EPA power-plant rule: comments close October 16

clip_image002By Christopher Monckton of Brenchley

The EPA is going through the motions of public consultation on its proposed power-grab rule for reducing CO2 emissions from electricity generating plants.

It has set a closing date of October 16 for submissions.

To get the proposed rule, with instructions on how to comment, go to Regulations.gov

http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2013-0602-0001

Don’t be late with your comments. The usual suspects will send in truck-loads of nonsensical, near-identical submissions. As many sensible ones as possible from the skeptical side of the case would be helpful.

Give them science. Give them data. Above all, give them a clear indication that this proposed rule will threaten the EPA’s own continued existence if it is persisted in. The GOP, which already has little patience with the EPA, will move for its outright abolition – and good riddance.

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90 thoughts on “EPA power-plant rule: comments close October 16

  1. Waste of time. Comments will have no impact. ePA has its marching orders, and this process is a mere formalism no different than the comments process to the prerequisite endangerment finding was. Better to join the number of states suing EPA since last week over the existing plant proposed standards, on grounds EPA does not have any statutory authority and states havenstandingmdespite the rule being non-final since they are tasked withnpreparing for implementation, somare harmed now.
    For the proposed new plant standards, there may not be standing until after rules are final. The legal attack is also different, hinging on past court interpretations of ‘adequately demonstrated’ technology. The better move is at the ballot box, where a sufficient reversal of the Senate can lead to simple amendment of the CAA to stop the EPA over reach.

  2. This is a genuine public service performed by Christopher Monckton. The link to the EPA comments is direct and simple. The tally given is about 31 thousand comments so far.
    IMHO, one should not neglect to make it clear that you would support any movement to abolish the EPA if it persists in its ill advised and misinformed war against the public welfare.

  3. The incestuous relationship of the Obama Administration and the EPA in a war on fossil fuels. And they dont give a dam that it will cripple the US, Double power costs to the general public and triple those costs to industry (who pass that cost on to the consumer). And all for a trace gas they have no proof of its ability to do what it is they claim by their FAILED MODELS.
    Reality shows CO2 relationship as 1 to 0.4 deg C per doubling and even that estimate is high by empirical evidence.
    Long past time to neuter the EPA and either severely reduce its roll and power or outright dismantle it.

  4. The WV Attorney General’s office has, in the past, been accused of being ‘sue happy’…but in this case, I’m glad to see it’s leading the charge against this insane rule and blatant overreach of executive branch authority.

  5. profitup10 says:
    August 9, 2014 at 10:31 am
    WOW did the EPA pull a lot of numbers out of the air? Check the dollars assigned to climate change etc . . no basis in facts.
    Read this from EPA – does anyone believe these numbers? I think not they are just pulled out of the air.
    http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2013-0602-0001
    ====================================
    Those numbers look like a hodge-podge of alarmist crap which have been debunked many times. Many are outright lies and others are major factual distortions. Exactly what i have come to expect from the agenda driven alarmists and propaganda people of the EPA.
    How many of the faithful will eat this pile of crap whole and not think twice? This shows how totally unhinged and desperate these people are to keep their control and power grab alive.

  6. One of the things that bothers me about the EPA and other regulatory agencies is that they both create the rules and enforce them. That’s more power than is allowed to the Federal Government under the Constitution. It violates the basic concept of the Separation of Powers that our legal system was founded on. On top of that, regulations are laws in all but name, and all laws are constitutionally required to be created, and passed by Congress, then signed in by the Executive.
    Regulatory agencies are an end run around the legal process and if you are targeted by them, you have no real recourse. You simply must obey and pay whatever fee they decide to blackmail you with.

  7. Thanks for the tip. I posted this comment:
    Comment:
    The key assumption in this rule is that man-made Carbon Dioxide is harmful to the environment by altering our climate. I do not think this is proven. The key elements of the debate on man-made catastrophic climate change are actually pretty simple. Obviously, climate changes and it is warmer than it was 150 years ago, so these facts are not in dispute. It is the “man-made” and the supposed impending catastrophe that are controversial.
    Now, if we were to double the amount of CO2 in the atmosphere from the current 400 PPM (0.04%) to 800 PPM physics and chemistry would predict that the atmospheric temperature would increase a trivial 0.75 degrees C. The climate alarmists have used global circulation models (GCM’s) with a climate sensitivity factor that increases this to three or four degrees C by assuming positive feedbacks. These models generally assume that as CO2 goes up, water vapor will increase and since water vapor is a much stronger greenhouse gas than CO2 they speculate that temperature will spiral out of control with catastrophic effects. That is pretty much their case.
    The problems with this are twofold. First there are no measurements to support the idea that water vapor will increase with CO2. In fact, the models suggest the highest rate of warming should be in the tropics because most water vapor is there and most heat enters the atmosphere there. But no significant warming has occurred in the tropics (or in Antarctica for that matter), warming has been almost entirely in the northern Northern Hemisphere and especially in the Arctic. Further, if more water is held in the atmosphere wouldn’t we get more clouds? Will the clouds make us warmer or cooler? No one knows, clouds are not in the GCM’s. Second, the GCM’s have not been successful in predicting anything yet. Observations have shown no increase in global temperature since 1998, but the models predicted an increase. The proportion of CO2 in the atmosphere has increased, why no increase in temperature?
    We need to remember that man’s burning of fossil fuels contributes only 8% of the CO2 that goes into the atmosphere; respiration, microbial activity, volcanism, ocean outgassing, etc. provide the rest. We also need to remember that the average CO2 in the atmosphere after the dinosaurs and until the ice age (which we are still in) is 800 ppm. Atmospheric CO2 only decreased to 300 PPM (and perhaps less) due to the ice age. The article noted below provides actual evidence (not a computer model) that the additional climate sensitivity due to doubling CO2 to 800 ppm will increase the average temperature 1.093 degrees C. A trivial amount and a fraction of what the IPCC circulation models predict. This makes much more sense and is in line with what has been seen in the Earth’s history. If this article stands the test of time, it kills the entire alarmist argument. Some have said that computing or measuring climate sensitivity to CO2 is a fool’s errand and perhaps this is so. But, either way the alarmist argument is destroyed. It is far from certain that climate change is a problem or even unusual.
    http://wattsupwiththat.com/2014/07/23/new-paper-finds-transient-climate-sensitivity-to-doubled-co2-levels-is-only-about-1c/#more-113314
    Other references (Princeton Professor William Happer and MIT Professor Richard Lindzen):
    http://live.wsj.com/video/opinion-climate-change-crack-up/B951E1BE-01A3-4F92-B871-A4AB9B171419.html#!B951E1BE-01A3-4F92-B871-A4AB9B171419
    http://online.wsj.com/news/articles/SB10001424052748703939404574567423917025400
    Dr. Roy Spencer
    http://www.drroyspencer.com/global-warming-natural-or-manmade/
    McKitrick and Vogelsang, 2014
    http://climateaudit.org/2014/07/24/new-paper-by-mckitrick-and-vogelsang-comparing-models-and-observations-in-the-tropical-troposphere/

  8. Last October I addressed an EPA hearing on proposed regulation of emissions from coal burning power plants. During my 3 minutes, I testified that there was no scientific or logical basis for regulation. In support, I provided the URL of a peer-reviewed article. Sad to say, of the 30 or so others giving testimony all supported regulation.

