Category Archives: Climate Change Regulations

An Analysis By Donald Rapp Of The Levitus Et Al 2012 Analysis

Donald Rapp (see the post on his book – The Climate Debate) sent me the two figures above with the note below. It is an interesting presentation of the Levitus et al (2012) analysis data, which I felt was informative. I am presenting here with his approval.  His e-mail transmitting the information follows. The Levitus et al 2012 paper is

Levitus, S., et al. (2012), World ocean heat content and thermosteric sea level change (0-2000), 1955-2010, Geophys. Res. Lett.,doi:10.1029/2012GL051106, in press

which I have posted on several times; e.g. see

Comment On Ocean Heat Content “World Ocean Heat Content And Thermosteric Sea Level Change (0-2000), 1955-2010″ By Levitus Et Al 2012

The Overstatement Of Certainty In The Levitus Et Al 2012 Paper

Dear Roger:

You might find this interesting. If you take the integrated data of Levitus et al (2012) and differentiate it by painstakingly fitting straight lines to adjacent years, you get the attached curve (vertical scale is in 10^22 J/yr). The average was 0.5 x 10^22 over this time period and since the early 1990s when there was 100% coverage, there was no sign of any acceleration.

Don Rapp

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New Article On Wind Turbines For Electric Power Generation

I was just alerted to a new article in the journal of the European Physical Society on wind turbines (h/t to Francis Massen). The electrical benefits and costs of wind turbines is not in my area of expertise, but this is a provocative article that should have wide dissemination and discussion.

The article is

C. le Pair, F. Udo and K. de Groot, 2012: – turbines as yet unsuitable as electricity providers. Europhysicnews DOI: 10.1051/epn/2012204Wind

The abstract reads

Wind turbines have been widely accepted as electricity producers thanks to claims that wind comes free of charge, and each kWh thus produced replaces a kWh provided by conventional techniques, i.e., it saves the fossil fuel otherwise needed. However, these assumptions have never been validated in existing power distribution systems even after the installation of as much as 86 GW of wind power in Europe alone.

The conclusion reads

Decisions to install large-scale wind-powered electricity generation are based more on the expectation to save significant amounts of fossil fuel and CO2 emission than on any evidence that this is indeed the case. Wind technology is not suited for large-scale application without a good buffer and storage system. We propose to stop spending public money on large-scale use of wind. This money should be spent on R&D of future power systems. We expect that wind will not play an important role in these future systems.

source of image

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Regulation Of CO2 And Other Greenhouse Gases By the State Of Colorado

I served two terms on the Colorado Air Quality Control Commission (1983 to 1989), and am pleased with the constructive policy decisions we made with respect to several air pollution issues including asbestos,  fireplaces and wood stoves, and visibility. However, I am very disappointed by their leap into controlling CO2 emissions, and their inaccurately narrow view of what is climate change.

The 2010-2011 Report to the Public of the Colorado Air Quality Control Commission has a summary of their program to monitor and regulate CO2 emissions. With respect to these emissions, the Report has the following text [highlight added]

Climate change

New state and federal regulations took effect in 2011 that require some of Colorado’s largest industries to obtain permits if their greenhouse gas (GHG) emissions are above a certain level. GHGs have been linked to climate change, and the U.S. Environmental Protection Agency (EPA) found, through a series of court and agency actions, that GHGs qualify as an “air pollutant” under the Clean Air Act (CAA) and pose a threat to public health and welfare. Subsequently, new emissions standards for automobiles were promulgated, followed by federal GHG reporting and permitting rules for stationary sources.

The Colorado Air Quality Control Commission incorporated the federal GHG permitting requirements into the state’s permitting program on October 21, 2010. Certain large industrial sources of GHGs began submitting permit applications to the Air Pollution Control Division in 2011. Under the permitting program, the sources may need to limit their emissions of GHGs or utilize emission control equipment known as Best Available Control Technology.

