Friday, April 17, 2009

EPA Says CO2 Endangers Health

Today the EPA issued a proposed finding that CO2 and other greenhouse gases endanger the public health.   This was done in spite of the overwhelming scientific evidence that CO2 and other GHGs in the atmosphere have absolutely no controllable effect on global air temperatures.  In fact, as CO2 and other GHG's have risen over the past 200 years, global air temperatures have fallen, at times remained relatively constant, and risen slightly at other times.  This is utterly uncontroversial, and completely destroys the basis for EPA's proposed finding. 

"Pursuant to section 202(a) of the Clean Air Act (CAA

or Act), the Administrator proposes to find that the mix of

six key greenhouse gases in the atmosphere may reasonably

be anticipated to endanger public health and welfare.

Specifically, the Administrator is proposing to define the

“air pollution” referred to in section 202(a) of the CAA to

be the mix of six key directly emitted and long-lived

greenhouse gases: carbon dioxide (CO2), methane (CH4),

nitrous oxide (N2O), hydrofluorocarbons (HFCs),

perfluorocarbons (PFCs), and sulfur hexafluoride (SF6). It

is the Administrator’s judgment that the total body of

scientific evidence compellingly supports a positive

endangerment finding for both public health and welfare.

The Administrator reached this judgment by considering both

observed and projected future effects, and by considering

the full range of risks and impacts to public health and

welfare occurring within the U.S., which by itself warrants

this judgment. In addition, the scientific evidence

concerning risks and impacts occurring outside the U.S.,

including risks and impacts that can affect people in the

U.S., provides further support for this finding.

Under section 202(a) of the CAA, the Administrator is to

determine whether emissions of any air pollutant from new

motor vehicles and their engines cause or contribute to air

pollution which may reasonably be anticipated to endanger

public health or welfare. The Administrator further

proposes to find that combined emissions from new motor

vehicles and new motor vehicle engines of four of these

greenhouse gases – carbon dioxide, methane, nitrous oxide,

and hydrofluorocarbons – contribute to this air pollution.

The other greenhouse gases that are the subject of this

proposal (perfluorocarbons and sulfur hexafluoride) are not

emitted by motor vehicles."

This is an excellent opportunity to be heard by the EPA.

I want to share some thoughts about making public comments, as I attend many public hearings on various issues before agencies and commissions, listen to the comments, observe the commenters, and read many of the written comments that are submitted. I also make comments from time to time. I meet with various commissioners and members of public agencies, and get their views and feedback on comments and those who make the comments.

One of my public comments on California’s Global Warming law is here:

Comments are made in all forms and styles. Some are more effective than others. For those who want to view some comments on other issues, for style and content, please have a look at the link below. Some comments are one or two sentences, and others extend for several pages. Length does not matter, but content does.

For the most effect, it is a good idea to consider the following format for a comment:

Use letterhead. When the letter is complete, scan it and attach the digital file to your comment.

Identify yourself and / or your organization, describe what you do or your experience. It is a good idea to thank the EPA for the opportunity to make comments. (They like reading this, even though they are required by law to accept comments). If you work for an employer who does not support your view, it is important to state that your views are your own and do not represent anyone else.

Organize your comments into paragraphs.

Use a form letter only if you must. It is far more effective to write a comment using your own words.

However, if someone else’s comment states what you wanted to say, it is fine to write and refer to the earlier comment, by name and date, and state your agreement with what was written. The agency appreciates that, as it reduces the number of words they must read.

It is important to know that the agency staff reads the comments, categorizes them, and keeps a total of how many comments were made in each category. So, the number of comments do count. Encourage your friends to make comments, too.

Make your statement/point in the paragraph, refer to actual data where possible, and give the citation or link. Tell them why you hold your view. Try to maintain a positive, reasonable tone, and if criticizing the EPA, tread gently. Point out the inconsistencies of their view compared to other respected publications, or to accepted methodologies.

It is a good idea to describe how you are affected, or will be affected, by this proposed rule.

Close by thanking the EPA for considering your view.

Sign your name (comments get much more serious consideration when signed).

The link to public comments on U.S. government issues:

Roger E. Sowell, Esq.

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