  9. The first principle of government is government cannot be too big to do the work of the people, so any solution requires a built-in opportunity for expansion. This requires the solution solve nothing so that the entity needn’t fear obsolescence, have a clear path to growth through increased responsibility (think EPA) and to appeal to people who self-identify as victims of the problem that won’t be solved. Nothing will turn out the victims like the promise of government largesse and the scale of that group is seen by the government as themselves being successful at doing the work of the people worthy of mention in a presidential press conference. Remember those? Yes it is a circular process.

  10. Mark that is not quite correct – they count the remarks and that is why this was delayed until October. So, please all send a email protest – America cannot afford raising utility cost by 4 or more times over ten years. Old and poor will die without A/C in heat and freeze without heat in winter. It could cause up to a million deaths over 10 years.

  11. And everything they propose is founded on their discredited “Endangerment Finding”…
    So everything they want to make us do is founded on pseudoscience..
    It is time to flat outlaw all regulatory powers being held in the same persons. The ability to act as Judge, Jury, and executioner needs to be removed and the judicial due process placed. The EPA, IRS and any other agency should not have the right to arbitrarily take what they want and this would help eliminate the abuses we see today.

  12. profitup10 says:
    August 9, 2014 at 11:14 am
    Mark that is not quite correct – they count the remarks and that is why this was delayed until October. So, please all send a email protest – America cannot afford raising utility cost by 4 or more times over ten years. Old and poor will die without A/C in heat and freeze without heat in winter. It could cause up to a million deaths over 10 years.
    ===============================================
    Barrack Obama, James Holdren, Eric Holder, Hillary Clinton, and many other elitist socialists view population reduction as a must. This is just a bonus by product of their control plan. Eugenics has always been the plan of many in the UN Agenda 21 realm. Every one of those people I named are avid UN Agenda 21 believers. Sadly they view this as a necessity to population control.

  13. Here is a copy of my submission….
    The EPA would have us believe that CO2 is pollution and the increase from 280ppm to 400ppm has been/will be a disaster for us. Consider these facts:
    1) At 200ppm CO2, plant growth is severely stunted, including crop plants. At 150ppm CO2 most plants start dying off. I would think that is a good thing we have increased the CO2 to be safely above the catastrophically low 200ppm levels.
    2) Green-house growers have shown that 1500ppm is optimum for growing vegetables and fruits. They grow much faster, bigger and require less water per pound of produce.
    3) The earth is a mere 1.5C warmer now than it was during the LIA, a time of much misery, starvation due to cold weather related crop failures, and death. The earth has not warmed at all in the past 15+ yrs.
    4) Since CO2 has gone from 300ppm to 400ppm, the earth has become 11% greener (as shown by published CSIRO Australia research) and crop yields have increased enormously.
    http://www.csiro.au/Portals/Media/Deserts-greening-from-rising-CO2.aspx
    Obviously, CO2 at these levels are NOT pollution and in fact have clearly been beneficial. Thus the rules the EPA are proposing to control CO2 emissions from power plants will do nothing but HARM to Americans and the economy, driving up the cost of energy and everything else that takes energy to make or transport. These proposed rules clearly should NOT be implemented.

  14. Rud Istvan says it is a waste of time. While I do agree that it is a total waste of time in regards to what the EPA will do right now, it may not be a waste of time when it comes to being able to repeal these regulations at some point in the near future if we can get back the senate. Having a large number of responses that the Good Guys can use to show that EPA willfully neglected in order to force through their ill-conceived regulations will be handy.

  15. From post:

    To get the proposed rule, with instructions on how to comment, go to Regulations.gov
    http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OAR-2013-0602-0001

    Right-click, “Open Link in New Private Window”:
    http://www.regulations.gov/?_escaped_fragment_=documentDetail;D%3DEPA-HQ-OAR-2013-0602-0001#!documentDetail;D=EPA-HQ-OAR-2013-0602-0001
    Get nothing.
    Right-click, “Open Link in New Window”:
    http://www.regulations.gov/?_escaped_fragment_=documentDetail;D%3DEPA-HQ-OAR-2013-0602-0001#!documentDetail;D=EPA-HQ-OAR-2013-0602-0001
    Still get nothing.
    Apparently they need Javascript on (I have NoScript) and granting them the ability to do whatever-they-want (like installing unique identifies and tracking code other than mere cookies) before we peons are even allowed to glance at the proposed rule, let alone comment.
    Well, that was a waste. You know, I was just now going to say they could kiss my hairy butt before I’ll jump through hoops for a public document that should be free and open access with zero restrictions, but given those DC unelected bureaucrats are used to frequently kissing butt (and other body parts), I’m afraid of what I could catch!

  16. The proposed rule for emission guidelines for states is totally unwarranted.
    Carbon dioxide is not a pollutant but vital plant food. The EPA has no valid scientific finding to support this rule, the effects of which will be highly detrimental to the economy and environment of the USA.
    Sincerely, Andy Tillman, Bend, Oregon

  17. By the way, it took me less than 5 minutes to make my submission in case you are wondering how long it takes. Also, feel free to use part or all of my submission as you see fit without and attribution to me what-so-ever.

  18. I won’t give advice to a foreign government but I would advise US citizens to consider using the words of the IPCC to counter the proposal of the EPA. The EPA consider the IPCC to be authoritative.
    The IPCC state clearly that poverty is the worse problem (A href= “https://ipcc-wg2.gov/AR5/images/uploads/IPCC_WG2AR5_SPM_Approved.pdf”>see page 7)
    I quote;

    Differences in vulnerability and exposure arise from non-climatic factors and from multidimensional inequalities often produced by uneven development processes (very high confidence). These differences shape differential risks from climate change. See Figure
    SPM.1. People who are socially, economically, culturally, politically, institutionally, or otherwise marginalized are especially vulnerable to climate change and also to some adaptation and mitigation responses (medium evidence, high agreement). This heightened vulnerability is
    rarely due to a single cause. Rather, it is the product of intersecting social processes that result in inequalities in socioeconomic status and income, as well as in exposure. Such social processes
    include, for example, discrimination on the basis of gender, class, ethnicity, age, and (dis)ability.13

    And the cheapest energy is part of the answer, in my opinion.
    The EPA would need to explain why it isn’t or why the IPCC are untrustworthy.

