While you are enjoying your Thanksgiving, do take the time to act upon this.
Daniel Simmons writes:
Great work with Watts Up With That (RWL Note: WUWT is where I first found this – here) on the CRU email scandal. Hopefully this scandal will lead to increased openness in climate science.
With all of the noise about those emails I wanted to bring your attention to an EPA comment period that closes this Friday. As you previously covered on Watts Up With That, EPA is working on declaring that CO2 and GHGs greenhouse gases endanger human health and welfare under the Clean Air Act.
That endangerment finding is the first step to regulating GHGs and the second is to develop the actual regulations to regulate GHGs for cars and light trucks. On Friday, the comment period for EPA’s proposed regulations on cars and light trucks closes. It would be very helpful to push back on the proposed endangerment finding by pushing back on the proposed regulations on cars and light trucks and sending EPA as many comments as possible on the proposed GHG regulations for cars.
We want to make sure as many people as possible know about this proposed rule and generate as many comments as possible. To facilitate people sending comments to EPA on the proposed rule, we put up a page that contains a model comment to send to EPA. The model comment is completely modifiable (RWL Note: I myself sent a heavily modified version – see below).
Also, here is EPA’s Proposed Rule: and a direct link to the Docket to submit comments to EPA is here:
People can also send email on this rule directly to EPA at a-and-r-Docket@epa.gov.
It would be very helpful if you would let your readers know about this comment period. Because of Thanksgiving and the cap-and-trade bills, this proposed rule hasn’t gotten very much attention and yet it relies on the same science as EPA’s other regulations and will help trigger a regulatory cascade of EPA inserting itself into many areas of life because those activities emit GHGs.
Here’s more background: To address climate change (and relying on the standards sources of climate science–the IPCC, NCDC, GISS, etc.) EPA is proposing to use the Clean Air Act to require 35 mpg fleetwide fuel economy standards by 2016—four years faster than Congress’ plan in the Energy Independence and Security Act of 2007. Not only will this rule drive up car and truck prices and limit consumer choice, it will start a regulatory cascade with EPA regulating GHGs using a number of sections of the Clean Air Act.
But EPA’s data show that the rule is all cost and no benefit. According to EPA, the proposed rule will increase car and truck prices an average $1,100. (74 Fed. Reg. 49460) As a result of less CO2 in the air, the rule will lead to decrease in global mean temperature by 16 thousandths of a degree Celsius (0.016°C) in 2100 and a decrease in mean sea level rise by 1.5 mm. (74 Fed. Reg. 49589) That’s not a joke—that’s what the rule says. Obviously 16 thousandths of a degree Celsius, 90 years down the road will not affect the climate in any way.
It would be bad enough if the rule only imposed exorbitant costs and with no benefits. But this will start the regulatory cascade that many of us have written about. To finalize this rule, EPA would also finalize their “endangerment finding” (in other words, EPA would find that GHGs from motor vehicles harm public health and welfare). CO2 and GHGs will become subject to National Ambient Air Quality Standards, New Sour Performance Standards, Hazardous Air Quality Standards, among other regulatory schemes.
If EPA makes an endangerment finding for GHGs, that action would make two permitting programs apply to GHGs—prevention of significant deterioration (PSD) and Title V. PSD applies to stationary sources which emit more than 250 tons a year and Title V applies to stationary sources which emit 250 tons per year. According to EPA, this would force as many as 6 million buildings (school, churches, hospitals, office buildings, farms, etc.) to comply with the Clean Air Act’s permitting provisions. To try to address this problem, EPA has proposed a “tailoring rule.” The point of the tailoring rule is that 250 tons per year of emissions can be read to mean 25,000 tons per year. Again, that’s not a joke.
I know, I know, we’re two days out, and Thanksgiving is one of those days, but it took me less than five minutes to hit the IFE’s page and put together my “model” – which, for anyone who wants it, is as follows:
Attn: Docket ID No. EPA-HQ-OAR-2009-0472
RE: Proposed Rulemaking to Establish Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards
The Environmental Protection Agency (EPA) is not justified in regulating carbon dioxide emissions from vehicles. Not only will these regulations will only increase the cost of our cars, harm our economy, and limit our transportation options, but they are also based on a scientific theory (man-made global warming) that has come into serious question with the release of the East Anglia University files. We need efficient, affordable transportation to rebuild our economy and create American jobs, not regulations derived from questionable theories.
According to the proposed regulations, EPA wants to regulate carbon dioxide emissions from cars and trucks, “because of the critical need to address global climate change.” (74 Fed. Reg. 49454).This regulation does not achieve EPA’s stated goal because, according to EPA data, it does not reduce global warming or sea level rise in a meaningful way. The regulation states that the carbon dioxide reductions “are projected to reduce global mean temperature by approximately 0.007–0.016°C by 2100, and global mean sea level rise is projected to be reduced by approximately 0.06–0.15 cm by 2100.”
To be clear, EPA is proposing to increase the price of automobiles by $1,100 per car (74 Fed. Reg. 49460) in exchange for (according to EPA) a global temperature decrease of 16 thousandths of a degree Celsius in 90 years. Also, according to EPA, sea level won’t rise by an extra 1.5 millimeters. These tiny amounts are so inconsequential that they will not affect global climate at all nor will they affect “public health and welfare” (See Clean Air Act Sec. 202).
The proposed regulations will, however, have dramatic and harmful consequences for our economy. To make matters worse, these regulations would start a regulatory cascade. EPA would start regulating emissions from millions of sources, including large buildings, churches, sports arenas, office buildings, farms, schools, hospitals, etc. EPA will be empowered to regulate greenhouse gases with many sections of the Clean Air Act, including sections 108, 111, and 112. This will further harm our economy, reduce American jobs, and worsen unemployment.
EPA should not regulate carbon dioxide or greenhouse gas emissions under the Clean Air Act. These regulations will make our high unemployment even worse. It does not make sense for EPA to reduce American jobs, increase the price of cars and trucks, and make America less economically competitive in exchange for an immeasurable and meaningless reduction in global temperature. These costs far outweigh a minimal reduction in carbon dioxide for a scientific hypothesis that remains unproven and has relied on extraordinary deviations from the scientific method in order to avoid scrutiny.
See? That’s not so hard, is it?
So please, go to the IFE or the EPA, and make your voice heard.
Cross-posted to the right-wing liberal
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