Posted by
Ed Bradford on Tuesday, April 21, 2009 3:43:53 AM
Ed's analysis of the
Proposed Endangerment and Cause
or Contribute Findings for Greenhouse
Gases under the Clean Air Act
at:
http://www.epa.gov/climatechange/endangerment/downloads/GHGEndangermentProposal.pdf
Comment on EPA "finding" here:
Federal eRulemaking Portal:
http://www.regulations.gov
Docket ID No. EPA-HQ-OAR-2009-0171
I read the document cover to cover. Please point out any errors
below.
Page 14 "very likely the cause of most of the
observed global warming over the last 50 years."
[DEFINITION: "very likely" = 90 to 99 percent probability]
Page 49:
"The Administrator therefore
disagrees with commenters on the ANPR who argue that when
considering whether the atmospheric concentration of
greenhouse gases may reasonably be anticipated to endanger
public health or welfare, she must consider the impact from
the regulation of greenhouse gases under the CAA following
an endangerment finding."
She considers danger of CO2, but does not have to consider any
dangers derived from the regulations.
We stopped using DDT and a danger was (and still is) Millions die from regulation.
She does not have to consider that.
Furthermore, if simply planting 1 million acres of trees
would make the United States a net negative CO2 producer, she must
still regulate. In other words, her only choice is to regulate
or not regulate, irrespective of the unintended consequences,
cost and the nature of the problem.
<OPINION author="egbegb2">
Not considering unintended consequences is bad government.
</OPINION>
Page 50 (bottom and page 51)
"For this action, the Administrator is proposing
that the air pollution be defined as the combined mix of
six key directly-emitted and long-lived greenhouse gases
which together constitute the root cause of human-induced
climate change: carbon dioxide (CO2), methane, nitrous
oxide, hydrofluorocarbons, perfluorocarbons, and sulfur
hexafluoride."
This is circular reasoning. She is assuming "human-induced
climate change" then going about proving it.
Page 57:
"The scientific evidence is compelling that elevated
concentrations of heat-trapping greenhouse gases are the
root cause of recently observed climate change."
She presents no evidence. None. The defining paper must make a
stab at it. This paper doesn't even refer to the TSD for
support. [TSD is the "technical support document" is reference in the
EPA document and is at same location.]
Page 58:
"The global average net effect of the increase in
atmospheric greenhouse gas concentrations, plus other human
activities (e.g., land use change and aerosol emissions),
on the global energy balance since 1750 has been one of
warming. This total net heating effect, referred to as
forcing, is estimated to be 1.6 Watts per square meter
(W/m2), with much of the range surrounding this estimate due
to uncertainties about the cooling and warming effects of
aerosols. The combined radiative forcing due to the
cumulative increase in atmospheric concentrations of carbon
dioxide, methane, and nitrous oxide over the period 1750 to
2005 is 2.30 W/m2. The positive radiative forcing due to
carbon dioxide is the largest (1.66 W/m2). Methane is the
second largest source of positive radiative forcing (0.48
W/m2). Nitrous oxide has a positive radiative forcing of
0.16 W/m2. The rate of increase in forcing due to these
three greenhouse gases during the industrial era is,
according to IPCC, very likely21 to have been unprecedented
in more than 10,000 years."
Is this true because the Administrator says so? Where are the
facts? She really must either make a
case in this paper of give up the ghost.
Page 59:
"Global observed temperatures over the last
century can be reproduced only when model simulations
include both natural and anthropogenic forcings, that is,
simulations that remove anthropogenic forcings are unable
to reproduce observed temperature changes."
SIMULATIONS. We are committing economic suicide because of the
results of weather simulations. Do we have nothing more than
weather simulations to base our "very likely"'s on?
What will the weather be like next July? How many paramaters are
adjustable in the weather simulation?
How to convince a jury that a weather model should be the basis for
economic shutdown. If the EPA can convince a jury of mortals
that a weather model can accurately predict the future, then the
EPA should be awarded a medal and we should all keep our mouths
shut. I believe convincing a jury consisting of reasonable men
that a weather simulation program can predict 50 years in the
future would have a probability of zero. Just ask the expert
how many parameters there are and what happens if this one is
off by 10%. Then ask about the next parameter.
Page 68:
"Indeed, a recent study referenced in the TSD estimated that black
carbon is having a much stronger direct warming effect (160 percent
higher on a global average) compared to IPCC's estimate."
EPCC estimate is immediately found to be in error. This is the
Franken effect where all errors are in favor of the agument.