GHG Permitting

The GHG permitting program falls under the federal “tailoring rule,” so called because the GHG emission thresholds are “tailored” to apply to only the largest sources of GHGs, such as power plants, refineries, and cement production facilities. The large facilities covered by the tailoring rule are responsible for about 70 percent of GHG emissions, which are primarily carbon dioxide (CO2) and methane (CH4), though there are a number of other less prevalent regulated GHGs.

Without the modification to permit threshold level incorporated into the tailoring rule, many smaller sources of GHGs would have been subject to permit requirements, such as schools, restaurants and farms, all of which emit GHGs. The GHG permitting requirements are being phased in to allow industry time to analyze their emissions and comply with the new regulations.During the first half of 2011, large sources that already had applied for permits for other non-GHG pollutants were required to include their GHG emissions in the analysis. During the second half, all sources that emit 100,000 tons per year of CO2 equivalent are potentially required to obtain a permit for their GHG emissions, however, in July 2011, the EPA deferred for a period of three years, permitting requirements for CO2 emissions from bioenergy and other biogenic sources, including landfills, some agricultural operations and electric energy utilities burning biomass.

In my view, this approach to regulate CO2 and other greenhouse gases in the same manner as with the “traditional air pollutants” such as SO2, nitrogen oxides, lead, etc is a very major expansion to a different class of environmental issues. Unlike the “traditional air pollutants”, which have no positive benefits, CO2 does as it is utilized by vegetation as part of its growth and health.  While it certainly is a first-order climate effect with both biophysical and biogeochemical effects (some of which may not be desirable), to include climate forcings into the air pollution regulatory framework is a very substantial widening of their authority over business and the public.

I have discussed the issue of CO2 as a “pollutant” in past weblog posts; e.g. see

New Plans To Regulate CO2 As A Pollutant

Comments On The Plan To Declare Carbon Dioxide as a Dangerous Pollutant

Will Climate Effects Trump Health Effects In Air Quality Regulations?

Supreme Court Rules That The EPA Can Regulate CO2 Emissions

Science Issues Related To The Lawsuit To The Supreme Court As To Whether CO2 is a Pollutant

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The Proposed Multi-Dimensional Growth Of The EPA In Climate Science

There is a news article by  of Fox News titled

EPA Ponders Expanded Regulatory Power In Name of ‘Sustainable Development’

which includes the text [highlight added]

“Environmental impact assessment tends to focus  primarily on the projected environmental effects of a particular action and  alternatives to that action,” the study says. Sustainability impact assessment  examines “the probable effects of a particular project or proposal on the  social, environmental, and economic pillars of sustainability”—a greatly  expanded approach.

One outcome: “The culture change being proposed here will require EPA to conduct an expanding number of assessments.”

As a result, “The agency can become more  anticipatory, making greater use of new science and of forecasting.”

The catch, the study recognizes, is that under the  new approach the EPA becomes more involved than ever in predicting the  future.”

In my post on May 15 2009

Comments On The EPA “Proposed Endangerment And Cause Or Contribute Findings For Greenhouse Gases Under The Clean Air Act”

I wrote

I have generally supported most EPA actions which have been designed to support environmental improvement. These regulations have resulted in much cleaner water and air quality over the past several decades; e.g. see

National Research Council, 2003: Managing carbon monoxide pollution in meteorological and topographical problem areas. The National Academies Press, Washington, DC, 196 pp.

However, the EPA Endangerment Findings for CO2 as a climate forcing falls far outside of the boundary of the type of regulations that this agency should be seeking.

The EPA on April 17, 2009 released this finding in “Proposed Endangerment and Cause or Contribute Findings for Greenhouse Gases under the Clean Air Act”.

This report is a clearly biased presentation of the science which continues to use the same reports (IPCC and CCSP) to promote a particular political viewpoint on climate (and energy) policy).

The text includes the statements

“The Administrator signed a proposal with two distinct findings regarding greenhouse gases under section 202(a) of the Clean Air Act:

Action

“The Administrator is proposing to find that the current and projected concentrations of the mix of six key greenhouse gases—carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6)—in the atmosphere threaten the public health and welfare of current and future generations. This is referred to as the endangerment finding.

