Climate Change

Tracking changes in Earth’s climate is important. Climate change measurement is a unique challenge, because the experiment is ongoing, as it has for billions of years. Also, the experiment cannot be rerun if there is a measurement problem, because each day is unique. This means that instrument accuracy and reliability are essential; and, that the instruments must be placed carefully, to ensure that they are measuring the correct conditions or events. In addition, the changes being measured are quite small, so the measurement approach must ensure that the act of measuring the changes does not alter the conditions being measured.

The US Climate Reference Network (US CRN) satisfies the requirements discussed above, but only for the US. The satellite measurements also satisfy those requirements globally. However, the Global Historical Climate Network (GHCN), which provides the measurements used to produce the temperature anomaly products maintained by NOAA/NCEI, NASA GISS, Hadley Centre and others does not satisfy those requirements. Measurement station accuracy is known to be persistent problem, as is measurement station location. Many station locations have been compromised by progressive urbanization. Other locations were compromised when they were installed, such as those on or adjacent to buildings or those installed at airports. The time has come to abandon the GHCN.

The calibration of the satellite measuring systems are regularly checked against deep space temperature and the temperatures measured by balloon-mounted radiosondes. Satellite land surface temperature measurements can also be checked against the measurements taken by the US CRN; and, could be checked against measurements taken by similar installations at other locations around the globe, if and when such installations exist. Satellite sea surface temperature measurements are routinely checked against measurements taken by buoys deployed across the world’s oceans. It is also time to abandon collection and analysis of sea surface temperature measurements taken by sensors in the engine cooling inlets of ocean going vessels, or by lowering buckets over the sides of ships to collect water samples for measurement.

The satellite measurements are far more comprehensive geographically, far more accurate than most ground-based temperature measurements, and far less influenced by progressively changing conditions on the ground. The satellites also primarily measure changes in the temperature of the troposphere, where heat energy accumulating in the atmosphere is stored.

However, as important as tracking changes in the earth’s climate is, the more important issue in climate change research is developing an understanding of both the natural and the anthropogenic factors which affect the climate. This is essential to developing a model of the climate which actually models how the climate would respond to various changed conditions, of which increased atmospheric CO2 concentration is one of many. Current climate models do not actually model the real climate well. This is hardly surprising, since many factors and events which affect climate are not well understood; and, thus, not included in the current climate models.

The primary factors which drive current climate models are climate sensitivity to CO2 and various forcings, including clouds. There is no experimentally established value for climate sensitivity, which is why values ranging from 1.5 - 4.5ºC per doubling of CO2 concentration in the atmosphere are used in model runs, rather than a single, experimentally determined value. Likewise, it is not even certain whether the forcing associated with clouds is positive or negative. Exercising climate models using a range of values for their primary drivers produces a wide range of potential future scenarios. However, none of these climate models have been validated, nor are they likely to be, as long as they do not include the range of significant natural factors which have affected global climate throughout the ages. These factors include El Nino Southern Oscillation, the Pacific Decadal Oscillation, and The Atlantic Multi-decadal Oscillation.

Current models also do not account for the effects of solar events or changes in solar activity of emissions. This is a particularly significant omission, since solar activity is the source of virtually all the energy which heats the earth and its atmosphere. It seems inconceivable that a climate which accurately models the real climate is possible without appropriate treatment of solar influences.

Therefore, the primary focus of climate research must shift to understanding and quantifying all the significant factors which affect the climate; and, to using that knowledge to develop a climate model which actually models the real climate. Once this model has been developed and verified, the more difficult task of determining whether the model has any forecasting effectiveness can begin.

It seems ludicrous to believe that we can accurately model an extremely complex system we do not understand. It seems at least equally ludicrous to believe that we can control an extremely complex system that we do not understand. It seems even more ludicrous to believe that we can understand how that extremely complex system would react in the distant future, if we cannot understand how it reacts now.

Numerous US corporations have stated that they are committed to efforts to mitigate climate change. Many of these corporations encouraged President Trump to remain in the Paris Agreement, which would include maintaining / increasing funding for the Green Climate Fund. These corporations apparently envision the potential to grow their businesses by offering their products and services to the developing and not-yet-developed countries, which would be recipients of climate change mitigation and adaptation funding from the Green Climate Fund.

This suggests a potential alternative source of US funding for the UN Green Climate Fund. US Corporations which have expressed commitment to mitigating climate change (and envision potential market development opportunities resulting from funding available through the UN Green Climate Fund) could provide funding directly to the Green Climate Fund. These funds could be provided from net profits, perhaps shared between retained earnings and dividends, with the approval of shareholders. Alternatively, the US federal government might choose to permit these contributions to be treated as market development expenses, which would make them tax deductible business expenses, which would transfer a maximum of 35% of the contributions to all taxpayers.

These corporations might make these contributions on the condition that the corporations manage the allocation of the funds to the recipient nations, consistent with the guidelines adopted for the Green Climate Fund. This would allow the corporations to use their management skills and experience to maximize the benefits of their funding for the recipients and their corporate interests. It would also avoid surrendering control of the funds to the opaque and demonstrably incompetent UN bureaucracy. Direct corporate involvement could also dramatically reduce the potential for funding to be siphoned off by the governments of the recipient nations.