  19. Mods: I posted a comment that has disappeared. Perhaps it was because I am not a US citizen and so am not allowed to comment on your domestic politics? That would be fair enough.
    But my comment was unusually well-researched, for me, and I would greatly appreciate if you could fish it out of the aether.
    In my own opinion, I think it helps the discussion.

  20. The Republican response should be. “The EPA rule will cost the economy $XX billion. We are taking that amount out of the EPA budget.”

  21. Hey Tories, didn’t America fight a war over 200 years ago to free ourselves from the political intrusion of British Lords? I

  22. “Four public hearings will be convened. ……The hearings will provide interested parties the opportunity to present data, views or arguments concerning the proposed action.”
    A good showing at these hearings would probably be more impactful. Too bad we’re not really well funded and well organized.

  23. Trying again
    I won’t give advice to a foreign government but I would advise US citizens to consider using the words of the IPCC to counter the proposal of the EPA. The EPA consider the IPCC to be authoritative.
    The IPCC state clearly that poverty is the worse problem (A href= “https://ipcc-wg2.gov/AR5/images/uploads/IPCC_WG2AR5_SPM_Approved.pdf”>see page 7)
    I quote;

    Differences in vulnerability and exposure arise from non-climatic factors and from multidimensional inequalities often produced by uneven development processes (very high confidence). These differences shape differential risks from climate change. See Figure
    SPM.1. People who are socially, economically, culturally, politically, institutionally, or otherwise marginalized are especially vulnerable to climate change and also to some adaptation and mitigation responses (medium evidence, high agreement). This heightened vulnerability is
    rarely due to a single cause. Rather, it is the product of intersecting social processes that result in inequalities in socioeconomic status and income, as well as in exposure. Such social processes
    include, for example, discrimination on the basis of gender, class, ethnicity, age, and (dis)ability.13

    And the cheapest energy is part of the answer, in my opinion.
    The EPA would need to explain why it isn’t or why the IPCC are untrustworthy.

  24. Show me the proof the EPA will even look at my comment.
    This EPA laughs off Congressional subpoenas, points to hard drive crashes as reasons for missing emails. Which is willfully and openly admitting they are in violation of federal law concerning records retention, with archive management so slipshod that corporations would get sued and prosecuted for the same.
    So point me to the rule, regulation, or law that says they MUST at least glance at my comment, then prove to me that this is something they won’t also ignore and never do. And also prove my comment, along with all the other ones that don’t fit the EPA agenda, won’t be something else that got lost in a hard drive crash, or filed away on a misplaced tape cartridge.
    Although we should all know what will happen, given the volume of comments they’ll simply parse them with a program and bin together the chunks.
    While I support the EPA’s mandate… – Approves Regulation
    Just because Congress gave you yahoos the right to… – Approves Regulation
    Perhaps [they] can get some help on the sorting from John Cook.

    • Just visit the EPA.gov site it is all there – rules to review regulations and how they are to be operated. Do they do all that is required – your guess is as good as mine? The counted and delayed the current Air quality under consideration. So they can count.

  25. Ok…I’m generally an optimist, but I’m also a realist.
    The only way, and I mean ONLY way there will be any impact on the EPA is in the upcoming elections.
    Facts and science mean nothing to these people. Control means everything to these people.
    They, like pretty much every government institution in this country (and elsewhere), seek only to expand control, period.
    If there’s a backlash in 2014/2016, then, and only then, will the EPA be reigned in, and it will take years to undo the damage that’s been done.
    Jim

  26. Heads Up on what is intended using the words of the EPA Secretary. Just Energy. The taxpayer funded community organizations I track sent me an invite to go with them to the first day of hearings in Atlanta and to join the March for Social and Economic Justice to go along with it. Children were to make pinwheels to simulate wind turbines. Lunch was to also be provided by the way.
    This is what Green Energy is really all about. It’s yet another rationale for government planning of the economy. Van Jones said it explicitly and how it fit with CPUSA. His words. Take a look at the Emerald Cities Collaborative if you are not familiar with it. http://emeraldcities.org/

  27. Just posted the following to EPA:
    I am a biomedical scientist, funded by the extremely competitive processes used by USDA, EPA, and NIH for more than 25 years. I have published more than 115 peer-reviewed publications. I currently serve as a member of an NIH study section, which reviews grant applications in the field of immunology, and I have served in elected positions in scientific societies and have served on the editorial boards of 7 journals in the fields of toxicology and immunology (including current service on the two top journals in toxicology). I have received more than $20,000,000 of highly competitive funding from various biomedical funding agencies. I am currently a department head and professor and Principle Investigator of a $10,000,000 center grant. I am telling you all of these things only to indicate that I actually do know something about science. Among my peer reviewed publications are several that focus on mathematical modeling of complex systems, including a machine-learning study that is completely unique in the analysis of immunological and toxicological data. Hopefully this suggests I actually know something about mathematical modeling of complex systems.
    I first became very interested in climate science when I read news stories and began to follow the scientific literature and a few blogs after the “Climategate” emails and documents were released. My assessment of this field including numerous highly publicized peer-reviewed publications is that Climate science is deeply flawed and has succumbed to group-think and to motivations related to research funding. There are many, many, many well established scientific observations, which demonstrate that the concerns regarding catastrophic anthropogenic global warming (CAGW) are vastly overstated and in any other field of science (including mine) would not be given serious consideration. Let’s consider that in spite of climate models that predict rapid increases in mean global temperature, there have been no such increases in the last 17 years (approximately), according to both thermometer based and satellite data. This was not predicted by the climate models that have been used to predict dire consequences due to climate change, and there is now a lively debate (as there should be) as to why this has occurred. This is exactly how science should work. Unfortunately, the IPCC and its political supporters have decided that in their summary for policy makers that they would use statements of high confidence of dire climate consequences based on NO REAL DATA. As I mentioned before, I am very experienced in analyzing data and have recently served as a consultant for the EPA in environmental chemical risk assessment (presumably because they thought I was qualified), and I can tell you unequivocally that my assessment of the available climate data indicates that there is absolutely nothing that can be asserted with high confidence with regard to the future or the world climate system or the effects of human activity on that system. Perhaps you do not put much confidence in my opinion, because I am not a climate expert. If so, I would encourage you to carefully review the congressional testimony of Dr. John Christy (U. Alabama Huntsville), Dr. Judith Curry (Georgia Tech), Dr. Roy Spencer (U Alabama Huntsville), and Dr. Richard Lindzen (MIT) which provide conclusive evidence that CAGW is NOT supported by the best evidence currently available and that facts such as the record levels of global sea ice in Antarctica, the absence of global temperature increases for the last 17 years, the existence of much higher carbon dioxide levels than current ones in the distant past when temperatures were lower than or comparable to the present. Current climate scientists, in my opinion, have fallen into a combination of groupthink and of self-censorship designed to continue CAGW as a world-wide threat to enhance government funding of research that supports this theme.
    To his great credit, Ph.D biochemist Michael Crichton (better know as a novelist), identified the inconsistencies in the evidence in climate science leading to the CAGW hypothesis well before the revelations of Climategate, which demonstrated data manipulation, peer review manipulation, and (in my opinion) blatant scientific misconduct. He defended his doubts in the appendix of his last novel, State of Fear.
    There are two occurrences that were most important in convincing me about serious problems in global climate science. Many climate scientists defended the “hide the decline” graphs used by Mann and Jones and others to convince people that current climate change is unprecedented. These graphs are scientifically indefensible. Second, a paper in PNAS (August 10, 2010 vol. 107 no. 32 p. 14257–14262), which is TOTAL speculation and would never be publishable in a biomedical journal. So, it is strange that EPA would try to regulate CO2, which is absolutely essential to life and enhances plant growth.

