EPA CO2 comment deadline for cars and light trucks fast approaching – get your comments in now

Daniel Simmons writes:

Great work with Watts Up With That on the CRU email scandal. Hopefully this scandal will lead to increased openness in climate science.

http://wattsupwiththat.files.wordpress.com/2009/06/epa_logo_1.png

With all of the noise about those emails I wanted to bring your attention to an EPA comment period that closes this Friday. As you previously covered on Watts Up With That, EPA is working on declaring that CO2 and GHGs greenhouse gases endanger human health and welfare under the Clean Air Act.  http://wattsupwiththat.com/2009/11/09/epa-sends-co2-endangerment-finding-to-the-white-house/

That endangerment finding is the first step to regulating GHGs and the second is to develop the actual regulations to regulate GHGs for cars and light trucks. On Friday, the comment period for EPA’s proposed regulations on cars and light trucks closes. It would be very helpful to push back on the proposed endangerment finding by pushing back on the proposed regulations on cars and light trucks and sending EPA as many comments as possible on the proposed GHG regulations for cars.

We want to make sure as many people as possible know about this proposed rule and generate as many comments as possible. To facilitate people sending comments to EPA on the proposed rule, we put up a page that contains a model comment to send to EPA. http://instituteforenergyresearch.org/contact_form/index2.php The model comment is completely modifiable.

Also, here is EPA’s Proposed Rule: http://www.epa.gov/oms/climate/regulations.htm

and a direct link to the Docket to submit comments to EPA is here: http://www.regulations.gov/search/Regs/home.html#docketDetail?R=EPA-HQ-OAR-2009-0472

People can also send email on this rule directly to EPA at a-and-r-Docket@epa.gov.

It would be very helpful if you would let your readers know about this comment period. Because of Thanksgiving and the cap-and-trade bills, this proposed rule hasn’t gotten very much attention and yet it relies on the same science as EPA’s other regulations and will help trigger a regulatory cascade of EPA inserting itself into many areas of life because those activities emit GHGs.

Here’s more background:  To address climate change (and relying on the standards sources of climate science–the IPCC, NCDC, GISS, etc.) EPA is proposing to use the Clean Air Act to require 35 mpg fleetwide fuel economy standards by 2016—four years faster than Congress’ plan in the Energy Independence and Security Act of 2007. Not only will this rule drive up car and truck prices and limit consumer choice, it will start a regulatory cascade with EPA regulating GHGs using a number of sections of the Clean Air Act.

But EPA’s data show that the rule is all cost and no benefit. According to EPA, the proposed rule will increase car and truck prices an average $1,100. (74 Fed. Reg. 49460) As a result of less CO2 in the air, the rule will lead to decrease in global mean temperature by 16 thousandths of a degree Celsius (0.016°C) in 2100 and a decrease in mean sea level rise by 1.5 mm. (74 Fed. Reg. 49589) That’s not a joke—that’s what the rule says. Obviously 16 thousandths of a degree Celsius, 90 years down the road will not affect the climate in any way.

It would be bad enough if the rule only imposed exorbitant costs and with no benefits. But this will start the regulatory cascade that many of us have written about. To finalize this rule, EPA would also finalize their “endangerment finding” (in other words, EPA would find that GHGs from motor vehicles harm public health and welfare). CO2 and GHGs will become subject to National Ambient Air Quality Standards, New Sour Performance Standards, Hazardous Air Quality Standards, among other regulatory schemes.

If EPA makes an endangerment finding for GHGs, that action would make two permitting programs apply to GHGs—prevention of significant deterioration (PSD) and Title V. PSD applies to stationary sources which emit more than 250 tons a year and Title V applies to stationary sources which emit 250 tons per year. According to EPA, this would force as many as 6 million buildings (school, churches, hospitals, office buildings, farms, etc.) to comply with the Clean Air Act’s permitting provisions. To try to address this problem, EPA has proposed a “tailoring rule.” The point of the tailoring rule is that 250 tons per year of emissions can be read to mean 25,000 tons per year. Again, that’s not a joke:  http://www.openmarket.org/2009/10/01/epa-tailoring-rule-confirms-mass-v-epa-set-the-stage-for-administrative-quagmire-and-economic-disaster/

0 0 votes
Article Rating

Discover more from Watts Up With That?