The following US corporations directly encouraged President Trump to remain in the Paris Agreement.

The table above demonstrates that a 1% allocation of after tax net income by the listed corporations could provide annual funding of $1.21 Billion per year to the UN Global Climate Fund; and, that a 1% allocation of gross revenues could provide annual funding of $1.6 Billion to the Green Climate Fund. Other large US corporations have also expressed support for the Paris Agreement.

Total net income of US corporations is approximately $1.8 trillion Therefore, it is reasonable to assume that contributions from US corporations could yield $5 - 20 billion for the UN Climate Fund. The question is whether US corporations are willing to put their money and their shareholders’ money on the line.

The US withdrawal from the Paris Agreement does not inhibit these corporations from making such contributions; and, US government treatment of these contributions as business expenses could offset a portion of the contributions. The Administration might consider encouraging major US corporations to make such contributions.

Much has been said and written about the anticipated effects of President Trump’s decision to withdraw the US from the Paris Climate Accord. Several US cities and states have announced their intention to conform to the CO2 reduction targets agreed to by President Obama in the Paris Accord. Several corporations have also announced their intent to continue pursuing CO2 emissions reductions in line with the previous US voluntary commitment.

Some have described these statements as defiance of President Trump’s decision to withdraw the US from the Paris Accord. However, nothing in President Trump’s statement in any way prevents or inhibits US cities and states, or US Corporations from pursuing climate change related actions which they believe are in their enlightened self-interest. Therefore, while these statements certainly express disagreement with Trump’s decision, they do not represent defiance. They merely express a willingness to move forward on their own, as they were free to do before the Paris Accord was ratified, after it was ratified, and after the US withdrawal.

There are significant differences in the positions of these entities and the position of the US as a nation with regard to the Accord. President Obama obligated the United States to achieving a 26-28% reduction in US CO2 emissions by 2030; and, expressed the nation’s intent to reduce US CO2 emissions by 80% by 2050. President Obama also obligated the United States to provide approximately 30% of the funding for the UN Green Climate Fund, which was to provide an initial $100 billion per year to fund adaptation to and mitigation of the adverse effects of climate change on developing and not-yet-developing nations. The UNFCCC expected this climate funding to increase to approximately $400 billion per year.

US cities, states, and corporations are not and will not be signatories to the Paris Accord. Therefore, they have not obligated themselves to achieving specific CO2 emissions reduction levels by 2030 or 2050. They have also not committed themselves to contribute to the Green Climate Fund. Arguably, they are less obligated as the result of the US withdrawal from the Accord, as they would have been obligated by the US federal government to achieve some portion of the overall US reduction target. Also, as US taxpayers, they would have been obligated to provide their share of the US contribution to the Green Climate Fund.

President Trump offered to consider renegotiation of the Paris Accord, or negotiation of a new Accord which would be fairer to US taxpayers. However, both France and Germany have stated that there would be no such negotiations. Regardless, the US is now free to proceed to deal with the issue of climate change as it sees fit. That means that ongoing efforts to improve energy efficiency, implement renewable energy for power generation and alternative fuels for transportation can continue apace. State energy commission and utility commission renewable portfolio standards programs and renewable energy incentives can continue or expand.

Essentially, the only effects of the US withdrawal are the shedding of the national compliance and funding obligations in the Paris Accord and avoidance of the limitations to US national sovereignty embodied in the Accord. US citizens, cities, states and the US as a nation can now plan for their future actions regarding climate change without looking over their shoulders to see who’s after them.

June 2017 research report from Dr. James P. Wallace III, Dr. Joseph S. D’Aleo, and, Dr. Craig D. Idso  that concludes: Temperature adjustments account for ‘nearly all of the warming’ in government climate data.

“... it is impossible to conclude from the three published GAST data sets that recent years have been the warmest ever – despite current claims of record setting warming,”

On the Validity of NOAA, NASA and Hadley CRU Global Average Surface Temperature Data & The Validity of EPA’s CO2 Endangerment Finding

The American colonies did not declare independence from Britain and fight the Revolutionary War with Britain to achieve that independence for the United States of America, only to surrender that independence less than 250 years later and voluntarily submit to being ruled by the globalist bureaucrats at the United Nations.

The citizens of the United States did not work toward and invest in the development of the US economy to hand the fruits of their labors to the UN, to be distributed to the rulers of other nations which have not achieved the same level of development, or which have not even permitted pursuit of such development.

The US capitalist economy was not developed to compensate for the poor economic performance, or outright failure, of socialist and communist economies, or the economies of dictatorial kleptocracies. US capital should not be used to cover up those economic failures, or to support those kleptocracies.

The Framers of the US Constitution did not create the First Amendment protections for freedom of speech to protect only certain, preferred speech or the speech of certain preferred groups. The First Amendment protections for freedom of religion were not created to protect only certain religions, or only the free exercise of religious practices in private settings.