  28. Ref: EPA-HQ-OAR-2013-0602
    I oppose any unnecessary scheme to outlaw coal-burning power plants whose effluents are sufficiently clean. This scheme could unconsciously wreak havoc with our electric power distribution grids. It can result in rotating blackouts that create a huge burden on industry and commerce with disastrous economic consequences. Major impacts on jobs, earnings and safety can result.
    This scheme is particularly pernicious if it is designed to curb carbon dioxide emissions because of false claims by radical environmentalists that this is needed to avoid global warming, rising sea levels and other assorted horrors. The computer programs that are doctored by junk science to predict catastrophe have been proven erroneous because their predictions are refuted by actual true temperature recorded data.
    In fact there has been no statistical global warming for at least 17 years, although Earth is still slowly recovering from the Little Ice Age of around 300 years ago when Londoners went ice-skating across the Thames River. In fact, we may be entering a period of global cooling as indicated by the dimension and shape of current the solar sunspot cycle which resemble the those recorded during the Little Ice Age.
    Copied and pasted below is a chart from the University of Alabama at Huntsville global temperature since 1979 based on measurements from satellites that cover virtually the entire globe. The true increase is around three tenths of a degree Celsius.
    UAH Global Temperature Update for July, 2014: +0.31 deg. C
    August 5th, 2014
    The Version 5.6 global average lower tropospheric temperature (LT) anomaly for July, 2014 is +0.31 deg. C, unchanged from June (click for full size version):
    UAH_LT_1979_thru_July_2014_v5
    In summary, I recommend rejection of the proposed changes in EPA-HQ-OAR-0602
    Respectfully submitted,
    M. Robert Paglee. P.E.(Ret.),

  29. From profitup10 on August 9, 2014 at 12:47 pm:

    (…) The counted and delayed the current Air quality under consideration. So they can count.

    They heard the howls of the corporations that donate big money to the campaigns, PAC’s, and “charitable causes” of the elected politicians. Difference.
    Now Obama is a lame duck crafting a legacy. He needs something other than his twin sterling successes of foreign policy and Obamacare, and doesn’t need campaign funds. “Champion of the global environment” is a good title. Even the EPA bureaucrats can guess how the congressional midterm elections will go, and lay odds on the party of the next president.
    Why wouldn’t the EPA “go for broke” and churn out all the “good progress” they can while they still can?

    • Here is what is driving the E=GREEN movement – not climate now is it?
      http://emeraldcities.org/about/strategies
      STRATEGIES
      shapes icon
      Collaborative Model
      All of our efforts involve a diverse cadre of skilled leaders in government, labor, community, and business, who have all subscribed to high-road community sustainability, around energy efficiency and beyond. We identify the needs of our Emerald Cities & meet those needs with our partnerships. The collaboration allows us to build accessible social capital within our communities, promote shared learning and action, bridge historical community-labor-policy divides, and produce broad-based, sustainable outcomes. Local councils must engage community groups including social justice advocates, development intermediaries, neighborhood associations, religious organizations, and social service providers, with particular representation of low-income and minority populations.We actively leverage the engagement of our Board organizations, and utilize technology to keep everyone connected.
      construction icon
      Large-Scale Retrofits
      Emerald Cities Collaborative targets energy efficiency retrofit work within the large commercial and MUSH+ markets – Municipal, University, Schools, and Hospitals, plus multi-family and affordable housing – in each Emerald City. Philanthropic or business partners such as private developers, signatory contractors, Workforce Investment Boards, community development finance institutions, or green investors, as well as respected leaders within the civic sector, are required in each city. The mayor of each Emerald City must publicly agree to comprehensively and equitably retrofit the city’s building stock within ten years, and agree to work with Emerald Cities partners to develop the plan.
      briefcase iconCommunity & Workforce Development
      We go beyond consumer demand and aim to change community attitudes and behaviors around energy efficiency. We make sure that local residents, particularly those historically excluded such as low-income residents, immigrants, and communities of color, directly benefit from the energy efficiency work being done in their communities and are included in the development of their region’s new green economy. We employ updated training and educational pathways and include community workforce agreements and labor standards in all of our projects to ensure local hire and high wages. The Building and Construction Trades Council and its affiliated local unions must formally endorse Emerald Cities efforts and goals with a standard resolution and agree to collaborate with community partners, civic leadership, and city government.

  30. How can there be any discussion regarding changes in CO2 affecting earth atmospheric temperature? There is no historical evidence that it has been significant. Radiation from the surface either from earth systems or from solar absorption heats the atmosphere. Assuming there to be only one photon that is to heat the atmosphere translates that there are 1 CO2 for 250, 000 other molecules for which to “energize”. Then there is the H2O content. CO2 is irrelevant in atmospheric heat.

  31. The benefits the EPA cites are largely a result of double counting. There are health risks associated with coal, and EPA regulations were put in place to cleanup coal. Now the EPA is using the same benefits for CO2. In private industry if you double count, it is called fraud.

  32. FWIW, Crichton was an MD not a PhD, and yes, the EPA does read it all and comment, although they will put similar comments into a basket and provide a single answer

    In light of the very large number of comments received and the significant overlap between many comments, this document does not respond to each comment individually. Rather, EPA summarized and provided a single response to each significant argument, assertion, and question contained within the totality of comments. Within each comment summary, EPA provides in parentheses one or more lists of Docket ID numbers for commenters who raised particular issues; however, these lists are not meant to be exhaustive and EPA does not individually identify each and every commenter who made a certain point in all instances, particularly in cases where multiple commenters expressed essentially identical arguments.

