EPA Declares GHGs a Danger

Today the U.S. EPA "finalized its endangerment finding on greenhouse gas pollution." (Note, this link is to a pdf document of 284 pages). The EPA thus sets the stage for massive regulation of CO2 emitting facilities, along with other gases that are declared to be greenhouse gases (but note that water vapor, by far the most significant greenhouse gas, is not on the EPA's list of components to be regulated). The EPA's seven listed reasons for making this endangerment finding ring rather hollow, as shown below:

1. Greenhouse gases are increasing and changing the earth's climate.

2. Polar ice caps crumbling into the oceans.

3. Changing migratory patterns of animals.

4. Broader ranges for deadly diseases.

5. Historic droughts.

6. More powerful storms.

7. Disappearing coastlines (presumably due to sea level rise).

1. The earth's climate has been warming at least since the end of the Little Ice Age, around 1850. Yet, man-made emissions of greenhouse gases, primarily CO2 and methane, have not been significant until 1975. EPA's greenhouse gas theory fails to explain how the earth warmed from 1850 to 1975, when greenhouse gases were very low and stable. Also, the earth warmed significantly during the Medieval Warm Period, a world-wide warm period that is beyond dispute. Yet it is certain that CO2 and methane emissions were very low in those days. A coincidental correlation of increasing temperatures and increasing CO2 over a mere two decades (1975 to 1995, or 1998) is not causal proof that CO2 causes global warming. EPA surely knows this, but it is not politically correct to state the obvious.

2. Polar ice caps are not crumbling into the oceans at any greater rate than in the past, in fact, polar ice is increasing in extent and depth. Satellite observations confirm this fact.

3. Animal migratory patterns have changed for millenia. The fact that some are changing now is not news, nor is it important.

4. The increased incidence of diseases is a function of increased prosperity world-wide, and the attendant increased mobility of humans. The inability of some countries to keep out illegal aliens is largely responsible for such diseases.

5. Historic droughts are not occurring in modern times, yet did occur thousands of years ago. Desertification is a natural process as is well-known and well-documented. As just one example, there are petrified forests in the U.S. desert Southwest.

6. More powerful storms are not occurring, indeed, hurricanes in the Atlantic are waning both in number and intensity. Measurements of storms are increasing due to satellites, and labeling of minor storms is increasing.

7. Coastlines are not disappearing as the EPA claims, because sea levels are not rising. Satellite data clearly shows a slowing of sea level rise worldwide. In many areas, the sea level is dropping, for example, off the west coast of the United States. This is especially troubling because California enacted a state law to combat global warming, AB 32, with a specific purpose of halting rising sea levels. The data shows the seas are declining. If increased CO2 did in fact cause sea levels to increase, how then does EPA explain the dramatic leveling off of sea level rise in recent years? EPA cannot explain this.

The EPA's finding is non-sensical, and will be challenged in court.

Where sound science can be obtained, making sensible regulations that properly consider economic harms is acceptable. But, as in this case, where clear evidence and sound science shows that CO2 cannot be responsible for any warming or cooling of the earth, the EPA has stepped far beyond the limits of its regulatory authority.

Based on sound principles of process control, CO2 has been shown to be immaterial to the earth's average temperature. (see this link). Briefly, the earth's average temperature cycles from warm periods to cold periods, with mild periods in between. Yet, CO2 levels remained relatively constant. A valid control system requires a consistent response between the target variable (earth's temperature) and the manipulated variable (what we can change, in this case, CO2). Furthermore, it is well-known that ice ages occurred several times after CO2 levels in the atmosphere were many times higher than those of today.

The EPA is charged with promulgating regulations to prevent harm to U.S. citizens from various pollutants, and should stick to that task. Among the most important of these, with actual harm to people, is the steady increase of pharmaceuticals (including endocrine disruptors, psychotropic drugs, and other very powerful sedatives) in recycled water from waste treatment plants across the country. This highly polluted water replenishes aquifers and re-enters the potable water system, which people drink and use for other domestic purposes.

It is time for engineers and technically-trained attorneys to step forward, and put an end to this nonsense of greenhouse gases and their supposed causing of global warming.

Roger E. Sowell, Esq.