ido” that drops the obligatory accusative case and eliminates the requirement for agreement with adjectives and nouns. Much better. The accusative always tripped me up in Esperanto.
    Though my favorite is Interlingua
    http://en.wikipedia.org/wiki/Interlingua
    which I can read just fine having never studied it at all… it has a common base with many indo-european languages…
    I could almost get behind it as a standard artificial language we could all share, since it took almost no effort on my part to learn anything…
    FWIW, ANY currency will need a central banker and international recognition. I don’t see any political constituency for such a thing. Besides, how does one deal with all the heat available for monetization in the Sahara as compared to, say, Siberia ?

  41. theBuckWheat (13:17:37) : Money spontaneously arose in human economic interaction based on inherantly obvious needs. Anytime we allow government the power to create money out of thin air, we only invite government to print all it wants, and in the process steal our collective wealth through dilution.
    Money actually arose through barter. It started as things of inherent value, then moved to things of symbolic value. The large stone doughnuts of one culture were particularly amusing when we were studying ‘money’. They had their own inflation problem since anyone could make a stone into a doughnut with a bit of work. FWIW, the mandate that the USA ought to have only gold and silver as legal money was for precisely the reason you present: to prevent printing and dilution.
    Unfortunately, the ‘gold standard’ also has issues, not the least of which is that during the 1950s and 1960s, the Soviet Union was a major gold producer and in a very real sense we had handed the value of our money supply over to an arch enemy. While I don’t like the “solution” I can understand the reasons…
    Climate Heretic (15:19:17) : If the Cap and Trade freezes on the vine ala Grapes in Brazil the EPA will be there with the Clean Air Act in hand because they do not require any Congressional approvals to levy fines and shut down companies. […]
    These enviros have the best politicians and lawyers that money can buy on their side and they played this one perfectly, via the courts and using the regulatory framework that was in place and they are only two moves away from checkmate.
    I cannot see a way out of this one …

    That is because you are focused on the physicality of where you live. Your money needs no passport to relocate.
    Look, it takes about 10 seconds to move your wealth to a different place. Does it really matter where your body lives? I sent my money largely “Out Of The U. S.”, or OOTUS, some time ago. Each day I assess the place that has the best advantages and the best momentum. One click, and a few seconds and it flies to a new country.
    At this point I hold ONE U.S. Bank security. That is a “preferred stock” with a double digit yield that I may sell in the next few weeks. I hold mostly non-US assets. A lot of it is in BRIC – Brazil, Russia, India, China. Along with a bit of Israel, Turkey, some Bermuda, a bit of Chile and Peru, some Canada and Australia. Most of my “currency” exposure is to the Brazilian Real, the Aussey and the Canadian dollar. A bit of Japanese yen and some British Pounds (though the company in question, Vodaphone, is doing a lot of bussiness outside of the UK, so earnings are in another mixed bag of currencies).
    The point? The way “out of this” is one mouse click away in your self directed investment account. Find the country that is going to win and put your money there. Click Click DONE!
    A bit of India, a bit of China ( I own EPE and FXI in both) a bit of Brazil (I own a lot of EWZ in Brazil) some shippers (mostly in Greece and Bermuda) etc.
    Frankly, one of my key investment drivers is “OOTUS” and another is “Not what Obama and the Democrats are screwing around with”. You just don’t need to be there: Click Click DONE!
    So my home is in the USA. Fine. Inflation will make my mortgage (fixed, 30 year) a fond memory that I can pay off with a credit card in a few years. I’m “good with that”. Food and oil going up? I own the food tickers and oil trusts that will pay out more each year of my life. New cars going to cost $50,000 from Gov.Motors? No problem. I have a fine old 1982 Mercedes that I will be driving until I die. Why do I care? Socialized Medicine? Buy TEVA (an Israeli generic drug maker) and short U.S. hospitals.
    The way out is easy. Whenever “The Minstry of Stupidity Speaks”, move your money to the place that will win. I don’t really care where my laundry dries or where my body sleeps… ( In fact, I used that to get a government subsidy for about $20,000 / year for something; but I’ll say no more lest it cause “issues”…) So you can be upset at their stupidity or you can make money off of it. The stupidity will be there in either case, “You cain’t fix stupid”…
    At this point, with my assets largely in tax sheltered retirement accounts and my “liabilities” exposed to government stupidity, I just don’t see where I care what “Obama and The Dees” does. Then again, I’m one form away from a second passport that lets me go anywhere in the E.U. and the British Commonwealth; should I choose to fill it out, and that may bias my thinking. It’s easier to be calm when you have an “out’…
    gt (21:21:42) : I hope I don’t get too politically-oriented… but what will you do if the congress passes the Waxman-Markley bill, despite all the evidences against AGW?
    I’ve already done it. I don’t care what Waxman-Malarkey does. It can only help my investments elsewhere. I’ve cut my “income” back to near nothing (building wealth inside IRA type accounts instead) and I have no significant payments for anything. I’ll move my money where the winners are and OOTUS as long as the USA is brain dead. That looks to be a long while….
    The more they “do stupid” the more I make money where folks do not do stupid things. What could be better?