The Framers did not create the First Amendment protections for freedom of the press to protect only certain forms of “press”, or some preferred subset of the “press”, or even a government press. Press freedom was protected to assure that the populace was informed, not narrowly to support some ideology, but broadly to support knowledge and understanding.

Independence Day is a time to celebrate our independence; and, it is a time to contemplate contemporary challenges to that independence and the freedom and liberty which it protects and defends. These contemporary challenges include: the UN pursuit of some form of global governance, intended to circumscribe our freedom and liberty, under the guise of controlling climate; the UN pursuit of wealth and income redistribution, ostensibly in pursuit of climate stabilization and climate justice; the US federal government efforts to reshape social norms, providing preferred status and special rights to subsets of the total US population; the US federal government efforts to inhibit free religious expression, when that religious expression conflicts with reshaped social norms; the US government funding of research, not to advance science, but to influence public perceptions of the state of science; and, the US federal government efforts to inhibit skeptical discussion of the state of the science.

In these efforts, guidance is made to appear to be offered with a velvet glove, when in reality that velvet glove barely disguises the iron fist it covers. The guidance is offered with politically correct words and phrases of dubious meaning, including: social justice; environmental justice; climate justice; and, racial and ethnic justice. The meaning of those terms is intended to evolve, over time, as required to achieve the objectives of those exercising governance.

Independence Day is also a time to realize that these contemporary challenges are not unique, but rather newer forms of historical challenges, presented and viewed in a contemporary context.

“Those who do not remember the past are condemned to repeat it.”, George Santayana

The Paris Agreement “entered into force on 4 November 2016”. A total of 197 “parties” have “ratified” the Agreement. Ratification of the Agreement is voluntary. Establishment of Nationally Determined Contributions (NDCs) under the Agreement is voluntary. The form and magnitude of the NDCs are voluntary. Achieving the NDCs is voluntary. Continued participation in the Agreement is voluntary. Participation in the Climate Fund is voluntary.

Ratification of the Agreement and performance under the Agreement is voluntary because the United States insisted that it be voluntary if the US were to participate. The US took this position because a requirement for mandatory participation and/or mandatory performance would have made the Agreement a “Treaty” under US law, which would have required ratification by a two thirds majority of the US Senate. The US Administration of President Obama considered Senate ratification extremely unlikely.

The US Administration of President Trump has now decided to withdraw the US from the Agreement. The Agreement permits withdrawal with one year advanced notice. Withdrawal can be initiated by the Executive Branch of the US government, since the Agreement was entered into by the Executive Branch. Withdrawal from the Agreement ends any voluntary US commitments under the Agreement, regarding both NDCs and contributions to the Climate Fund.

The Trump Administration had already halted contributions to the Climate Fund. The Administration’s proposed 2018 budget does not include funding for the Climate Fund. The Administration is also attempting to reverse the EPA Clean Power Plan (CPP), which was the primary vehicle for achieving the CO2 emissions reductions committed to by the Obama Administration under the Paris Agreement. The Administration is also questioning the 2009 EPA Endangerment Finding regarding CO2, which underlies the entire US climate change effort.

The Administration decision to withdraw from the Paris Agreement does not prevent other parties which ratified of the Agreement from pursuing their pledges under the Agreement. It also does not halt the ongoing decline in US CO2 emissions, though it might result in a slowing of the rate of decline. However, US withdrawal will have a major impact on the Climate Fund, since the US was expected to be the largest contributor to the Fund.

The Administration decision to withdraw from the Paris Agreement does not necessarily affect any existing or proposed new US efforts to reduce CO2 emissions. It does not affect US climate research efforts. However, the Administration has made it quite clear that US climate change efforts will be significantly changed in the future, both in scope and direction.

Many ancient cultures attributed the significant events occurring around them to the “gods”. Some had individual gods for each type of event. Many had religious ceremonies created to appeal to or to appease the various gods. In some cases, these ceremonies involved human sacrifices.

The consensed climate science community uses climate models to produce potential future climate scenarios; and, to attempt to explain observational information from the real current climate. They suggest that increased atmospheric CO2 would result in climate change, which would then result in the following:

• more tropical cyclones;
• stronger tropical cyclones;
• more tornados;
• stronger tornados;
• more frequent droughts;
• more severe droughts;
• longer droughts;
• desertification;
• increased crop failures;
• greening of the globe;
• more heavy rainstorms;
• more flooding;
• more heat waves;
• colder winters;
• more snow;
• less snow;
• ice free Artic;
• melting permafrost;
• shrinking glaciers;
• climate refugees;
• increased crop failures;
• more rapid plant growth;
• animal range shifting;
• plant range shifting;
• more rapid sea level rise;
• more frequent wildfires;
• coral bleaching;
• ocean acidification;
• widespread hunger;
• unrest and conflict; and,
• resource wars.

Some sources assert that these effects of climate change are already manifesting in various parts of the globe; and, that they will become more pervasive in the future. However, the only documented effects to date are minimal warming, continued progressive sea level rise, slightly reduced ocean alkalinity and the greening of the planet.