    • Eli Rabett:
      Though the EPA is required by law to respond to all comments it doesn’t necessarily follow this law. it appears to be able to violate this law with impunity. I learned that this was so when I responded to the EPA’s request for public comment on the proposed “endangerment” finding. After this finding was made, the EPA published a document in which it claimed to respond to all comments. When I read this document I found that it did not respond to my comment. When I wrote to EPA administrator Jackson to inform her of same, she failed to respond to my letter.
      I have had similar experiences with a couple of other federal agencies who have been granted the power to make regulations. When a scientifically or logically based case is made by a citizen against a regulation, this case has no impact on the legislative outcome. It is political power that determines this outcome.
      In one case, I spotted a fallacy in an argument underlying a regulation and reported it to the pertinent agency. They ignored me. I published a peer reviewed article proving my case. They continued to ignore me. They ignore me still, 29 years later.

  33. From the1pag on August 9, 2014 at 1:12 pm:

    I oppose any unnecessary scheme to outlaw coal-burning power plants whose effluents are sufficiently clean.

    Analysis: There is no such scheme, plants can clean up their emissions per federal law and continue operating, if they are already sufficiently clean per EPA regulations then no actions need be taken.

    This scheme could unconsciously wreak havoc with our electric power distribution grids.

    Analysis: The stability of the electricity distribution grids is beyond EPA’s Congressionally-authorized mandate.

    It can result in rotating blackouts that create a huge burden on industry and commerce with disastrous economic consequences.

    Analysis: The adequacy and continuity of the electricity supply is beyond EPA’s Congressionally-authorized mandate.

    Major impacts on jobs, earnings and safety can result.

    Analysis: Availability and adequacy of jobs and earnings are beyond EPA’s Congressionally-authorized mandate. Safety is important to the EPA, and a cleaner environment is better for the health and safety of all.
    Ah heck, the entire first paragraph was nothing but garbage. Why would you think they would think any of the rest of it was worth reading?

    This scheme is particularly pernicious if it is designed to curb carbon dioxide emissions because of false claims by radical environmentalists that this is needed to avoid global warming, rising sea levels and other assorted horrors.

    Analysis: Domestic Extremism detected, anti-establishment. Sending message with tracking metadata to Homeland Security for review.

  34. It is hard to even think straight with all the noise, but when your neighbor has a power washer, it would appear that everything needs cleaning.

  35. Dear Sir Christopher,
    Of some note on the current condition in Washington D.C..
    “Gone Missing in Action”
    IRS e-mail, EPA e-mails, Justice Dept. e-mails, Border Patrol e-mails, ATF guns even go missing.
    Very real chance some very high percentage of our sides e-mails will go missing, like 90% or so.
    The EPA as you know is about 90% Greenpeace, Earth First members now.
    Big issue some think.

  36. At what point does a state just say, “No.” and dare the feds to come in and shut down power plants?

  37. @kadaka (KD Knoebel) 1:51 pm
    Analysis: The stability of the electricity distribution grids is beyond EPA’s Congressionally-authorized mandate.
    A good bureaucratic retort.
    It opens up another argument. What would be the environmental impact to this country of a major, regional multi-day electrical-grid blackout? These “Barack-outs” from an overstressed coal-poor generation capacity will most likely happen during heat waves or polar vortex cold snaps. How many people will die of heat-stroke from lack of A/C? How many people die of cold because of lack of heat. How many lives will be lost in these Barack-outs? How many will have death certificates with cause of death be thermal in nature: hypothermia, hyperthermia, carbon monoxide poisoning from trying to stay warm?
    May I remind you, the EPA can point to no death certificates that link as a direct cause carbon pollution, mercury from coal fired plants, or other coal-fired heavy metals. Their statistics are all done using, wait-for-it, models. But once the coal plants are shut down, the incidents, severity, and casualties of blackouts is guaranteed to rise. And THESE deaths we can single out.

  38. President Obama and Sen. Barbara h nBoxer have publicly declared co2 to be a known pollutant. Yet they allow even the youngest members of our society to openly purchase pollutant (co2) infused water, soft drinks and for the adults there is beer and sparkling wine.
    For the president and senate to allow major corporations to infuse a known Pollutant into our consumables is inexcusable. Coca Cola, Pepsi, Miller, Coors, Budweiser as well as the smaller drink makers will be forced to lay off the majority of their employees. Mass recalls will follow and the inevitable class action suits will tie them up in Cofk for years.
    If our esteemed representatives do not take immediate action to ban these drinks they will be guilty of misfeasance.
    Millions can play that game.

  39. In the video attached to Dr. Roy Spencer’s Keynote Speech at #ICCC9 (WUWT July 14, 2014), there is a 20 min talk by Jay Lehr, a groundwater hydrologist who was in at the beginning of the EPA. I wrote a timestamped transcript in the comments. Some of the best bits:

    (Times are mm:ss in the video in the head post.)
    32:40 – The primary force we battle is the US EPA. I Don’t think we can reduce the power of EPA, We have to Replace the US EPA. I have a plan.
    …. 35:15 – There is no one with a greater right to propose a plan to replace EPA in Washington than I. For I played the greatest role in America to establish it. 1968 I helped the Bureau of Water Hygiene into something stronger. No regrets for what I started, but I’ve been doing penance for 40 years.
    37:10 – Safety net of regulations. Clean Water, Clean Air, Mining, … seven laws. “We did nothing in the 70s that was NOT effective.” “I would argue since 1980 there has not been a single” law, reg, “that has had any value.” Superfund was first of these disasters. Endangered Species Act, too.
    38:30 – My Plan: Replace Washington EPA with Committee of the Whole of the 50 States — In Topeka, Kansas – the geographic center of the USA. “Government is best when it is local.”
    39:50 – Phase out US EPA (Wash DC) over 5 years. There are 50 state agencies. Each State sends 3 delegates. They will elect a Chairman for 3 years, no more.
    41:00 – “No one in this room could name for me the 14 offices of US EPA.” Phase out as follows:
    … The states will get $20 million/year/state. Budget for EPA is $8.2 billion. New plan: $1 Billion goes to states, $1 goes to Topeka HQ and research. $6.2 billion is saved.
    42:30 – First two offices to go: Office of Indian Affairs. And Office of Indian Environment. Move them to Bureau of Indian Affairs, with 1/2 of budget.
    43;10 – Year 2: Move offices of policy, admin, enforcement.
    Year 3: Move Air and Radiation, Solid Waste
    Year 4: Move Water, Chemical Contamination
    Year 5: Move Chief Council, CFO, Env. Information Officer, Administrator.
    A very smooth transitions to shut down Washington and Regional Offices. The States should be thrilled. They will have a say in everything and more money.
    44:45 – Over these 5 years, the Committee of the Whole will review every regulation the states are forced to operate by US EPA. They will have the right to revise, eliminate, delegate to States, or advise Congress for changes. Global Warming is about to become the biggest thing EPA has ever done. The States will embrace the phase in. I think Congress will embrace it.
    … 46;30 …. Nobody LIKES EPA. They think we NEED it. The Plan does not eliminate environmental protection. We will lose nothing but 15,000 people and $6 billion in budget.