Subscribe to get the latest posts sent to your email.

99 Comments
Inline Feedbacks
View all comments
November 25, 2009 1:56 am

watch—http://www.youtube.com/watch?v=429xoDtqS-A&feature

Brnn8r
November 25, 2009 1:58 am

Ahhh guys, we’ve had an ETS since 2007. The AMENDED bill National has passed has actually watered down a lot of the potency of the Labour ETS.
If anything this is going to allow increases in our emissions compared to the old one.

Johnny
November 25, 2009 2:08 am

They hard-coded the hockey stick into the program which draws the curve! And with the fudge factor they can alter how much the curve bends like the want it to…
To sum up the FUDGE FACTOR postings so far:

Willis Eschenbach (18:59:05) :
This is interesting:
From the progrm file FOI2009/FOIA/documents/harris-treebriffa_sep98_e.pro

;****** APPLIES A VERY ARTIFICIAL CORRECTION FOR DECLINE*********
;
yrloc=[1400,findgen(19)*5.+1904]
valadj=[0.,0.,0.,0.,0.,-0.1,-0.25,-0.3,0.,-0.1,0.3,0.8,1.2,1.7,2.5,2.6,2.6,$
2.6,2.6,2.6]*0.75 ; fudge factor
if n_elements(yrloc) ne n_elements(valadj) then message,’Oooops!’
;
; Now normalise w.r.t. 1881-1960
;
mknormal,densadj,x,refperiod=[1881,1960],refmean=refmean,refsd=refsd
mknormal,densall,x,refperiod=[1881,1960],refmean=refmean,refsd=refsd
;
; APPLY ARTIFICIAL CORRECTION
;
yearlyadj=interpol(valadj,yrloc,x)
densall=densall+yearlyadj
That is more than interesting. It is a perfect example of why the code needs to be released. [..] But look at what they are actually doing. They are fudging the numbers by an arbitrary amount to get the result they want. You probably understand this code, but let me see if I can explain it in English for those who don’t.
First, they put together a list of numbers that will be used to calculate the yearly adjustment. The numbers start at zero, get a bit smaller, and then gradually increase. This list is called “valadjust”.
valadj=[0.,0.,0.,0.,0.,-0.1,-0.25,-0.3,0.,-0.1,0.3,0.8,1.2,1.7,2.5,2.6,2.6,2.6,2.6,2.6]
At the end of their calculations, they use valadj to make a yearly adjustment string, yearadj, by interpolating (taking intermediate values) from the values in valadj. This gives a value for each year, by which each year’s data will be adjusted up or down.
densall=densall+yearlyadj
But of course, they’re fudging things, so it won’t come out right the first time. To control the process, they put in a “fudge factor”, a single number that they can use to change the size of all the data adjustments. This is the “fudge factor” referred to in the code, which at the moment is set to 0.75. This is the 0.75 at the end of the line for setting up the valadj values:
valadj=[0.,0.,0.,0.,0.,-0.1,-0.25,-0.3,0.,-0.1,0.3,0.8,1.2,1.7,2.5,2.6,2.6,$
2.6,2.6,2.6]*0.75 ; fudge factor
They are using arbitrary values plus a fudge factor to make the result just what they want …
——–
Or here (it is IDL not plain Fortran):
debreuil (04:25:44) :
Ok, haven’t done fortran in 20 years, but if I read this right, it is creating a weighting hash for each 5 year period starting in 1904 (two arrays, 1st is year, second is weighting). The forties area are multiplied by as much as -.3, then in 1960 the ‘fudge’ creeps positive, up to 2.6 in 1980 onwards. It then interpolates this over the data. Please correct if this is wrong…
1904 0.
1909 0.
1914 0.
1919 0.
1924 0.
1929 -0.1
1934 -0.25
1939 -0.3
1944 0.
1949 -0.1
1954 0.3
1959 0.8
1964 1.2
1969 1.7
1974 2.5
1979 2.6
1984 2.6
1989 2.6
1994 2.6
1999 2.6
original code (..FOIA..documents..osborn-tree6..briffa_sep98_d.pro)
;
; Apply a VERY ARTIFICAL correction for decline!!
;
yrloc=[1400,findgen(19)*5.+1904]
valadj=[0.,0.,0.,0.,0.,-0.1,-0.25,-0.3,0.,-0.1,0.3,0.8,1.2,1.7,2.5,2.6,2.6,$
2.6,2.6,2.6]*0.75 ; fudge factor
if n_elements(yrloc) ne n_elements(valadj) then message,’Oooops!’
;
yearlyadj=interpol(valadj,yrloc,timey)