This document depends heavily on EPCC. Are there any other
EPCC errors?
Page 70:
"The Administrator is
not basing her proposal on any one impact, but instead is
weighing the evidence collectively and determining that as
a whole it clearly indicates that the air pollution at
issue endangers public health and welfare now and in the
future."
Here is described discretionary judgement. Judgement affected by
the Church of Human Induced Gobal Warming. This is religion
affecting government. Our government now has a preferred religion.
Page 77:
"By the end of the century, projected average
global warming (compared to average temperature around
1990) varies significantly depending on emissions scenario
and climate sensitivity assumptions, ranging from 1.8 to
4.0C (3.2 to 7.2F), with an uncertainty range of 1.1 to
6.4C (2.0 to 11.5F), according to the IPCC."
Predictions vary from -4.6C to 10.4C.
Page 84:
"The Administrator also acknowledges that warming
temperatures may bring about some health benefits. Both
extremely cold days and extremely hot days are dangerous to
human health. But at least in the short run, modest
temperature increases may produce health benefits in the
U.S. (and elsewhere). Although the IPCC projects reduced
human mortality from cold exposure through 2100, it is
currently difficult to ascertain the balance between
increased heat-related mortality and decreased cold-related
mortality. With respect to health, different regions will
be affected in different ways. The Administrator does not
believe that it is now possible to quantify the various
effects. Because the risks from unusually hot days and
nights, and from heat waves, are very serious, it is
reasonable to find on balance that these risks support a
finding that public health is endangered even if it is also
possible that modest temperature increases will have some
beneficial health effects."
YIKES
Increased heat will cause fewer deaths from exposure but
more deaths from heat. The Administrator cannot tell which will be
greater, but declares "it is reasonable to find on balance, that
these risks support ... public health is endangered."
Page 84:
"There will likely be an increase in the spread of
several food and water-borne pathogens (e.g., Salmonella,
Vibrio) among susceptible populations depending on the
pathogens survival, persistence, habitat range and
transmission under changing climate and environmental
conditions."
This is a stretch. Seems easily verifiable by comparing NY with
Atlanta.
Page 85:
"Climate change, including the direct changes in carbon
dioxide concentrations themselves, could impact the
production, distribution, dispersion and allergenicity of
aeroallergens and the growth and distribution of weeds,
grasses and trees that produce them."
This sounds like a guess.
Page 86:
"The CCSP reports that climate change has the potential to
accentuate the disparities already evident in the American
health care systems as many of the expected health effects
are likely to fall disproportionately on the poor, the
elderly, the disabled, and the uninsured."
If heat is bad, why is America migrating to the south? Especially,
why to the aged migrate south?
Page 87:
"It is estimated that climate change can exacerbate tropospheric
ozone levels in some parts of the U.S."
It is "estimated"??? How scientific. Who did the estimate?
Page 88:
"But, as temperature rises,
these crops will increasingly begin to experience failure,
especially if climate variability increases and
precipitation lessens or becomes more variable."
This assumes that farm technology is static. It isn't. It
has evolved with changing conditions and will continue
to evolve adapting to new conditions. Any estimates about
the future of farming based on status quo are in error.
Page 89:
"The IPCC reported that moderate climate change in
the early decades of the century is projected to increase
aggregate yields of rain-fed agriculture in North America
as a whole by 5-20 percent, but with important variability
among regions."
Climate Change is GOOD according to the EPA.
Page 90:
"IPCC reported that overall forest growth for North America
as a whole will likely increase modestly (10-20 percent) as
a result of extended growing seasons and elevated CO2 over
the next century, but with important spatial and temporal
variation."
MORE FOREST GROWTH GOOD according to the EPA.
Page 92:
"Climate change is likely to affect U.S. energy use
(e.g., heating and cooling requirements), and energy
production (e.g., effects on hydropower), physical
infrastructures and institutional infrastructures."
Less energy due to closing of coal fired plants means less air
conditioning which means more heat related deaths becasue this act
turns off air conditioning and does not consider unintended consequences.
Page 92:
"The Administrator acknowledges that as for human
health, so too for welfare: moderate temperature increases
may have some benefits, particularly for agriculture and
forestry over the short term, as summarized above in this
section and discussed in more detail in the Technical
Support Document in Part IV, sections 9(a) and 10(a). This
possibility is not inconsistent with a judgment that
greenhouse gases in the atmosphere endanger welfare.