The Administrator is further proposing to find that the combined emissions of CO2, CH4, N2O, and HFCs from new motor vehicles and motor vehicle engines contribute to the atmospheric concentrations of these key greenhouse gases and hence to the threat of climate change. This is referred to as the cause or contribute finding.”

As Climate Science has shown in the past; e.g. see

New Plans To Regulate CO2 As A Pollutant

Comments On The Plan To Declare Carbon Dioxide as a Dangerous Pollutant

A Carbon Tax For Animal Emissions – More Unintended Consequences Of Carbon Policy In The Guise Of Climate Policy

Will Climate Effects Trump Health Effects In Air Quality Regulations?

Supreme Court Rules That The EPA Can Regulate CO2 Emissions

Science Issues Related To The Lawsuit To The Supreme Court As To Whether CO2 is a Pollutant

the “cause” for their endangerment finding can cover any human caused climate forcing.

In my May 15 2009 post, I gave an example of how their finding could be rewritten to cover other human climate forcings. As another example, based on our paper

Pielke Sr., R.A., A. Pitman, D. Niyogi, R. Mahmood, C. McAlpine, F. Hossain, K. Goldewijk, U. Nair, R. Betts, S. Fall, M. Reichstein, P. Kabat, and N. de Noblet-Ducoudré, 2011: Land  use/land cover changes and climate: Modeling analysis  and  observational evidence. WIREs Clim Change 2011. doi: 10.1002/wcc.144

the paragraph above for an EPA Action could be rewritten as

The Administrator is further proposing to find that certain land use changes result in a threat of climate change. This is referred to as the cause or contribute finding.”

The EPA. according to this news report, could be developing justification to move into areas of regulation that they have not been involved with in the past, including land management.

They also, as implied in the article,  reply on multi-decadal climate predictions of societal and environmental impacts, which, as has been shown in our paper

Pielke Sr., R.A., R. Wilby, D. Niyogi, F. Hossain, K. Dairuku, J. Adegoke, G. Kallos, T. Seastedt, and K. Suding, 2011: Dealing  with complexity and extreme events using a bottom-up, resource-based  vulnerability perspective. AGU Monograph on Complexity and  Extreme Events in Geosciences, in press

and weblog posts; e.g. see

The Huge Waste Of Research Money In Providing Multi-Decadal Climate Projections For The New IPCC Report

have NO predictive skill.  The EPA would be seeking broader regulatory ability to influence policy but without a sound scientific basis.

I have always been a strong supporter of clean air and water, as exemplified with my two terms on the Colorado Air Quality Commission during the administration of Governor Romer (D).  I have published numerous papers and taught classes on air quality including  the use of mesoscale and boundary layer models to develop improved proceedures to assess the risk of pollution from power plant plumes, vehicular emissions, and other sources of these contaniments.  The EPA has been a leader in the effort to reduce human and environmental exposure to toxic and hazardous pollutants.

However, the broadening of the EPA into climate forcings based on model predictions, as reported in the Fox News article,  is a significant concern.

I would be interested in a dialog with them, based on the bottom-up, resource-based vulnerabiltiy persepective presented in our paper

Pielke Sr., R.A., R. Wilby, D. Niyogi, F. Hossain, K. Dairuku, J. Adegoke, G. Kallos, T. Seastedt, and K. Suding, 2011: Dealing  with complexity and extreme events using a bottom-up, resource-based  vulnerability perspective. AGU Monograph on Complexity and  Extreme Events in Geosciences, in press

to see what areas of risk should fit within their regulatory framework. As we wrote in that paper, the bottom-up, resource-based framework

concept requires the determination of the major threats to local and regional water, food, energy, human health, and ecosystem function resources from extreme events including climate, but also from other social and environmental issues. After these threats are identified for each resource, then the relative risks can be compared with other risks in order to adopt optimal preferred mitigation/adaptation strategies.”

In my view, this is the way forward with respect to assessing “sustainability”, and discussions should be undertaken to ascertain if the EPA is the right venue to do this.

As reported in the Fox News article, however, the EPA is considering the broadening out of their regulatory authority, but without building on a sound scientific foundation.  There is no evidence that their approach to sustainability uses the inclusive, bottom-up assessment approach, such as given in our 2011 paper.