  40. Stephan Pruett
    Is there any mathematical evidence that climate models can work? I get the feeling from reading about them that the number of ad hoc assumptions and the chaotic systems of nature that are being modeled preclude any possibility of getting one with robust predictive power. So, I ask again:
    is ANY climate model mathematically feasible?

  41. inMAGICn:
    Whether such a model is feasible, depends upon what one means by “climate.” A statistically validated model has already been created that predicts spatially and temporally averaged precipitation over a period of 1 year. “Climate” usually implies an averaging period of 30 years but this is not in the cards because statistically independent observed events are too few by a factor of at least 30. Climatologists have convinced policy makers that they can forecast the climate over long periods through the use of a fallacious argument that dispenses with the need for statistically independent observed events altogether and by overlooking the fact that the resulting models convey no information to a policy maker.

  42. Terry O
    Statistical validation can only carry you so far, as you pointed out. But, do you know of any analysis that would demonstrate that such validation is feasible in the longer time-frame of “climate,” be it 30, 100, or more years?
    Thanks

  43. Stephen Rasey says:
    August 9, 2014 at 2:37 pm
    @kadaka (KD Knoebel) 1:51 pm
    Analysis: The stability of the electricity distribution grids is beyond EPA’s Congressionally-authorized mandate.
    A good bureaucratic retort.
    It opens up another argument. What would be the environmental impact to this country of a major, regional multi-day electrical-grid blackout? These “Barack-outs” from an overstressed coal-poor generation capacity will most likely happen during heat waves or polar vortex cold snaps.
    ——————————————————————————————————————————
    A multi-day blackout would most likely mean a generator or sub-station transformer has melted. Neither of these are kept in ready inventory. I have read somewhere that the US no longer manufactures the transformers; Italy being the source. In any case, if either goes, it will be a lot longer than a few days. Pray for good fuses.

  44. I agree with those who’ve said to “save your ink”. This comment period is just to “check the box”. It will have no effect on the ideologues who run the show (unfortunate that they do). It will have no affect – it’s already a done deal. There is only one solution and that is to vote Republican (even if you have to hold your nose). This radical administration and their Senate cronys (all D), just have to go. Maybe we can, in time, repair the damage. Otherwise, all of us (and especially those less fortunate people they seem to care so much about!), are going to economically suffer big time.

    • ECK:
      I’d amend your position by suggesting that if opponents to the EPA’s policy formed themselves into a pressure group of sufficient size they might well prevail. This has happened in immigration politics where proponents of a limited rate of immigration into the U.S. have formed themselves into the pressure group that calls itself NumbersUSA. Under repeated attempts by both political parties to pass legislation on immigration numbers that is contrary to the interests of most Americans, the members of NumbersUSA have prevailed. Currently, NumbersUSA has 3 million activists who together are able through their phone calls to their members of Congress to shut down the switchboard on Capitol Hill. Recently they defeated legislation that would have granted amnesties to illegal aliens at the expense of American workers.

  45. I think it is reasonable to expect that the EPA will ignore the comments. However, I still think it is important to comment. If they are swamped by common-sense, scientifically valid comments, those comments will constitute an official record of the opposition to this plan. This will serve 2 purposes. It will become a news story (at least in some news outlets), and some of the undecided among the public may be swayed. And it will affect the next congress, by emboldening those who are inclined to rein in the EPA, and nudging fence-sitters in that direction.

  46. James the Elder says:
    August 9, 2014 at 7:09 pm
    A multi-day blackout would most likely mean a generator or sub-station transformer has melted. Neither of these are kept in ready inventory.
    Been there, done that…not fun.
    Oct 29 and onward, 2012…Large chunks of WV were without power, in some areas for weeks (8 days or so, for me…). Granted, it was storm damage, from Sandy (and the 2+ feet of snow over large chunks of the state), but the cause iisn’t as important as the effects…for 3 days NOTHING was open…no stores, no gas stations…NOTHING. Most businesses had no backup power and most stores had no backup refrigeration or anything. The good thing was, most of us had plenty of snow to pack coolers with…but in many areas that melted quickly. And my part of the state was not the worst…there were areas, not too far from me, including one of my wife’s co-workers who didn’t get power back until the end of November, or later!
    And the really bad thing…it was a repeat performance, because in June 2012, large chunks of WV were without power due to a derechio…
    To top it all off, this happened with a power grid fueled by coal and gas. There is a wind farm, a few miles from my house that I can see easily. Neither storm damaged it, but it was offline longer than it took to fix the lines running from it. Damage inspections had to be done and every person who had experience with anything power related was busy elsewhere. Now imagine if the grid were mostly wind…there definitely would have been major damage to at least part of it and with each tower needing to be inspected…
    Power probably would have been back on, from the June storm, the day before Sandy hit.

  47. For those of you that get this far down the comments.
    I can’t comment, not being a US national but I urge those that do to bear in mind that the EPA is knowingly (by their own admission) trying to A. Reduce the temperature to that of the LIA, and B. Reduce the food supply. Both of these are injurious to the American People, as such EPA administrators may be held accountable for future deaths from cold or starvation should they be successful in achieving their stated aims of reducing CO2 and temperature.
    The EPA has totally failed in its duty to account for the possibility of low CO2, if they are forced to account for this they must then simultaneously assess CO2 as an essential atmospheric component (non pollutant) AND a pollutant simultaneously, surely such a oxymoron couldn’t stand even in an American court – at the very least the EPA would be forced to assert a safe range for CO2, this would trigger another round of consultation which would invalidate the endangerment finding.
    Can someone in the US lodge a comment along these lines, ie that of the failure to recognise the threat of LOW CO2

  48. One more point, for those who say it’s useless to comment. The right comments can make a big difference, if you can demonstrate an interpretation where the EPA and it’s administrators may be liable, or give a good argument for unconsitutionallity, or public harm caused by the policy where the government and it’s administrators may end up before a court, or potential treaty violations then your comment as part of the public record can be used by litigators down the track. You are arming those litigators with a potential argument that may end up being used to bring down the regulation. If I were a litigator, I would start by looking for angles in the public commentary.
    For example, my post above shows the way to demostrate that in legislating for lower CO2 the EPA is opening itself up to law suits for cold related events at any time CO2 is decreasing, something quite possible during the solar minimum. I have also showed how the regulation harms the people. EPA are going to create fuel poverty, fuel poverty that will kill American babies. This warning to the EPA can be used by litigators in the future to show that the EPA was forewarned about the ramifications of it’s actions and was callously ignoring the negative outcomes of its policy
    US citizens should comment, focus on how the EPA is harming you by these regulations, talk about grannies and babies dying of EPA induced fuel poverty, talk about harm, unconstitutionality, the harmful effects of low CO2, worry them about the law suits, and give those litigators as much ammunition as you can to win against the EPA.