Beneficial effects can coexist with harmful effects, and it
is not necessary to reach a firm conclusion, for particular
domains and sectors, about the net result in order to reach
an overall conclusion in favor of endangerment."
The administrator will decide the issue without regard to the facts
according to the Church of Human Induced Global Warming.
Page 94:
"... the Administrator also believes many of these impacts could
raise economic, trade, humanitarian and even national
security issues for the U.S."
Many of the impacts are so bad that motherhood itself is threatened.
Page 97:
"Even if the probability of extremely
high-impact events may be small, the existence of such high
impact events, and the potential for other currently
unknown catastrophic impacts that could plausibly result
from record-high atmospheric greenhouse gas levels,
substantially bolsters the case for an endangerment finding
with respect to greenhouse gases"
The mere possibility of catastrophic impacts is sufficient reason,
but also we must consider the potential for other unknown
catastrophic impacts. That is sufficient reason to regulate.
<OPINION author="egbegb2">
This is bad government.
</OPINION>
SUMMARIZING: The possibility of known and unknown catastrophies
is sufficient reason.
Page 97:
"These uncertainties
will be with us for the foreseeable future. However,
Congress expected the Administrator to consider
uncertainties and extrapolate from limited data."
IT'S NOT MY FAULT, CONGRESS MADE ME DO IT.
[Up to this point, I have not found a cause and effect relation between
global warming and human beings contained in this document. There has been
suggested a correlation between human emitted gases but no evidence has been
put forth blaming the gases and only the gases for global warming. Therefore,
"human-induced climate chanage" is begging the question.]
Page 98:
"Administrator believes that the scientific findings in
totality provide compelling evidence of human-induced
climate change, and that serious risks and potential
impacts to public health and welfare have been clearly
identified, even if they cannot always be quantified with
confidence."
BAD
I do not agree. No such argument has been presented up through and
including Page 98.
Page 98:
"Given the evolution of climate change science over
the past 15 years or more, the Administrator believes the
evidence of discernible human influence on the global
climate, and the risks that such climate change poses, has
become more compelling, and therefore believes the evidence
that there is endangerment to the public health and welfare
of current and future generations has likewise become more
compelling in step with our increasing understanding of the
climate change problem."
BAD
This paper is a very strong statement of the Administrator's
beliefs in the Church of Human Induced Global Warming but cause and
effect evidence is missing.
Page 99:
"7. Summary
The Administrator concludes that, in the circumstances
presented here, the case for finding that greenhouse gases
in the atmosphere endanger public health and welfare is
compelling and, indeed, overwhelming."
The case is not present in the paper. The only thing overwhelming
is the Administrator's beliefs.
Page 99:
"The evidence points ineluctably to the
conclusion that climate change is upon us as a result of
greenhouse gas emissions, that climatic changes are already
occurring that harm our health and welfare, and that the
effects will only worsen over time in the absence of
regulatory action."
No such "ineluctable" argument has been presented. Therefore,
I have proved the Administrator doesn't know what she is talking
about.
"The effects of climate change on public
health include sickness and death."
No evidence, no examples nothing. Just assertions.
"The greenhouse
gases that are responsible for it endanger public health
and welfare within the meaning of the Clean Air Act."
This has not been shown in this paper.
Page 107 (footnote)
"One teragram (Tg) = 1 million metric tons."
We are now using European definitions for numbers. This, in American,
is 1 trillion metric tons. Our
regulations are now authored abroad.
Page 107:
Total
"U.S. greenhouse gas emissions have increased by almost 15
percent between 1990 and 2006."
Total population increased 21% from 1990 to 2007.
Interpolating to 2006 gives a population increase of 20%.
[http://en.wikipedia.org/wiki/Demographic_history_of_the_United_States]
World increased 26%, America increased 15%. Looks to me like
whatever we do it won't work.
Page 130
"H. Executive Order 13211: Actions Concerning Regulations
That Significantly Affect Energy Supply, Distribution, or
Use This action is not a ÎéÎísignificant energy actionÎéÎí as
defined in Executive Order 13211 (66 FR 28355 (May 22,
2001)), because it is not likely to have a significant
adverse effect on the supply, distribution, or use of
energy. This action does not impose requirements on these
activities."
Transportation is energy. I disagree with this conclusion.
Page 132:
"EPA has determined that this proposed endangerment
determination will not have disproportionately high and
adverse human health or environmental effects on minority
or low-income populations."
The EPA previously refused to consider (page 49)
unintended conseqences, so this statement cannot be true.