If the EPA persists in using the top-down IPCC approach to develop impact assessments, they will inevitably develop seriously flawed policy responses.

source of image

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BMW’s Comment On Ethanol

I came across an interesting brochure from BMW that is titled “Beyond octane: How additives in gasoline are affecting your BMW’s performance”. We have scanned and posted the one side of this brochure below (click on image for a larger view).

The text that reads

“In combustion, ethanol provides less energy than gasoline, resulting in reduced fuel economy. When ethanol burns inside the engine, it tends to form a weaker mixture that may cause misfire, rough idle and cold start issues in your vehicle. In addition, engine components may deteriorate over time when in contact with ethanol”.

This is hardly an endorsement for this fuel component that is promoted as one way to reduce carbon dioxide emissions.

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Follow Up News Article By Timothy B. Wheeler of The Baltimore Sun Titled “Scrubber Clears The Air, But Won’t Help Climate Change”

On February 2010 I posted the announcement of an excellent news article by Timothy B. Wheeler in the Baltimore Sun

in my post

An Excellent News Article [But With One Very Important Error] In The Baltimore Sun By Timothy B. Wheeler Titled “A New Smokestack Cleans Baltimore’s Air”

There was a follow up today on the issue I raised on the neglect of mentioning the effect of the air pollution control equipment on the amount of carbon dioxide emitted into the atmosphere. The new article is titled

Scrubber clears the air, but won’t help climate change

which includes the text

“Now, Constellation is saying, the scrubbers should make Brandon Shores one of the cleanest coal-burning plants of its size in the country.

One pollutant the scrubbers won’t remove, though, is carbon dioxide. A byproduct of burning coal, CO2 is the main “greenhouse” gas produced by human activities that scientific authorities say is gradually changing the earth’s climate. Though you can’t see it, it’s pouring out of the scrubber stack seen at left, along with the billowing white water vapor. Brandon Shores emitted 7.8 million tons of the gas in 2008, according to government figures supplied by Constellation’s John Quinn.”

“But the scrubbers will actually cause the plant’s emissions of carbon dioxide to increase about 2.5 percent, company spokesmen say.  That’s because the plant will be using some of the electricity it produces to run its scrubber equipment, and will need to burn more coal to make up for the diverted power.”

The full article  is worth reading.

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Air Pollution – A National Concern

I was reminded of a short essa  that I wrote in 1979 [thanks to Emmanuel Ekanem, a research student in the  United Kingdom for reminding me of it]. The article is

 Pielke, R.A. 1979: Air Pollution – A National Concern. Bull. Meteor. Soc., 78, 1461.

This article urged a broadening of the assessment of risks in weather to include air pollution as a threat.  In terms of threats from air pollution (without considering any climate effects), it causes more loss of life in the United States, than the other weather hazards.

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An Excellent News Article [But With One Very Important Error] In The Baltimore Sun By Timothy B. Wheeler Titled “A New Smokestack Cleans Baltimore’s Air”

There was an excellent news article on February 20 2010 in the Baltimore Sun titled “A new smokestack cleans Baltimore’s air” by Timothy B. Wheeler.  However, there is one very important error that the reporter makes. The article reads in part

“A new smokestack is not usually cause for celebration among environmentalists. But the 400-foot stack spouting white clouds at Brandon Shores power plant represents a quantum leap in cleaning Baltimore’s air, not another source of pollution.”

I have advocated throughout my career, including my tenure on the Colorado Air Quality Control Commission, on the need to improve air quality. This is a critical threat to human health, which is one of the five resource areas that we urge action on in our paper

Pielke Sr., R., K. Beven, G. Brasseur, J. Calvert, M. Chahine, R. Dickerson, D. Entekhabi, E. Foufoula-Georgiou, H. Gupta, V. Gupta, W. Krajewski, E. Philip Krider, W. K.M. Lau, J. McDonnell,  W. Rossow,  J. Schaake, J. Smith, S. Sorooshian,  and E. Wood, 2009: Climate change: The need to consider human forcings besides greenhouse gases. Eos, Vol. 90, No. 45, 10 November 2009, 413. Copyright (2009) American Geophysical Union.

and in our focus on vulnerability as a policy framework (e.g. see also).