  49. Based on ““Affordable energy in ample quantities is the lifeblood of the industrial societies and a prerequisite for the economic development of the others.” — John P. Holdren, Science Adviser to President Obama. Published in Science 9 February 2001 ”
    It seems obama and epa are trying to make energy in USA less affordable and less available? USA should rid itself of these social engineering nuts?

  50. “Terry Oldberg says:
    August 9, 2014 at 8:26 pm
    ECK:
    I’d amend your position by suggesting that if opponents to the EPA’s policy formed themselves into a pressure group of sufficient size they might well prevail. This has happened in immigration politics where proponents of a limited rate of immigration into the U.S. have formed themselves into the pressure group that calls itself NumbersUSA. Under repeated attempts by both political parties to pass legislation on immigration numbers that is contrary to the interests of most Americans, the members of NumbersUSA have prevailed. Currently, NumbersUSA has 3 million activists who together are able through their phone calls to their members of Congress to shut down the switchboard on Capitol Hill. Recently they defeated legislation that would have granted amnesties to illegal aliens at the expense of American workers.”
    And yet the borders remain open, plane loads of illegal immigrants being “dumped” in various states.
    Thousands streaming over the borders on a daily basis. Does anyone in this administration care?…sure, because every one of those entering is a democratic vote.
    And they may have defeated that bill, but what was the impact?…there will be another bill, and another, and another one after that until this administration and the democratic party gets what it wants.
    Jim

    • jimmaine:
      The battle over the open borders issue is not yet won but the good guys are now winning most of the skirmishes. If you’ve got the time, please join us.

  51. FWIW, In my opinion, if there are no comments submitted in opposition to their proposal to officially demonise Co2, then it becomes very easy for them to advance their plan saying so. They could claim ”Consensus”, …everyone’s happy.
    I think there are many clever people here with good solid argument, sound supported science and facts, to put the sceptical case across. It may be useful to diversify the arguments as much as possible, so that the EPA can’t just make one sweeping rejection. Reading through the comments here, I find it heartening that there is more passion to fight this than resignation and apathy.
    As Some have suggested, pointing out future litigation, accountability for negative consequences, could make for some very interesting reading.
    I too am outside of this political jurisdiction, but isn’t Lord Monckton a fellow European? How will he make a submission. I would love to read his slaughter of the (not so) innocents. Ultimately, the decisions made by the EPA in the U.S. will have a resounding impact on policy the world over. Like I said, they will officially rubber stamp Co2 as a Pollutant. That won’t be ignored by policy makers everywhere.
    So please, don’t be despondent. It may seem futile and a foregone conclusion already drawn, but at the very least, make it as difficult as possible so that it’s not for the want of trying.
    Regards, Eamon.

  52. For what its worth… the process was simple and my comment is below
    This proposed set of regulations seems to be based on thinking aligned with the NRC
    conclusion quoted within its pages: “Emissions of carbon dioxide from the burning of
    fossil fuels have ushered in a new epoch where human activities will largely
    determine the evolution of Earth’s climate”
    This is simply a theory which has no basis in actual observation. A warming trend
    began about 1820 or so, depending on which data sets are used, and extended in an
    almost a straight line until the late 20th century with only one significant pause in
    the 1950s and 1960s. This warming trend ended in any statistically significant way
    about 17 years ago, and we are now in a period of reduced violent weather, reduced
    droughts, and increasing sea ice extent despite the continuing increase of
    atmospheric CO2.
    CO2 itself has not been shown to have any negative human health effects in current or
    projected atmospheric concentrations.
    And finally, because of huge projected increases in future CO2 output in other
    countries, these proposed regulations will have no significant impact on worldwide
    trends of atmospheric CO2 levels, and thus cannot possibly render any measurable
    benefits to climate, sea levels, or general human health.

  53. The only thing that’ll get EPA’s “attention” are rolling blackouts this coming winter in the DC/NYC megalopolis during a cold wave, and then it’ll only be more BS.

  54. For the possible use of colleagues in responding to the EPA or to other regulatory agencies throughout the world, I present the following list of arguments against regulating CO2 emissions from electric power generating stations:
    1) The EPA’s endangerment finding was illegal under the Daubert standard governing the admissibility of scientific testimony in federal courts because the claims of the climate models were not “scientific” under this standard; in particular, the claims made by the models lacked falsifiability.
    2) With possible rare exceptions, climate models convey no information to a policy maker about the
    outcomes from his or her policy decisions.
    3) The appearance of a scientific basis for regulation of CO2 emissions is a consequence of applications of the equivocation fallacy on the part of climatologists.
    4) The contention that that an “anthropogenic signal” is detectable over the “noise” of natural
    variability in the global temperature violates the upper bound on the speed of light in the theory of
    relativity.
    5) When a numerical value is assigned to the equilibrium climate sensitivity, this assignment conveys no information to a policy maker about the outcomes from his/her policy decision.
    6) As a method for assignment of a numerical value to the equilibrium climate sensitivity, Bayesian
    parameter estimation suffers from the existence of non-informative prior probability density functions, each yielding a different posterior probability density function with consequential violation of the law of non-contradiction.
    For details, please contact me by email to terry@knowledgetothemax.com .

  55. The is considerable worldwide evidence now that any so-called warming in the past century is actually due to dubious manipulation of temperature records by NASA/NOAA and others. Steve Goddards http:///www.stevengoddard.wordpress.com is one good source. So the association of CO2 with warming of the climate is very likely completely theoretical and probably has not occurred at all, or if it has it is miniscule. So all of these trillion $ efforts for decarbonization, wind and solar power, carbon capture and storage, closing of conventional power plants etc may well have been pointless. Just think what all of the funding could have been more usefully put to!

  56. This liberal green may not be much of a proponent of nuclear power in its present form (i.e. light water solid fuel uranium reactors) but I am an ardent proponent of liquid fluoride thorium reactors. Alvin Weinberg designed both of them, but actually designed the latter due to the problems with the first.
    Learn more about molten salt reactors using thorium fuel at the Alvin Weinberg Foundation’s website and the progress being made (primarily by China) to put one online very soon.
    http://www.the-weinberg-foundation.org/learn/molten-salt-reactors/
    For me, liquid fluoride thorium reactors will make the CO2 issue irrelevant by 2030 or so, because once the first reactor has been online for a few years, (China’s goal is to have one online by 2020) no one will want to develop any other kind of power.