The proposed approaches to avoiding, minimizing or reversing the purported effects of climate change resulting from increased atmospheric CO2 concentrations involve various forms of human sacrifice. None appear to require the sacrificing of virgins on ceremonial altars so far, though some have suggested that fate for “deniers”. However, population control of some undefined form is an integral component of the overall approach. Abandonment of fire is another integral component, as is the abandonment of animal husbandry. Return to a hunter/gatherer existence is currently not advocated, at least publicly. Some appear to mourn the passing of the age of the “noble savage”.

There is no shortage of individuals and organizations willing and anxious to lead and/or participate in the effort to appease the “God of Weather”, for several hundred billion dollars per year. There does appear to be a shortage of sources willing and anxious to provide the desired funding.

“The problem with socialism is that you eventually run out of other peoples' money.” --Margaret Thatcher

Sources:

https://climate.nasa.gov/effects

https://www.wwf.org.uk/updates/effects-climate-change

https://www.edf.org/climate/climate-changes-effects-plunder-planet

https://ec.europa.eu/clima/change/consequences_en

http://www.windows2universe.org/earth/climate/cli_effects.html

http://www.davidsuzuki.org/issues/climate-change/science/impacts/impacts-of-climate-change/

http://www.businessinsider.com/terrible-effects-of-climate-change-2014-10

http://www.greenpeace.org/international/en/campaigns/climate-change/impacts/

https://www.nature.org/ourinitiatives/urgentissues/global-warming-climate-change/threats-solutions/

https://www.nature.org/ourinitiatives/urgentissues/global-warming-climate-change/threats-solutions/

http://www.noaa.gov/resource-collections/climate-change-impacts

https://www.nrdc.org/stories/are-effects-global-warming-really-bad

The Trump Administration has raised a number of questions regarding the US and global efforts to limit climate change. Each of these questions must be addressed calmly, carefully, and comprehensively. The Administration must be extremely aware of potential legal challenges to its actions, even when those actions are clearly within the scope of its constitutional authority, as has been the case with the travel ban and sanctuary cities actions.

The key issues with regard to climate change are:

• the Paris Accords, which were ratified by the previous administration without the advice and consent of the US Senate;
• the EPA Clean Power Plan, which was issued based on a ruling by the US Supreme Court that EPA was authorized to regulate CO2 emissions under the Clean Air Act;
• the EPA Endangerment Finding which asserted that CO2 emissions represented a threat to public safety and health;
• the Social Cost of Carbon (SCC) analysis prepared by the Interagency Working Group on Social Cost of Greenhouse Gases;
• the future EPA and DOE budgets in support of climate change action;
• future US involvement in the UN Intergovernmental Panel on Climate Change; and,
• future participation in the UN Framework Convention on Climate Change (UNFCCC).

The US participation in the UNFCCC essentially underlies all of the other climate change issues. The Heritage Foundation recommended that the US withdraw from the UNFCCC in 2016. This action is within the authority of the Executive Branch. The withdrawal would become effective one year after the Administration provided notice. Withdrawal would terminate any US financial and performance obligations under the Convention.

The second obvious step was to withdraw the US from the Paris Accords. The previous Administration assured that the obligations to which it agreed in the Paris accords were non-binding, since otherwise the Paris Accords would have required the advice and consent of the US Senate, which would have been extremely unlikely to ratify the Accords as a treaty. Again, the withdrawal will become effective one year after the Administration provided notice. The withdrawal will terminate any non-binding US financial and performance obligations under the Accords.

The Administration has already issued an Executive Order to the participating agencies to disband the Interagency Working Group on Social Cost of Greenhouse Gases. One of the most crucial issues with the current SCC is that there is no recognition of the benefits of increased atmospheric carbon dioxide concentrations, although these benefits are real and might well exceed the costs, now and for the foreseeable future. The other crucial issue is that the SCC is based on modeled scenarios produced by unverified models; and, thus, the actual SCC is unknown and arguably unknowable.

The US Supreme Court has stayed the enforcement of the EPA Clean Power Plan to allow several lawsuits filed by the Attorneys General of several states (including the current EPA Administrator) to move through the courts. The Administration has determined that it will not act to defend the CPP in the ongoing proceedings.

Finally, there are a series of issues with the 2009 EPA Endangerment Finding. The Administration has not yet taken any action to rescind the Endangerment Finding, but such steps might well be crucial to achieving its overall objectives.

The consensed climate science community attributes the approximately 1°C increase in global annual temperatures since 1880 to anthropogenic CO2 emissions; and, discounts the effects of natural climate variability. Great concern is expressed over the rate of change of the global average temperature anomaly (~0.7°C/century), which is claimed to be the most rapid rise in the historical record.

However, as shown in the graph below from the National Centers for Environmental Prediction, natural variability still exists; and, it can result in changes in the global average temperature anomaly far more rapid than the change attributed largely to human influences. The seven months of daily anomalies cover the emergence from the 2015/2016 Super El Nino.