  42. E.M.Smith (22:28:41) :
    wws (10:49:33) : a “heat based currency” will become reality about the same time the entire human race begins speaking Esperanto. When does the “anticipation map” book that one into our future?
    FWIW, ANY currency will need a central banker and international recognition. I don’t see any political constituency for such a thing. Besides, how does one deal with all the heat available for monetization in the Sahara as compared to, say, Siberia ?

    Simple, they are already taxing us additional fuel duty to fly, they will simply up that tax in proportion to any positive difference between the average temperatures of the points of departure and destination. They’ll get you one way or the other…
    I wrote this extra verse Monty Python’s ‘Galaxy song’ a while ago
    http://www.gecdsb.on.ca/d&g/astro/music/Galaxy_Song.html
    Well the planet’s getting hot, “It’s co2!” – or maybe not,
    It’s got the Hacks and Greens in such a spin.
    We’re taxed into the ground, for driving cars around,
    And jetting off to Spain is such a sin.
    But don’t believe it yet, keep your cool and hedge your bet,
    The temperature is dropping every day.
    The ocean cooling down, will stop the gulf stream rolling round,
    And the glacier from the north is on the way.
    🙂

  43. Kudos to Anthony for an excellent comment and letter/document. TALLBLOKE comment is right on. Do not despair, give it you best effort in responding back to the EPA. The postings especially those that reference peer review can be used in court to challenge any proposed regulations or rulings. There is every reason to believe using the same tactics of the left, we can defeat or at the very least delay any damaging EPA actions for years, allowing nature to show whose boss. SteveSadlov is correct “…nature bats last”.
    As for Waxman Markey, there are a lot of rural democrats who feel the coastal “damn the red states” democrats are ignoring their concerns. Waxman and Markey will try and buy them out. You need to contact your local reps/senators and tell them to follow their instincts and vote no on Cap-n-Tax or they lose your vote in 2010 or 2012.
    Senator Inhofe believes it will fail in the senate, but I fear the same thing will happen with attempts to buy the votes. There is a lot of money out there pushing these efforts. Anytime you see firms like Goldman Sachs and GE pushing an effort hard, you can be sure it isn’t because they care about polar bears. They see huge potential profits. Ultimately the bubble will burst and our economy and consumers will suffer, but some people will have been made very rich (at the expense of all the rest of us). And of course, our government will bail the companies out if carbon trading fails again at our expense. Another black hole.
    Please take action. Posting is easy but you are mainly speaking to the choir, we need you to do more. Tell everyone you know about the real story. Only 24% of Americans in a recent survey knew that cap-n-trade had anything to do with energy and the environment. Many though it had to do with health care. Many think it brings only benefits and no costs. That is what Waxman and Markey and the state climate plan teams all claim. Studies have shown it will cost an average of $1600 to $4200 per year in energy and other cost increases for goods and services for an average American family. There will be millions of lost jobs. Ignore the nonsense about green jobs. Spain’s experience has been for every green job created, 2 real jobs are lost as manufacturing moves overseas (China and India) where they don’t have onerous taxes. And only 1 in 10 green jobs are permanent. Encourage others to call their representatives or attend town hall meetings.
    I have been a conservationist and environmentalists (old sense) all my life, but this is not about the environment (and most of my life a democrat or independent). This is a political and economic tsunami that cares little about science or real data or for that matter the planet. It sees this issue as any opportunty to develop a new world order and exert more control over us and everything we do. It will take a huge effort from all of us to defeat it.