Gregg E.
November 25, 2009 2:13 am

Just had to add this one to illustrate just how bad the education systems are getting. A UK teacher’s union, the Professional Association of Teachers, wants to replace the word “fail” in the classrom with “deferred success”.
http://failblog.org/2009/11/25/deferred-success-fail/
Ha! The CRU beat them to it. I guess all TV media other than FNC (and mostly Glenn Beck there) completely ignoring the CRUtape Letters is them hoping for “deferred success”.
Another good one is the IgNobel prize awarded for the Dunning-Krueger effect. http://en.wikipedia.org/wiki/Dunning-Kruger_effect
“Unskilled and Unaware of It: How Difficulties in Recognizing One’s Own Incompetence Lead to Inflated Self-Assessments” In other words the bloody incompetent a-holes that somehow get promoted to positions of authority and only manage to screw things up while thinking they’re doing just fine, no matter what everyone around them says.

Spartan79
November 25, 2009 2:20 am

I hate to be cynica, but you can’t possibly believe that Browner & Co. at the EPA intend to pay the slightest attention to any comments or evidence contrary to their agenda. The law requires public comment and hearings before new regulations can go into effect. The regulations are already written, ready to be issued in the Federal Register the minute the law allows them to be issued.

Paul Z.
November 25, 2009 2:52 am

C’mon you lazy British bastards, sign the petition!
http://petitions.number10.gov.uk/HADLEY-LEAK/
Do you want to pay trillions of pounds for a fraudulent cause so that the rich fascist elite can be the only ones to eat meat, drive cars, and have kids? Next, the AGW zealots will tell us “NO MORE SEX FOR YOU PEONS. CREATES TOO MUCH HEAT & CO2. BAD FOR GLOBAL WARMING.”

Rational Debate
November 25, 2009 3:00 am

Michael (00:30:48)
Michael, there are those who believe total collapse of our system from within is exactly the desired results. Take a look at the Cloward-Pivin theory, promulgated by progressives. Just as a starter, a link from googling Cloward-Piven, with a short excerpt of the article (fyi, many links to further info embedded in the actual article online that haven’t come thru in this copied bit):
http://www.americanthinker.com/2009/02/the_clowardpiven_strategy_of_e.html
-SNIP-
Obama adheres to the Saul Alinksy Rules for Radicals method of politics, which teaches the dark art of destroying political adversaries. However, that text reveals only one front in the radical left’s war against America. The Cloward/Piven Strategy is another method employed by the radical Left to create and manage crisis. This strategy explains Rahm Emanuel’s ominous statement, “You never want a serious crisis to go to waste.”
The Cloward/Piven Strategy is named after Columbia University sociologists Richard Andrew Cloward and Frances Fox Piven. Their goal is to overthrow capitalism by overwhelming the government bureaucracy with entitlement demands. The created crisis provides the impetus to bring about radical political change.
According to Discover the Networks.org:
Rather than placating the poor with government hand-outs, wrote Cloward and Piven, activists should work to sabotage and destroy the welfare system; the collapse of the welfare state would ignite a political and financial crisis that would rock the nation… [Emphasis added.]
-SNIP- (continued online at link provided above)

Rational Debate
November 25, 2009 3:09 am

Gregg E. (02:13:46) : -SNIP- In other words the bloody incompetent a-holes that somehow get promoted to positions of authority and only manage to screw things up while thinking they’re doing just fine, no matter what everyone around them says.
——–
Long known as “The Peter Principle” e.g., One inevitably gets promoted to the level that is just beyond/above one’s real level of competence.