The two most dramatic features of the graph are the rapid temperature anomaly excursions in January, 2017 and April, 2017. In early January, the global anomaly declines rapidly by slightly more than 0.5°C, then rapidly rebounds by approximately 0.6°C. In April, the global anomaly again declines by approximately 0.5°C. These rapid changes, which are each equal to or greater than half the anomaly change over the past 135 years, occurred over a period of 15-30 days, or at a rate of approximately 600 times the rate of change attributed to human influences.

These two features are even more dramatic when only the Northern Hemisphere is considered. The Northern Hemisphere anomaly declines by slightly more than 1°C in early January, then rapidly rebounds by more than 1.2°C in mid-January. In April, the anomaly again declines rapidly by more than 1.1°C. These anomaly changes occurred at a rate approximately 1200 times the rate of change attributed to human influences.

It is interesting to note that the Southern Hemisphere, which contains far less land surface and thus far more ocean surface than the Northern Hemisphere, experiences far more tightly constrained variations; and, that these variations are out of phase with the larger variations in the Northern Hemisphere. The Southern Hemisphere anomaly is less than 60% of the global anomaly during the period.

It is also interesting to note that the 2017 year-to-date anomaly is averaging approximately half the global anomaly increase attributed to human influence.

The consensed climate community has also concluded that the pause in global temperature anomalies over the past 20+ years did not happen, based on a reanalysis of sea surface temperature estimates reported in Karl et al 2015. However, as illustrated by the graph below, natural variability continues to exist in the earth’s oceans as well.

There is no known human influence which would cause sea surface temperatures to decline precipitously, as they did in the last few months shown in the graph above, nor is there any human influence capable of causing the rapid increases and decreases shown in the remainder of the graph.

The consensed climate science community has been very quick to attribute increases in global temperature anomalies to human influence; and, to minimize the impacts of natural phenomena, such as El Nino and La Nina events, on those anomalies. They have been far less forthcoming with explanations of declines in the anomalies, such as those discussed above.

The US currently consumes approximately 97 quadrillion British Thermal Units (BTU) of energy in all forms each year (97 Quads). Since this quantity of energy and the forms of energy which constitute it vary over time, this analysis will use rounded numbers to avoid the impression of unjustified accuracy or precision.

Current US energy consumption, by fuel source, is approximately:

Current US electricity consumption is approximately 12 quads.

The objective of the climate change movement is to eliminate fossil fuel consumption by the end of the century, if not before. The climate change movement is also not supportive of nuclear power generation or additional hydroelectric generation. Achieving their goal would require replacing the useful energy services provided by approximately 87 quads of current US energy consumption with renewable sources of energy. As shown above, current US energy consumption produces only approximately 31 quads of useful energy services. The balance of the energy consumed is rejected as the result of process inefficiencies. Therefore, approximately 21 quads of additional renewable energy would be required to replace the useful energy services currently provided by fossil fuels and nuclear, assuming 100% utilization efficiency. At a more realistic utilization efficiency level of 60%, approximately an additional 35 quads of renewable energy would be required.

One scenario would provide the entire 35 quads of additional renewable energy with wind generation. If we assume a mix of onshore and offshore wind generation, an average wind turbine capacity of 3 MW and an average wind turbine capacity factor of 35%, the incremental generating capacity required would be approximately:

35,000,000,000,000,000 BTU/yr

3MW/WT * 0.35 * 1,000,000 W/MW * 3.413 BTU/Whr * 8766 hours/yr. = 35,000,000,000,000,000 BTU/yr

31,000,000,000 BTU/yr = 1,200,000 wind turbines

Normal electric industry practice would provide a capacity reserve margin of approximately 20%, to allow for weather extremes and equipment outage for maintenance and repair. This would increase the number of additional wind turbines required to approximately 1,450,000.

Hourly variations in electricity demand can average approximately 60%, which would require either additional generation capacity or storage capacity equal to approximately 30% of peak demand. Seasonal demand is also higher in summer and winter than in spring and fall, requiring additional, longer term, storage.

Current US electric generating capacity is approximately 1,000 Gigawatts (GW), of which 70 GW is wind generators and 80 GW is hydroelectric generators. Replacing the remaining 850 GW with 3 MW wind turbines at a 35% capacity factor would require approximately 800,000 wind turbines.

Therefore, it would require approximately 2.3 million wind turbines to replace existing fossil and nuclear generated electricity and the current direct uses of coal, oil and natural gas. That is approximately 30 times the current installed wind generation capacity. Other scenarios might rely on a combination of wind and solar initially, with later additions of Ocean Thermal Energy Conversion and Wave Energy. Regardless, this would be a monumental task.

President Trump’s Presidential Executive Order on Promoting Energy Independence and Economic Growth instructs the EPA Administrator to “review and, if appropriate, as soon as practicable, take lawful action to suspend, revise, or rescind, as appropriate and consistent with law, the "Legal Memorandum Accompanying Clean Power Plan for Certain Issues," which was published in conjunction with the Clean Power Plan.”