  44. gt (21:21:42) :
    ‘I hope I don’t get too politically-oriented… but what will you do if the congress passes the Waxman-Markley bill, despite all the evidences against AGW?’
    I’m doing two things.
    I’ve been letting my representatives know that if they vote for any type of CO2 regulation, I will work very hard to make sure they do not return to Washington. (Do not email, fax your representatives)
    And stop paying taxes by keeping my spending down to the bare bones. (The only time the government collect taxes is when you spend your spendable income)
    CO2 Cap and Tax
    Corporate Welfare for Wall Street

  45. juan (11:31:06) :
    “I don’t know if this will be useful or not. Americans for Prosperity have a setup for submitting comments on the EPA proposal that I found very easy to use. They have a boilerplate letter, but it’s easy to do what I did–erase it and write your own. The link is
    http://capwiz.com/americansforprosperity/issues/alert/?alertid=11825801&type=CU
    Another thanks to you, juan – I just got my opinion off thanks to your link. Despite the doom and gloom of “the fix is in”, I like to be on record.

  46. I t may be time for another reminder on this Anthony, this thread got lost in the blizzard of posts over the last few days.

  47. Once again, the CO2 issue is “settled”. I don’t have the article, published in Science, but this news report indicates that studies showing much higher CO2 concentrations in the past will be safely ignored in the upcoming discussion. There seems to be little time for a rejoinder to this last minute attempt to pull a nail out of the AGW coffin.
    June 18 (Bloomberg) — Carbon dioxide in the earth’s atmosphere has risen to its highest level in at least 2.1 million years, according to a new investigation of the greenhouse gas’s role in ice ages over the millennia
    […] according to the study published today on Science’s Web site.
    see http://www.bloomberg.com/apps/news?pid=20601072&sid=aG5p2kBin538

  48. My previous comment was based on the reality of the situation but in no way do I advocate NOT sending in comments. I have sent two, one personal and one for my business.
    The problem here is not one of democracy, the problem is legal, the courts have ruled that CO2 is a danger and must be regulated under the Clean Air Act. To not do so would leave the EPA open to massive lawsuits from well funded enviro-groups.
    The more comments the better if the court ruling is ever to be overturned, but it will not be now, the EPA and the Administration is populated with Enviromentalists who believe 100% in AGW and so they have no inclination to stand up for the will of the people.

  49. I’d like to use the AFP comment idea, but as a layperson relatively new to all this information, would like to know if anyone has a suggestion what I could add to the boilerplate. Thanks

  50. I went right to the beef. Just wrote again to my US legislatures here in Oregon regarding the Energy Bill. Let em know one and all that if they come anywhere near this bill or even the watered down version of it that gives a hat tip to global climate catastrophe garbage, they will get my no-vote next election. Think I’ll go another round to tell them to go over to the EPA and knock a few heads together.

  51. to Jerry Lee Davis re: EPA email address that bounced.
    Jerry the EPA published this faulty email address in the Federal Register. On Auto, the first hyphen was not the same as the second in the address. They gave us a faulty edress for the advanced comments also.
    Do not cut and paste theirs. It will be ok if you type it aout and do normal – hyphne marks.
    This is accurrate: GHG-Endangerment-Docket@epa.gov
    I submitted by email, by gov regulations email and by express hard copy mail.
    Floy Lilley

  52. I emailed my two liberal, Democrat Senators about my dislike for “cap and trade” legislation. One of them, John Tester, replied that global warming is real because he has been planting crops on his farm earlier and earlier the last few years. Imagine my surprise, since we had a hard frost and snow in my area on the 8th of June after a very cool spring here in Montana. Last year we had frost on the 11th of June. I can only presume he has moved his farming operation to DC or, more likely, he is just full of it, and the fix is in on this legislation.