November 25, 2009 3:15 am

The AGW fraud in one sentence — Pay more taxes to the government, so government scientists can pretend to control the weather.
The bad news, we all know it is pretend science now.

Robinson
November 25, 2009 3:41 am

;
; Apply a VERY ARTIFICAL correction for decline!!
;
yrloc=[1400,findgen(19)*5.+1904]
valadj=[0.,0.,0.,0.,0.,-0.1,-0.25,-0.3,0.,-0.1,0.3,0.8,1.2,1.7,2.5,2.6,2.6,$
2.6,2.6,2.6]*0.75 ; fudge factor
if n_elements(yrloc) ne n_elements(valadj) then message,’Oooops!’
;
yearlyadj=interpol(valadj,yrloc,timey)

Wow, smoking gun? I can hardly believe it! I don’t know Fortran (I’m a C++/C# developer); is yrloc defining a range (1400 -> findgen(19)…) or is it defining a two dimensional array? How is “yearlyadj” subsequently applied to actual temperature data?
Dumb question of the week: what is the theoretical basis for the number series [0.,0.,0.,0.,0.,-0.1,-0.25,-0.3,0.,-0.1,0.3,0.8,1.2,1.7,2.5,2.6,2.6,$
2.6,2.6,2.6] having any significance to the historic temperature record? What does the $ sign mean in fortran (or IDL)?

Ron de Haan
November 25, 2009 3:54 am

The entire scam and all attempts to tax, regulate and limit CO2 emissions are under questions as the science is disputed.
So the only way to tacle this is to demand a total stop of any legislation directed at CO2 until we have got the science right.
For me it’s unbelievable that our political establishment continues to push their agenda when the core of the scientists that produced the scientific reports are suspect of scientific fraud.
That should be the message to EPA.
And the US population should go into the streets in protest.
You can no longer afford to wait for the next elections. This is an acute emergency and it will determine your future.
Your moment is now.

Ron de Haan
November 25, 2009 4:02 am

This is the way to go:
http://algorelied.com/?p=3271
All Americans should support Inofe with his quest for INVESTIGATION.
This is our chance to stop the current process and get the science right.
So go to the Hill and D E M AN D a P U B L I C I N V E S T I G A T I O N of C L I M A T E G A T E.
This is your chance, you don’t get a second one.

Ron de Haan
November 25, 2009 4:06 am

My interview with Al Gore (provides a sobering view behind the madness)
http://factsnotfantasy.blogspot.com/2009/11/my-interview-with-al-gore.html

Ron de Haan
November 25, 2009 4:10 am

Make sure this is not going to happen in the USA.
If we can save the USA, we can also save Australia.
If we lose, we’re all dead meat and the free world will be no more.
http://joannenova.com.au/2009/11/the-cliff-of-political-oblivion-laws-based-on-fraud/

Ron de Haan
November 25, 2009 4:17 am

Round II
It’s the only right conclusion: Demand a Public Investigation of Climate Gate and get the science right. It’s the last chance for a death man’s hanging.
http://algorelied.com/?p=3269

old construction worker
November 25, 2009 4:35 am

Nylo (01:18:39) :
“Sorry, I am a convinced skeptic, but I cannot see how establishing some limit on emissions for cars can be a bad thing to do. A less emitting car is a car that uses less fuel. Upon combustion, it is not only CO2 that you produce, there are other polutants too, real polutants. Less fuel consumption means less polutants in the air. Not to mention that if you use less fuel you are certainly saving money. I would like that law to come true, although I know very well it will do nothing related to saving the world from a supposedly terrible global warming. The reasons are different.’
So you want to regulate a CO2,non toxic gas, to reduce the real polutants?
Make your argument that’s a sound policy

