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.
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.
@Andy May
My compliments. Very well written.
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.
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
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.
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?
“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.
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.
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.
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.
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 .
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!
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!!!
The EPA has made up it’s mind and the results are pre-determined. Still, you can’t win if you don’t fight.
@James Baldwin 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.
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.
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.
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?
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.
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.
” just as federal law explicitly bans the EPA from regulating firearms ammunition.”
===============
They may be unelected, but they are not stupid.
@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.
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.
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?
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’.