  53. Free money comming cheap!
    http://www.pbn.com/detail/43115.html
    Posted June 19, 2009
    energy
    Carbon price falls in RGGI’s 4th auction
    By Ted Nesi
    PBN Web Editor
    PBN FILE PHOTO
    DOMINION RESOURCES, which operates the coal-fired Brayton Point power plant in Somerset shown above, was again one of the bidders in the latest RGGI auction, held earlier this week.
    NEW YORK – The price of a permit to emit one ton of carbon in the Northeast states’ regional cap-and-trade program fell by 8 percent in the program’s third auction, which was held earlier this week, administrators said today.
    The Regional Greenhouse Gas Initiative (RGGI) said it sold all of the nearly 31 million permits for carbon emitted in 2009-2011 that were up for auction at a clearing price of $3.23 per permit. The electronic auction was held on Wednesday.
    That was down from the price of $3.51 each that the permits fetched in the previous auction last March, but the number of separate entities placing bids rose to 54, compared with 50 in March.
    The auction raised $104.2 million for energy efficiency, renewable energy and other programs in the 10 participating states, which include Rhode Island, according to RGGI Inc., which administers the program on the states’ behalf.
    Rhode Island will receive $1.49 million in proceeds from this week’s auction, RGGI said. The R.I. Office of Energy Resources earlier this year outlined plans to spend the money by expanding a number of existing energy efficiency programs overseen by National Grid, Rhode Island’s dominant gas and electric utility company.
    The bidders included National Grid and a subsidiary of Dominion Resources Inc., which owns Providence’s Manchester Street and Somerset’s Brayton Point power plants.
    In addition, RGGI sold all of the nearly 2.2 million permits for carbon emitted in 2012 on offer for a clearing price of $2.06 each. That was down by a third from the March auction, when 2012 permits sold for $3.05 each.
    The future of the RGGI program is currently uncertain as Congress considers a federal cap-and-trade program to reduce greenhouse gas emissions. A bill under consideration by the House of Representatives would end the RGGI program and allow holders of RGGI allowances to exchange them for federal permits.
    RGGI is a 10-state compact that calls for freezing and then reducing carbon dioxide emissions, a leading cause of climate change, by 10 percent over the next decade. Under RGGI (pronounced “reggie”), power plants that use fossil fuels must buy a permit for every ton of carbon dioxide they emit.
    Although the cap for emissions technically went into effect on Jan. 1, there is a three-year compliance period, meaning polluters do not have to submit allowances to cover their 2009-2011 emissions until March 31, 2012.
    The next RGGI auction is scheduled to be held Sept. 9.

  54. Ron de Haan (19:22:54)
    ‘The auction raised $104.2 million for energy efficiency, renewable energy and other programs in the 10 participating states, which include Rhode Island, according to RGGI Inc., which administers the program on the states’ behalf.’
    Just tack it on to the cost of goods sold.
    And you wonder why people and business are moving out of the RGGI area.

  55. It took me some time to find the URL for submitting comments to the EPA on GHG regulation. It is: http://www.regulations.gov/fdmspublic/component/main?main=SubmitComment&o=090000648096894b
    Maybe I am just slow but my problem was searching for “EPA-HQ-OAR-2009-0171” mixes the document you want to comment on with every submission made on that document (thousands).
    The EPA is not going to decide they don’t have the authority to regulate CO2. The Supreme Court said they have that authority … that the EPA can decide whether or not they should regulate based on their view of the science. My point is the decision is now in the scientific and not the legal arena. But things that overlap … like a British court ruling the Al Gore film was incorrect in claiming increased CO2 led to increased GW are very relevant to the decision the EPA will be making.

  56. I put my two cents worth into the EPA. Its buried on page 223 Comment # 2887.1, but I think you will find it interesting. I did some energy transfer calculations on the IR heating of the air at 2 meters above the ground. A 100 ppm increase in CO2 has no effect on the heat transfer, or on the meteorological surface air temperature. And a 100 ppm increase in CO2 does not heat the oceans either. Just count the sunspots and run the numbers. The climate change falls right out.

