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–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:
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:
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
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
Anthony, very well-written comment to the EPA.
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.
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.
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
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.
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
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.
Kendra,
To the AFP comment, you can include information from the American Energy Alliance’s model comment: http://www.americanenergyalliance.org/index.php?option=com_wrapper&Itemid=88
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
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.
Look here for the coalition of 186 opposing the Waxman Bill and see if your representative has signed:
http://www.atr.org/coalition-oppose-waxman-markey-cap-trade-a3377
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.
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.
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.
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.
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.
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’.
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.’’
Will this do any good, I left my two cents, but I doubt it will be heard?
I cam accross a pdf that has thousands of sigantures attached to the ruling.
That are for C2 regulation
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.’’
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
Back to square one on the Waxman Climate Bill.
Talks blew up, Good news or Bad news?:
http://www.rollcall.com/news/36041-1.html?type=printer_friendly