old construction worker
November 25, 2009 4:38 am

Petition the Law Makers to Stop this Scam
They say we’ll loose a little Freedom, what’s the fuss
Freedom is Cheep there’s plenty of it
It was only bought with the others blood
The Stick is broken Open your eyes
The MWP was grafted Upside Down
Stop believing, The IPCC lies
Set may CO2 FREE and STOP insanity
I Will Not go down that California Road to Prosperity
The Question remains, the Question is bound
What side will You be on, LAW MAKER
As the Team goes Down
Will You fight for my Liberties
Or sell your Soul for a piece of gold?
By FIRE ANT

Steve Keohane
November 25, 2009 4:59 am

Nylo (01:18:39) : I find it fascinating every winter when oxygenating compounds are added to the gasoline here to ‘reduce emissions’, and coincidentally I get about 8% fewer miles per gallon. This is true for the past twenty years and 5-6 vehicles. Care to explain how that works?

Patrick Davis
November 25, 2009 5:02 am

OT I guess, but related, as all topics recently are really. Was talking to a friend here at home tonight in Sydney at dinner, previously was “worried” about “climate change” and “carbon pollution” and “something should be done” about it, sort of a “believer” in AGW. I tried to explain to them that the images we see in the MSM of stacks will billowing clouds of, in their opinion CO2, were actually steam. Didn’t wear in the past. Oh hum!
Anyway, seems Australia is commited to an ETS as of today which will cost, an estimated (And we all know about govn’t estimates are *VERY* conservative) $1100 p/a per taxpayer (Thanks KRudd747 and Ms Wrong), and they said to me tonight and I quote;
“We’ve been tricked.”
No sheet Shirlock.
Funny how he’d used the word “trick”-ed. And they are not privvy to Dr. Phil Jones use of the word.
No sheet Shirlock! I warned ya…

Dave D
November 25, 2009 5:04 am

I sent in my message, but I added a lead paragraph and I suggest many readers do the same to add impact and make these seem less “choreographed”, though perhaps I am niave to think anyone reads and consuiders them… Anyways, my lead paragraph, though politely worded discussed the future prospects for the EPA’s longevity if they violate the will of the American Nation they are charged with protection. I suggested 4 neutrally worded questions be sent out in a poll to allow them to understand just what kind of anger and condemnation they may soon be facing if they carry on. Question #2: If the EPA restricts the emmision of CO2 and the economy suffers and workers lose their jobs, should the EPA be closed? I reminded them that the more political they become and the less they maintain their mandated role, the less secure their longevity becomes. 2010 will see a more neutral congress. 2012 will see a new party in the White House. How many of thse making these irrational decision will be OK to retuire before then, my guess is not very many. They are threatening our financial security, they need to atleast consider their own likely fate…

Patrick Davis
November 25, 2009 5:15 am

“Nylo (01:18:39) :
Sorry, I am a convinced skeptic, but I cannot see how establishing some limit on emissions for cars can be a bad thing to do. A less emitting car is a car that uses less fuel.”
That’s not entirely true, as it depends how those emissions are measured. There was a time when fuel was a “premium product”, but it was expensive to make in large volumes.
“Upon combustion, it is not only CO2 that you produce, there are other polutants too, real polutants.”
That is true. S02, NOX, PM10 particulates for diesel fules etc. CO2 however, is not a pollutant.
“Less fuel consumption means less polutants in the air. Not to mention that if you use less fuel you are certainly saving money.”
Oh how wrong you are. You won’t save money, gauranteed. An example for you; In New Zealand there is a Road User Charge (RUC) on fuel. This was “levied” in about 1972, apparently to raise money for road building and maintenace (And some roads in Ethiopia are better than those in NZ). Strangely, and still today, ~50% goes into what is called the “consolidated fund”, meaning pollies pockets in the form of guilt edge pension funds and unlimited taxpayer funded jollies. Then, in the early 90’s the Gummint realised cars were more fuel efficient, ie , more MPG, *LESS* revenue from the RUC. The RUC was raised. Funny that, eh? Get a more effcient car, and pay more tax.
“I would like that law to come true, although I know very well it will do nothing related to saving the world from a supposedly terrible global warming.”
What warming (Outside normal variability and CRU/IPCC computer trash)?
You need to look less at your TV and look more into books.