  57. I disagree with the assertion (Climate Heretic (10:15:23) ) that US courts have ruled that CO2 is a danger. The Supreme Court ruled on this issue and explicitly stated something very different. They made it clear that they were NOT (nor was a junior court) ruling on the danger of CO2. They simply stated that making that decision was the responsibility of the EPA.
    The EPA position was they had no legal authority to regulate CO2 and the Supreme Court said: you not only have the legal authority but the legal responsibility…not to decide CO2 is harmful … but to make a determine if it is harmful … and if so, then to regulate it.
    I am not a lawyer (nor do I play one on TV) but I did read the decision and the above is my interpretation.
    My apologies if this sounds like legal nit-picking … I know the press presents the issue exactly as implied by Climate Heretic but the distinction is important. Especially to those submitting comments to the EPA. Comments over their legal authority will be ignored (they already have their marching orders on that) but comments as to the science are VERY relevant.

  58. My letter … short and sweet.
    How is paying taxes to the government going to control the sun?
    The SC ruled that CO2 might, may, could — yeah it’s possible that plant food is a health danger, so if you think it is go ahead and regulate it. Court based ‘science’.

  59. The courts ruled there was enough evidence that CO2/GHG Family was a danger and that a previous decision by the EPA to not regulate the GHG family of gases was WRONG because it was based on pending Cap and Trade or other legislation in Congress.
    The EPA cannot make the determination without following the regulatory procedure, which includes public comments, this is just the wheels of government turning.
    The ruling states that there is ample evidence that GHGs are harmful (pollutant) and as such are the domain of the EPA. If the EPA does not find that GHG from tailpipe emissions are a danger then they are leaving themselves open to civil suit.
    Here is the Finding from the Supreme Court
    In Massachusetts v. EPA, the Supreme
    Court reversed the lower court’s
    decision and held that EPA had
    improperly denied the petition. 549 U.S.
    497 (2007). The Court held that
    greenhouse gases are air pollutants
    under the CAA, and that the alternative
    grounds EPA gave for denying the
    petition were ‘‘divorced from the
    statutory text’’ and hence improper.

    Specifically, the Court held that
    carbon dioxide, methane, nitrous oxide,
    and hydrofluorocarbons fit the CAA’s
    ‘‘sweeping definition of ‘air pollutant’ ’’
    since they are ‘‘without a doubt
    ‘physical [and] chemical * * *
    substances which [are] emitted into
    * * * the ambient air.’ The statute is
    unambiguous.’’ Id. at 529. The Court
    also rejected the argument that postenactment
    legislative developments
    even ‘‘remotely suggest[ed] that
    Congress meant to curtail [EPA’s] power
    to treat greenhouse gases as air
    pollutants.’’

  60. Oops I cut the most important part off.
    ‘‘whether an air
    pollutant ‘causes, or contributes to, air
    pollution which may reasonably be
    anticipated to endanger public health or
    welfare.’ ’’ Id. at 532–33. Thus, ‘‘[u]nder
    the clear terms of the Clean Air Act,
    EPA can avoid taking further action
    only if it determines that greenhouse
    gases do not contribute to climate
    change or if it provides some reasonable
    explanation as to why it cannot or will
    not exercise its discretion to determine
    whether they do.
    ’’

  61. I disagree with the assertion (Climate Heretic (10:15:23) ) that US courts have ruled that CO2 is a danger. The Supreme Court ruled on this issue and explicitly stated something very different. They made it clear that they were NOT (nor was a junior court) ruling on the danger of CO2. They simply stated that making that decision was the responsibility of the EPA.
    The EPA position was they had no legal authority to regulate CO2 and the Supreme Court said: you not only have the legal authority but the legal responsibility…not to decide CO2 is harmful … but to make a determine if it is harmful … and if so, then to regulate it.
    I am not a lawyer (nor do I play one on TV) but I did read the decision and the above is my interpretation.
    My apologies if this sounds like legal nit-picking … I know the press presents the issue exactly as implied by Climate Heretic but the distinction is important. Especially to those submitting comments to the EPA. Comments over their legal authority will be ignored (they already have their marching orders on that) but comments as to the science are VERY relevant.
    OH! You’re my new favorite blogger fyi