    • This was written in 2010 . .
      A BOLD NEW ENERGY POLICY TO SAVE THE AMERICAN WAY OF LIFE!!!
      We put millions of skilled workers on manufacturing jobs building 500 to 1,000 Nuclear power plant of a low cost standard design. This will provide all the energy to accomplish a full restoration of our industrial base. How will this happen you ask?
      First we “MINE” the oceans for gold, silver, copper, uranium, methane, manganese and other valuable minerals and metals. It has been estimated that it will be profitable to mine gold from the seas at around $ 3,000 per ounce. Second we use cheap nuclear power to extract these metals which could make a profit to pay off the national debt. Third we use the byproduct “WATER” to farm the huge vacant dry south west feeding the entire planet with low cost food.
      Finally we use the cheap nuclear power to build factories to manufacture everything the entire planet needs and we return to zero unemployment and can pay good wages because we have free energy that makes a profit in it’s creation.The money generated can payoff all debts, build nuclear reprocessing plants, research and develop a system to render nuclear waste harmless.
      Just think, full employment, no energy crisis ever, gold to make money valuable, make the dollar the strongest currency on earth, end inflation, end government debt. Just imagine “AMERICA REBORN AND THE DREAM FULFILLED!!!

  57. The EPA has made up it’s mind and the results are pre-determined. Still, you can’t win if you don’t fight.

  58. @James the Elder at 7:09 pm
    A multi-day blackout would most likely mean a generator or sub-station transformer has melted.
    That would be one of several scenarios.
    The key point I am trying to make is that if we loose the grid because of a multi-day heat wave or cold snap (polar vortex) and we have lost our surplus of coal-fired generation, then restoring the grid will require good fortune or authoritarian cuts in electrical demand. That is assuming there is no loss in infrastructure.
    But, there could be losses in infrastructure. There may be accidental losses. They could also be… purposeful. Tim Wirth and James Hansen needed nothing more than an almanac to choose the hottest day of the year for their 1988 hearing. Other people can get almanac and weather reports, too to misuse for their own purposes.

  59. I commented, but I’m afraid it was a waste of my time to do so. The EPA will do anything and everything to make more money and take what few freedoms we Americans have left. God forgive them… because I will not.

  60. I think better than individual comments would be a declaration by a panel of recognized scientists delivered to the head of the EPA in such a way that cannot be ignored. The statement could include a critical assessment of the reliability (or fallibility) of current AGW theory, cautions, or whatever is deemed appropriate. Thus Congress will have the justification to undertake remedies against the EPA for ignoring the advise of prestigious science in the formulation of policy.
    Conceivably this approach might weigh with the formulators as this is politics and the GOP has a chance of taking the Senate.

  61. This continues my comment above. If, for example, it can be shown that the EPA is relying on false or dubious information and the “prestige panel” brings this to the attention of the formulators, then the formulators can be shown as derelict of their responsibilities etc. Such a course would have to be organized by someone who is in a position to do so. What say you, Christopher Monckton, does this sound feasible?

  62. The US Supreme Court ruled 7-2 that under current law the EPA has the authority to regulate CO2 as a pollutant. If you don’t like it, then lobby Congress to change the laws so that CO2 is explicitly excepted from EPA regulation, just as federal law explicitly bans the EPA from regulating firearms ammunition.

  63. I testified in person on the Clean Power Plan in Atlanta, GA at one of the public hearings. I outlined calculations showing the estimated $7.3 – $8.8 billion dollar implementation cost is between 1 and 2 orders of magnitude to low.
    A close study of the plan does, however, show how the plan will accelerate a process that has already been going on naturally since 2007… the rapid replacement of coal-fired power plants with natural gas advanced combined cycle.

  64. ” just as federal law explicitly bans the EPA from regulating firearms ammunition.”
    ===============
    They may be unelected, but they are not stupid.

  65. @mpainter.
    I don’t share your belief that people on the left reject science. I think just the opposite. I think their problem is that they have constantly been beat up with the argument that the science is settled. Truly compelling evidence by a consensus of prestigious scientists that the science is not settled would open their minds.
    My opinion of the GOP (its base anyway) is that they are the ones who are more prone to rely on religion and superstition when they vote; far more so than democrats. It is not the democrats that push creationism and its ilk.

  66. I hate to be the Devil’s advocate here but I’m all for them passing these crippling regulations because I’m convinced that these C-Rate scientists at the EPA and their supporting Green Mob will not learn through traditional means, they must learn the hard way. My suggestion for East Coast denizens, buy a generator.

  67. Davidgmills:
    Please do not put words in my mouth nor thoughts in my head that are in fact your own. I never said anything that you ascribe to me, not even by a stretch.

    • The left Progressives have only one SCIENCE – political science which has two subdivisions =
      PROCTOLOGY AND SCATOLOGY.
      We all know the can not do math and without math how can they produce a proof?

  68. My Lord Monckton,
    The GOP, which already has little patience with the EPA, will move for its outright abolition
    I suggest that you seriously overestimate the collective spine of the GOP. They will not. They will talk about it briefly and promptly shut up when criticized by the media for being ‘anti-environment’.

  69. If you check their record, the EPA has had dozens of “Comment” gatherings, when the 10:1 pro or con was ignored and they did what they usually do: what they damn well please.

  70. davidgmills says:
    “I don’t share your belief that people on the left reject science. I think just the opposite. I think their problem is that they have constantly been beat up with the argument that the science is settled. Truly compelling evidence by a consensus of prestigious scientists that the science is not settled would open their minds. ”
    You just demonstrated that YOU don’t even know what science is. And you post is typical for them left, which is up to it’s eyeballs in the anti-science/anti-reason/anti-logic of postmodernism.

  71. Attack the “Regulatory Impact Analysis for the Proposed Carbon Pollution Guidelines for Existing Power Plants and Emission Standards for Modified and Reconstructed Power Plants” http://www2.epa.gov/sites/production/files/2014-06/documents/20140602ria-clean-power-plan.pdf
    I’m confident the WUWT clan can tear this document to shreds.
    My comment is going to focus on 1) the glaring omission in section 5 of the potential increase in wood burning for heat directly and 2) the statement in the same section of the assessment that admits the potential for CO2 emissions to increase globally due to transfer of manufacturing to regions with higher CO2 emission intensity energy sources due to higher domestic electricity prices due to the regulation in question. (What part of “Global” do they not understand?)
    An incomplete and inadequate assessment hardly seems a sound basis for regulatory action.

Comments are closed.