November 25, 2009 5:17 am

With regards to the code, let me see if I’m getting this right. They have a set of values – tree ring widths, going back 1000 years. They look at the last 120 years to see if there is a correlation with measured temps. They find one between 1881 – 1924. 1944 also happens to correlate with the tree ring width for that year, but not the period between 1924 – 1944, and not the period after 1944. So they truncate the dataset of trees down until they find twelve that show a rising trend, but even then it still doesn’t correlate with measured temps.
So they add a fudge factor to get them over this problem, with the added benefit of being able to adjust it to show more or less, according to their needs.
For all their education, that has got to be one of the ugliest hacks I’ve ever seen. No wonder they wouldn’t release the data. Treemometers really don’t make good thermometers.

George S.
November 25, 2009 5:24 am

Nylo (01:18:39) :
“Sorry, I am a convinced skeptic, but I cannot see how establishing some limit on emissions for cars can be a bad thing to do. A less emitting car is a car that uses less fuel. Upon combustion, it is not only CO2 that you produce, there are other polutants too, real polutants. Less fuel consumption means less polutants in the air…”
Somehow you see causality where I don’t believe it necessarily exists. Lower emissions don’t reduce fuel consumption. In fact, I suspect emissions restrictions cause fuel consumption to increase.
That notwithstanding, our vehicles emit VERY little pollution when compared to cars from 20-30 years ago. I remember US cities enveloped in yellow-brown haze and brown smoke pouring out of tunnels. By the way, your limits on emissions show up in the form of catalytic converters. In fact, I have to have my cars tested by next month to ensure they meet some bureaucrat’s measure of acceptable emissions.
Government intervention in the free market is a losing proposition. However, I’ll grant them some leeway in the areas of safety (i.e. seat belts). [even safety can be regulated in the free market…Saab and Volvo success due to their attention to crach protection] Restrictions such as traffic laws should be the purview of state govts – nod feds.
EPA should go the way of the do-do.

George S.
November 25, 2009 5:34 am

Uh, that should read “…crash protection…”
haha, crach!

pyromancer76
November 25, 2009 5:50 am

Nylo (01:18:39) :
“Sorry, I am a convinced skeptic, but I cannot see how establishing some limit on emissions for cars can be a bad thing to do. A less emitting car is a car that uses less fuel. Upon combustion, it is not only CO2 that you produce, there are other polutants too, real polutants. Less fuel consumption means less polutants in the air.”
Nylo, sorry, but yours is just about the stupidest comment anyone can make. People like you are the reason that CO2 has been demonized — your ridiculous collapse of logic disenables all scientific thinking. If you want to control the pollutants, then control them; don’t falsely identify a non-pollutant to do your work for you. “Less fuel consumption means less pollutants in the air?” Well, less fuel consumption also means that less and less gets done and we have fewer and fewer resources– declining industry, declining travel, declining living conditions, etc.
If you want to put your passion and commitment to positive use (instead of the evil your position enables), support abundant fuel use of the most economic kind — with pollution controls (yes, clean coal is still messy, but so much less so than in the past) — and let us continue to make technological progress. As soon as it is financially feasible and competitive, lower (or different) fuel-using cars and trucks will be “invented”. Our history from the 19th century proves this to be so. When we become affluent, we clean up things — because we have the resources to do so!!! You have the argument bass-ackward.
Also, listen to Dr. Pielke. It’is land-use change (human-caused!) that is the greatest cause of “climate change” in a variety of micro-climates and regions. When land is stripped of its natural resources and natural functions, we create problems far greater than that of the pollution of fuel use. Please wake up to your stupidity.