  62. old construction worker (20:21:27) :
    Ron de Haan (19:22:54)
    ‘The auction raised $104.2 million for energy efficiency, renewable energy and other programs in the 10 participating states, which include Rhode Island, according to RGGI Inc., which administers the program on the states’ behalf.’
    Just tack it on to the cost of goods sold.
    And you wonder why people and business are moving out of the RGGI area.
    old construction worker,
    Just wait untill the price hits 35 dollar or more.
    NO TAX OR EMISSION RESTRICTIONS ON CO2, THE GAS OF LIFE (PROSPERITY AND FREEDOM)

  63. Yeah it’s amazing when you see things going onin Kalifornia where they literally cut off the water supply to about 85% or the farmers to save a minnow where by putting humane life behind that of a Minnow and turtles and who knows what is coming next. As for the major increases in Co2 in the last 10-20 years is to graph the increase of Co2 for there own purposes to show there really is GW when in fact the trends thay have been modeled form zround the world show otherwise. We are being Dupped on a daily basis and allowing it to happen right before our very eyes, WE as a republic need to take a stand and say enough is enough, gives us our money back that has been stolen and given to these groups of Enviromentalist who inly model the current Eviroment to back the EPA just to continue on with there research and feed the hand that feeds these unscrupulous people who refuse to actually work for a living or atleast do so in a truthful way !!!! A Minnow over 85% of farmers in Kalifornia, wheres the justice in this…. Will these groups and organization not be happy until all civilization is done away with and were back to the STONE AGES I’m not sure I understand and to top it all off there all Hipocrite. Show me a handful of Enviromentalist that was there clothes using a wash bd, read by candle lite, and store there food form there own gardens in a root cellar, and do not use a computure, or watch TV or listen to a Radio oh and last but not least either walk to work or ride their bikes and do not smoke !!!!! Someone show me where these do sayers are who wish to impose such regulation onto others but also chose to live by the motto of DO as I say, Not as I do.

  64. Designating carbon dioxide as a polutant is ignorant and foolish. I could go on and on, but I work for a living.

  65. I don’t understand why we never hear from the opposition on this matter. It seems all the media is in the tank on this and no one wants to hear what thousands of other sicentists, all more qualified than Al Gore, and only hear about the discussion is over. This is the biggest lie ever perpetrated on the American public since snake oil. BULL!

  66. I don’t understand why we never hear from the opposition on this matter. It seems all the media is in the tank on this and no one wants to hear what thousands of other sicentists, all more qualified than Al Gore, have said. Over 34,000 scientists have signed a document stating their position on this hoax. Yet, all we hear about, the discussion is over. This is the biggest lie ever perpetrated on the American public since snake oil. BULL!

  67. 23 June is the last day to submit your views on CO2 regulation to the EPA. A simple way to voice your opinion is to click on this link … http://www.regulations.gov/fdmspublic/component/main?main=SubmitComment&o=090000648096894b
    … and type in your comment. You can even remain anonymous … though I expect providing a name will result in your comments being taken more seriously.
    I submitted my opinion: http://www.regulations.gov/fdmspublic/component/main?main=DocumentDetail&o=09000064809d4590
    If you oppose CO2 regulation for reasons similar to mine, feel free to reference the report I provided as a “supporting document”. That may make the EPA more likely to read it! My position is similar to what you hear from many “deniers” with these twists:
    1 IPCC forecasts (4 of them) have all been dramatically wrong. So wrong the implication is: it is impossible to take them seriously.
    2 Climate models are compared (quite unfavorably) to the financial models that enabled the recent global financial meltdown.
    3 President Eisenhower’s farewell speech warned of two major threats to democracy. One was the famous military-industrial-complex. The other was a scientific-technological elite. (No one remembers that one?) The envisioned threat was scientists (dependent on federal funding) would provide results desired by the government and researchers and politicians would take advantage of the public. This idea (which I have not seen elsewhere in this debate) is developed and documented; global warming is presented as the 1st manifestation of this threat to US democracy.
    Anthony, please consider another post on the main page reminding your readers the EPA comment period ends 23 June 2009.