The legal underpinnings for the Clean Power Plan(CPP) are: the April 2, 2007 US Supreme Court ruling that CO2 is a pollutant under the Clean Air Act; and, the EPA December 5, 2009 Endangerment Finding and Cause or Contribute Finding for greenhouse gases. This Endangerment Finding requires that EPA establish and promulgate a National Ambient Air Quality Standard (NAAQS) for the greenhouse gases which are the sources of the endangerment. This NAAQS has not been issued in the 7+ years since the Endangerment Finding; and, an internet search provides no links to any documentation of EPA activity to develop and promulgate this NAAQS.

Several sources have called for reconsideration of the EPA Endangerment Finding:

• Manhattan Contrarian
• ICECAP
• Competitive Enterprise Institute (CEI) and the Concerned Household Electricity Consumers Council (CHECC)

           (HT: The Science and Environment Policy Project www.sepp.org)

EPA Administrator Scott Pruitt questions whether EPA has either the authority under the Clean Air Act or the ability, as currently structured and staffed, to regulate CO2 emissions. Congress considered and explicitly rejected including CO2 as a criteria pollutant when considering the Clean Air Act and its later amendments.

Democrat members of the US Senate have written to Administrator Pruitt, expressing their concerns about the future of the CPP; and, demanding responses from EPA regarding EPA decisions relating to the future of the CPP.

It is becoming increasingly clear that the effort to rescind the CPP will be challenged as long as the Endangerment Finding remains in place. Therefore, as difficult as it might appear, the Endangerment Finding must be challenged; and, either substantially revised or rescinded.

Recent climate research suggests that climate sensitivity to increased atmospheric CO2 concentrations is at the lower end of the range of values estimated by the IPCC, or even below that range. These results suggest that humanity is not as “endangered” as the studies used to support the 2009 EPA Endangerment Finding indicated. Therefore, it appears that the first approach to revising or rescinding the EPA Endangerment Finding should be a thorough review of the recent climate sensitivity research by non-EPA “tiger teams”, to determine whether the “endangerment” identified by EPA is real and of sufficient magnitude to justify regulatory programs such as the CPP.

Absent the requirements of the CPP, electric utilities and non-utility power plant owners and the state utility commissions which regulate them would be free to continue to pursue expanded natural gas combined-cycle power plant and renewable generation options, applying Best Available Current Technology, consistent with maintaining system reliability and controlling consumer energy costs.

Prior to the US election in November 2016 the UNFCCC, the IPCC, the signatories to the Paris Accords and numerous environmental NGOs were quietly confident that the expected future Clinton Administration would continue the environmental policies of the Obama Administration. Since the election of President Trump, those organizations and their progressive allies in the US have attempted to convince the then President-elect and now President to modify the positions he espoused during his campaign regarding climate change.

They have also attempted to convince themselves and others that the momentum produced by the Paris Accords would continue regardless of the positions taken by the Trump Administration; and, they attempted to halt or slow the approval of Scott Pruitt as the new EPA Administrator. Their progressive allies in and out of government have resisted and continue to resist the changes being pursued by President Trump and Administrator Pruitt. They even organized a March for Science to demonstrate their opposition to the Administration’s climate agenda.

Several recent events have clearly demonstrated to these groups and their progressive allies that they have been unsuccessful in slowing the Administration’s pace or changing its direction.

• The publication of the President’s America First budget blueprint, which includes a significant reduction in EPA staffing and funding.
• Issuance of the Presidential Executive Order on Promoting Energy Independence and Economic Growth.
• Administration Office of Management and Budget Director Mick Mulvaney’s recent response to questions regarding future climate change funding.
• Administrator Pruitt’s recent statements regarding the Paris Accords.
• Energy Secretary Perry’s failure to agree to the G7 climate statement.

The NGOs and others have now begun efforts to convince US businesses that they “must” take the lead in moving the US toward a clean energy economy, since the Administration has decided not to force the US economy down that path. The Environmental Defense Fund document linked above goes into significant detail regarding what they believe is in the enlightened self-interest of US businesses, apparently under the impression that those businesses would be incapable of identifying courses of action which would be in their best interests on their own; or, that they can shame the businesses into courses of action which the businesses do not see as being in their best interests.

The Administration actions so far have no impact on the climate change positions taken by several states in the Northeast and California, which have established state goals and state cap & trade programs designed to achieve those goals. The Administration actions also have no effect on the Renewable Portfolio Standards established by state legislatures and regulatory bodies regarding electric power generation. They also have no impact on state incentive programs for on-site generation, including net metering programs available from regulated utilities. However, the Administration has begun efforts to free the states from the CO2 emissions reduction requirements which would be imposed by the EPA Clean Power Plan, which has currently been stayed by the US Supreme Court.

The US “commitment” to reduce its CO2 emissions under the Paris Accords is not the only issue of discussion regarding the Accords. The developing nations have begun their “show me the money” chorus regarding the Climate Fund agreed to in Paris. It appears exceedingly unlikely that the desired $100 billion per year funding level will be achieved, despite the best intentions of the intended funders and the fondest desires of the intended recipients.

