By 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.
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.
Mass civil disobedience is needed–let them know you will not obey incompetent, insane regulations.
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
EPA ADMINISTRATOR SPEAK OUT ALL OPINION AND NO LINKS TO FACTS?
http://irishamerica.com/2014/07/the-administrator/
The Administrator | Irish America
irishamerica.com
Gina McCarthy was appointed Administrator of the Environmental Protection Agency in June 2013, after a 30-year career in the health and environmental…
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/
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.
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.),
From profitup10 on August 9, 2014 at 12:47 pm:
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.
http://static.berkeleyearth.org/pdf/climate-impacts-of-coal-and-natural-gas.pdf
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.
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.
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
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.
From the1pag on August 9, 2014 at 1:12 pm:
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.
Analysis: The stability of the electricity distribution grids is beyond EPA’s Congressionally-authorized mandate.
Analysis: The adequacy and continuity of the electricity supply is beyond EPA’s Congressionally-authorized mandate.
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?
Analysis: Domestic Extremism detected, anti-establishment. Sending message with tracking metadata to Homeland Security for review.
Never give in/up.
Nil illegitimus carborundem !! (Don’t let the b*****ds grind us down
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.
There is no way the Republicans are going to eliminate the EPA.
The State Legislatures have the power to Close all non Article I section 8 compliant agencies.
http://articlevprojecttorestoreliberty.com/index.html
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.
At what point does a state just say, “No.” and dare the feds to come in and shut down power plants?
@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.
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.
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:
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?
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.
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
inMAGICn:
On sound theoretical grounds, a statistically validated model is not a possibility for 30, 100 or more years. 1 year is the upper limit.
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.
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.