  68. Pofarmer said:
    “Now, indeed the AVG temp for may is the highest, at least since their easily accesible records started in 2000. HOWEVER IT”S NOT BECAUSE OF THE HIGH TEMPS. THE HIGH TEMPS ARE STATIC, IT’S BECAUSE OF WARMER LOWS.
    I think this goes right in with the theory that clouds are a temperature control mechanism.
    Can somebody PLEASE help out with this???????????”
    My Reply:
    You are right. I did an analysis on this some months ago after examining the CET records back to 1660 and posted it here. Winters are warmer than the LIA (not surprising!) but summers are generally no warmer so the mean average is shifted higher because there are not the lower temperatures to mitgate against them.
    If you see this and respond I will see if I can dig the post out.
    Tonyb

  69. I got my comment submitted. I had a little difficulty I but finally figured things out. At http://www.regulations.gov one needs to search for the particular docket item and there is a chance you’ll end up commenting on someone else’s comment if your not careful.
    For me, as a farmer, the issue is that global warming is a good thing (if you insist on believing in that way) and facing the inherent uncertainties of weather and climate we might as well look to managing the global climate in a way that is optimal for food production. Crop failures due to summer freezes are not an impossibility and the repercussions of crop failure would be far worse than anything that I’ve seen tossed about by the global doom by warming crowd.

  70. Farmer Hank. Yep we have frost damage on wheat. Moisture corrects for heat damage. I see there is a lot of acreage for farming in the Northern parts of the souther Canadian provinces. Farmers keep records. Every year a Farmer compares his wheat harves in terms of yield but also dates. If the area is warming that means last frost is earlier. Harvests are not going earlier. You can plant an earlier variety of wheat that matures a little earlier but you can’t alter the fact that the season is not warming and the harvest is not earlier.