The general reaction of the consensed climate science community, the environmentalist community, the progressive political class, and the “mainstream” media to the Trump Presidential Executive Order on Promoting Energy Independence and Economic Growth has been marked by a degree of hyperbole bordering on the unhinged. The EO has been accused of doing several things which it does not do, nor even intend to do.

One major focus of the reaction has been aimed at the Administration’s intent to remove support for the Clean Power Plan. This is viewed as an attempt to reinvigorate the US coal industry, though the intent is actually to allow operators of existing coal-fired electric generating plants to continue to operate those plants to meet their customers’ electric needs; and, to allow the construction of new coal-fired generating stations, if approved by the State Utility Commissions with jurisdiction over the serving utilities. The EO does not affect existing State Renewable Portfolio Standards, nor does it reduce or eliminate existing federal programs to encourage wind and solar generation development and use. The EO does not require a reversion from current environmental dispatch protocols to economic dispatch. The EO does not affect any existing federal emissions regulations regarding criteria pollutants. The EO merely states the intent not to enforce the proposed CO2 emissions limits imposed by the CPP, which are not currently economically achievable on either new or existing coal generators with commercially available and demonstrated control equipment.

Trump’s critics have proclaimed that the Clean Power Plan is the salvation of the future of life as we know it; and, that not enforcing it will make no difference because its objectives will be achieved anyway. There is reasonable likelihood that the truth lies somewhere between these extreme positions.

A second major focus is the intent to abandon or substantially revise the current Social Cost of Carbon calculation. The current SCC estimate of ~$40 per ton is believed to be exaggerated; and, to completely ignore the social benefits of increased atmospheric CO2, such as the NASA-documented “greening” of the planet. Increased atmospheric CO2 concentrations have been experimentally determined to increase plant growth rates and to improve the efficiency with which plants use available water.

The intent of the SCC calculations was to be a precursor to a carbon tax or fee (essentially a “sin” tax) intended to drive up the costs of fossil fuels and produce large incremental federal revenues. One proposal for a “fully refundable carbon tax” is discussed here in all its redistributionist glory.

A third significant focus is the intent to reopen federal lands to fossil fuel exploration and production. Most of the growth of natural gas reserves over the past eight years has been the result of exploration and production on private lands. While this has been effective in dramatically increasing availability and reducing cost, the limitations to E&P on federal lands has taken many highly regarded development prospects “off the table” and led to the development of less attractive prospects because they are on private land and thus accessible.

Perhaps the most shocked reactions to the explanations of the Administration positions which led to this Executive Order have been to the extremely blunt response by Administration Budget Director Mick Mulvaney to questions about climate change funding in the President’s Budget Outline. Mulvaney is quoted as responding that he believed the President had been quite clear that he believed that funding was a waste of taxpayers’ money and that the Administration would not be funding that in the future.

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Several commentators have identified rescission or substantial revision of the 2009 EPA Endangerment Finding regarding CO2 and other “greenhouse gases” as the key to achieving the Trump Administration’s environmental objectives, as described in the 2017 Executive Order “Presidential Executive Order on Promoting Energy Independence and Economic Growth”.

“The Clean Air Act, which was last amended in 1990, requires EPA to set National Ambient Air Quality Standards (40 CFR part 50) for pollutants considered harmful to public health and the environment. The Clean Air Act established two types of national air quality standards. Primary standards set limits to protect public health, including the health of “sensitive” populations such as asthmatics, children, and the elderly. Secondary standards set limits to protect public welfare, including protection against decreased visibility, damage to animals, crops, vegetation, and buildings.

The US Supreme Court ruled in April 2007 that EPA had the authority to regulate the emissions of CO2 and other greenhouse gases under the Clean Air Act of 1970, as amended. The Supreme Court decision was based on the potential endangerment which could be caused by climate change driven by CO2 and other GHG emissions, rather than on direct human endangerment resulting from exposure to these gases.

EPA issued an Endangerment Finding regarding greenhouse gases in December, 2009. The language reproduced above states that EPA was then required set an NAAQS for CO2 as well as the other listed greenhouse gases. The contemporaneous EPA Cause or Contribute Finding was limited to new motor vehicles, though they are obviously not the only sources of CO2 and other GHG emissions of concern. For example, the UN Food and Agriculture Organization (UN FAO) has determined that “the livestock sector generates more greenhouse gas emissions as measured in CO2 equivalent – 18 percent – than transport.”

EPA was immediately petitioned to set the NAAQS for CO2 at 350 ppm. Others have spoken out for an NAAQS at 270 ppm. Dr. James Hansen of NASA-GISS and others asserted that 350 ppm was the maximum safe atmospheric concentration of CO2. This assertion was based on the outputs of climate models, rather than on any rigorous experimental demonstration of endangerment. EPA could elect to set the NAAQS at some other atmospheric concentration. However, EPA has failed to do so in the intervening 7+ years, for a variety of reasons.