  71. Here is what I, as a non-scientist citizen sent in. I think it is very important that the agency hears from the informed lay public.
    I appreciate the opportunity to submit a comment on Docket No. EPA-HQ-OAR-2009-0171, the proposed public endangerment finding in regard to carbon dioxide and other greenhouse gases.
    I am writing as a private citizen, I have no public office or position. My involvement with groups involved in one side or another of environmental issues is limited to a membership in The Nature Conservancy for a number of years and very large donations to that group and a past membership in the Sierra club. I have a law degree and an MBA and I currently work primarily as a mergers and acquisitions advisor in the health care industry. I believe it is particularly important for the EPA to solicit and consider the input and perspective of ordinary citizens on such a significant matter.
    Although I am not a trained scientist, I have had a keen interest in science since childhood. I have subscribed to Scientific American for over thirty years and also subscribe to Nature and Science. I regularly read science books and I read a variety of online science information sources. I also have training in experimental methods and statistics. Several years ago I became interested in climate science and paleoclimatology. I am old enough to remember the articles regarding an impending ice age in the 1960s and the l970s, so when concerns were raised about a possible human-induced global warming, my curiousity was piqued and I have since read a wide variety of books and articles regarding the topic. I read not only popularized versions of the research but I increasingly seek the source articles published in technical journals. So I believe I have a relatively informed viewpoint and most importantly, a more detached and objective perspective than appears to exist among the various advocates in regard to this topic.
    Many people will undoubtedly submit very detailed comments referring to various research in this area. I would like to briefly summarize a few thoughts and observations.
    1. It appears to be the case that the earth has gone through multiple cycles of warming and cooling in the recent, in geological terms, past. These cycles have gone on well before humans arose on the planet and before humans engaged in activities which had the potential to significantly affect climate. These natural variations appear to be linked to variations in the earth’s orbit which affect the total amount of solar energy which reaches the planet and potentially to actual variations in solar energy output, the geographic configuration of continents and other features and other factors.
    2. In the course of earth’s history, including the recent cooling and warming cycles, carbon dioxide levels have also apparently risen and fallen substantially. Carbon dioxide levels seem to have been higher than they are today in the past, but the earth cooled after those high levels and they have been lower than they are today and the earth still warmed. Given the inherent timing uncertainties in both the proxy temperature and proxy carbon dioxide records, it is unclear whether rising carbon dioxide levels preceded warming and whether falling carbon dioxide levels preceded cooling. In fact, it appears equally likely that rising carbon dioxide levels followed warming and falling carbon dioxide levels followed cooling. Given what we appear to know about the carbon cycle, either possibility could exist. A very recent research paper has shown fairly defiinitively that carbon dioxide levels did not fall before the most recent cooling episode.
    3. The models in which carbon dioxide causes a temperature increase rely on positive feedbacks which are not supported by any actual research. That is not to say that these feedbacks don’t exist, but that there is no real-live experiments or studies which support or prove the existence of these feedbacks. This is a particular concern because negative feedbacks from rising carbon dioxide have also been postulated, although equally unproven. Given the uncertainties in the historical record of any correlation between rising or falling carbon dioxide levels and succeeding warming or cooling, and the lack of any experimental proof, relying on models would seem quite imprudent.
    4. The earth is currently is one of the warming intervals between longer cooling periods. Based on past cycles we are likely nearing the end of this warming period. Warming, however, appears to have tended to continue to increase until a relatively abrupt transition to coooling. Given historical climate behavior, there is a strong possibility that any warming in the last century may be consistent with natural variation. In fact, the burden should be on those who believe it is not due to natural variation to prove that fact, given that natural variation appears so clearly in the historical record and the current warming is not inconsistent with other instances of natural variation in warming.
    5. I have attempted to understand the various climate models used to project global warming. It is very difficult if not impossible to get the underlying equations, algorithms and code. This is an alarming situation if these models are being relied on in the setting of policy. The agency should demand that any models used in considering this issue be fully unveiled and available to the public for evaluation.
    6. Global cooling periods are far worse for humanity than global warming eras. In fact, our current state of relatively advanced civilization is largely due to the most recent warming. It has facilitated the development of agriculture which has allowed a much higher standard of living and enabled urban living which created the environment for much greater sophistication in many human activities. The next cooling period will be devastating to human civilization. Perhaps our efforts would be best directed toward ensuring that we understood all the factors influencing climate and anticipating how we might address the cooling that is inevitably bearing down on us.
    7. The various actions proposed to limit or reduce greenhouse gases in the atmosphere have severe economic costs, particularly for poorer people and nations. The actions would reduce most people’s standard of living. These costs should not be imposed in the absence of firm, indisputable proof that carbon dioxide and other human emissions are responsible for the vast majority of any global warming which is or might occur.
    8. Particulary alarming to me, given the very high regard in which I hold science and the scientific frame of mind, is the emotional tone which has been adopted in regard to this issue. Scientists are human and it would be foolish to think they are immune to the biases and emotions which affect human reasoning and actions. But a scientist should also know that they can understand their own biases and emotions and set them aside. Dispassionate research is critical if we are to have accurate facts upon which to base sound public policy. Unfortunately, it is apparent to me that many of the scientists involved in this field of research have lost that dispassionate objectivity, which makes their research highly suspect. The agency needs to take a critical look at the process by which climate research is being conducted, including whether funding is being objectively parceled out to examine all theories and whether various studies may have been tainted by researchers a priori beliefs.
    The new administration has stated that it wants to restore scientific objectivity to public policy decision-making. There is no better opportunity to do that than this docket item, which is fraught with misleading and misused science. In light of the enormous consequences of action by the EPA, and the inadequate state of knowledge about how climate really works, the only prudent course of action for the agency is to delay any action on this docket and to seek funding to support truly independent and objective research to create more accurate models of likely future outcomes. Until such knowledge is attained, any action is likely to impose unwarranted costs on the American people and lead to actions which may actually exacerbate the effect of climate on our economy and other aspects of our lives. Thank you again for allowing comments and for taking my thoughts into consideration. I would also request that you allow me to testify at any public hearings the agency may hold on this topic. Thank you.

  72. kevin roche
    I read through your comment. Nicely done. I am very much with you on your item number 5. It would be so nice to see a good exposition of the basic mechanics of a climate model. Something that summarized the kinds of factors that are taken into account; perhaps a history of climate modeling; how estimates are made on various factors; how close the estimates are to real world values…. and most importantly what is left out.
    I also read through Monckton’s offering which has a document ID of EPA-HQ-OAR-2009-0171-0700.1 . He does such a beautiful job of going for the jugular in the most cordial way. He makes The Team look like such a bunch of arrogantly lazy slobs….. which I guess is what they are.

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