Fortunately, the NAAQS process includes an “escape hatch” for exceedances resulting from “pollution” from non-state sources, including non-US sources such as China and India. Unfortunately, each US state would have to comply with the NAAQS, with the exception of “pollution” from non-state sources, even in the face of continuing increases in emissions from those non-state sources.

An NAAQS set at 350 ppm would arguably require not only the total elimination of CO2 emissions by each US state, but also the installation of facilities deemed capable of reducing atmospheric CO2 concentrations by ~50 ppm below current levels during the compliance period. Presumably, the capacity of the US facilities to remove existing CO2 from the atmosphere would be limited to the capacity to remove CO2 from “state sources”.

Historic NAAQS compliance periods have been less than 10 years. A similar compliance period for CO2 would make the “83% by 2050″ touted by the Obama Administration pale in comparison. This would be the case, not only because the required investments would have to be made over an extremely compressed time frame, but also because many potential technologies, which might have become economically viable both for producing energy without CO2 emissions and for removing CO2 from the atmosphere, would likely not be commercially available during the dramatically shortened compliance time frame.

Regardless, absent a dramatic change of course by the developing world, the actual atmospheric concentration of CO2 would continue to increase, though arguably at a somewhat slower rate than would otherwise have occurred. That means that an NAAQS set at 350 ppm could not possibly be achieved in reality without rapid and coordinated action by all of the nations of the globe to both halt current emissions and to install and operate facilities to remove CO2 already in the atmosphere. The discussions at COP 15 in Copenhagen in December, 2009 and the Paris Accords announced in December, 2015 suggest that such action is highly unlikely, absent some cataclysmic event(s).

The International Energy Agency (IEA) has estimated that the investment required to stabilize atmospheric carbon concentrations at ~450 ppm by 2050 would be ~$45 trillion over and above the business as usual scenario; and, could be more than double that amount if technology advances do not occur as rapidly as they project. The investments required to stabilize atmospheric carbon concentrations at ~350 ppm by 2050 are not estimated, but would certainly be more than $100 trillion, since the emissions reductions required would become emissions eliminations; and, additional investments would be required to remove carbon already in the atmosphere. A dramatically shortened compliance time frame would increase these investments significantly.

I remain convinced that the ultimate intent of the AGW CO2 “mitigation” effort is the total elimination of anthropogenic carbon emissions. Should EPA actually establish an NAAQS for carbon dioxide at a concentration at or below ~400 ppm, that intent would be confirmed; and, the timeframe for compliance would be dramatically shortened compared with the timeframes contemplated even by the Paris Accords.

The FACT that the atmospheric concentration would not actually be stabilized at that level, since accomplishing that is clearly beyond the capability of the US, would have no bearing on EPA’s enforcement of the NAAQS. The only advantage of an NAAQS which is clearly unachievable in reality would be its susceptibility to being overturned by the courts, which still appear to retain the ability, if not the willingness, to separate fantasy from reality.

The Trump Administration has released “America First, A Budget Blueprint to Make America Great Again”. The blueprint is long on direction and short on details. The implications of this document for climate change are significant and broad-ranging. Of course, it remains to be seen how and to what extent the direction provided by this budget blueprint will be embodied in the actual Federal Budget.

The impacts of the budget blueprint on climate change would impact primarily the following cabinet departments and executive branch agencies:

            Department of State (UN funding for UNFCCC, IPCC and related activities)

            Department of Commerce (NOAA, NCEI)

            Department of Energy (NREL, energy efficiency programs)

            Environmental Protection Agency (climate related programs, including CPP)

            NASA (GISS activities related to climate change)

These impacts are discussed in more detail below.

Department of State

Eliminates Global Climate Change Initiative. Ceases funding to Green Climate Fund and its two precursors. Probable effects on numerous other UN climate change related activities.

Department of Commerce

Eliminates NOAA grants for coastal and marine management and education, largely related to sea level rise. Retains funding for current polar satellite programs, but proposes savings from future efforts.

Department of Energy

Refocuses Energy Efficiency and Renewable Energy and Fossil Energy Research and Development programs on limited, early stage R&D. Specific impacts on national laboratories are not articulated.

Environmental Protection Agency

Discontinues funding for the Clean Power Plan, international climate change programs and climate change research and partnership programs.

Energy Star appliance efficiency program is defunded.

NASA

NASA’s efforts will be refocused toward space exploration and away from climate change. Major effect should be on the Goddard Institute of Space Studies, which is currently heavily involved in climate change related activities.

The largest budgetary impacts of the budget blueprint fall on the Department of State (28.7% reduction) and US EPA (31.4% reduction). The major impacts on the Department of State appear to be in UN-related funding for climate change activities, though UN funding for other activities is also identified for elimination or reduction. The major impacts on EPA are focused on climate change, as had been promised.

The detailed negotiations in the Congress regarding the 2018 Federal Budget will occur against the background of both a congressional investigation and a NOAA investigation of allegations surrounding Karl et al adjustments to the global sea surface temperature data; and, EPA efforts to terminate the Clean Power Plan and to question the validity of the 2009 CO2 endangerment finding.