The single error, in the otherwise excellent article, is in the following paragraph [where I have bold-faced the error];

“Constellation Energy has just completed work on $875 million worth of pollution “scrubbers” at its 26-year-old coal-fired power plant on the Patapsco River. One of the plant’s two steam-generating units resumed operation with the new air-quality controls in December, and the second is cranking up now. The white clouds rising from the stack are almost entirely water vapor. A pair of 700-foot stacks nearby, which until recently belched toxic, acidic smoke from the power plant, are quiet.”

There is an other gas in this relatively clean effluent and it is carbon dioxide! I am unclear why this is not recognized in the article, but it is an important oversight.

The excerpts from the article given below present what are the positive benefits of the new scrubbers.

“But that’s likely to change with the installation of the twin scrubbers at Brandon Shores and pollution controls put in at Constellation’s other coal-burning plants in the area. The Baltimore-based power company has invested more than $1.5 billion to comply with Maryland’s Healthy Air Act, which when it was passed in 2006 was billed by state officials as the toughest power-plant pollution law on the East Coast.”

“Under the law, the state’s power plants were required to reduce harmful emissions by 70 percent to 80 percent by this year, and by 75 percent to 90 percent by 2013. Targeted are releases of nitrogen oxides, sulfur dioxide and mercury – byproducts of burning coal that contribute to environmental and health problems in the state.”

“Nitrogen oxides contribute to ground-level ozone pollution or smog that can make hot summer air difficult or painful to breathe. They harm water quality in the Chesapeake Bay as they drop from the air. Sulfur dioxide is a major source of fine-particle pollution that can cause breathing difficulties or premature death.”

“Mercury is a toxic metal that, in small doses, can damage the brain, nervous system and other organs. It accumulates in fish tissue, prompting state health officials to warn against eating too many fish caught locally.”

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Comment On News Article “U.S. Chamber of Commerce Seeks Trial On Global Warming”

There was a news article in the LA times on August 25 2009 by Jim Tankersley entitled “U.S. Chamber of Commerce seeks trial on global warming“.

The article has the text

“The U.S. Chamber of Commerce, trying to ward off potentially sweeping federal emissions regulations, is pushing the Environmental Protection Agency to hold a rare public hearing on the scientific evidence for man-made climate change.”

I do not know if a “trial” is effective, however, it is certainly clear that the EPA ruling is scientifically very flawed, as I wrote in a series of posts:

Republican Comment On EPA Endangerment Findings

Brief Overview Of Several Climate Science Research Findings

Comments On The EPA “Proposed Endangerment And Cause Or Contribute Findings For Greenhouse Gases Under The Clean Air Act”.

As I have written in the last weblog above

In conclusion, the EPA Endangerment findings is the culmination of a several year effort for a small group of climate scientists and others to use their positions as lead authors on the IPCC, CCSP and NRC reports to promote a political agenda.

Now that their efforts have reached the federal policy decision level, Climate Science urges that there be an independent commission of climate scientists who can evaluate the assement process that led to the EPA findings as well as the climate science upon which it is constructed. “

The Chamber of Commerce statement further documents that independent assessments of the EPA findings are required.

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Republican Comment On EPA Endangerment Findings

Last year, I testified before a House Subcommittee on the

Pielke Sr., Roger A., 2008: A Broader View of the Role of Humans in the Climate System is Required In the Assessment of Costs and Benefits of Effective Climate Policy. Written Testimony for the Subcommittee on Energy and Air Quality of the Committee on Energy and Commerce Hearing “Climate Change: Costs of Inaction” – Honorable Rick Boucher, Chairman. June 26, 2008, Washington, DC., 52 pp. [View PDF of Oral Summary].

I am pleased that my testimony was referred to in the Republican comment on the Proposed Endangerment and Cause or Contribute Findings for Greenhouse Gases Under the Clean Air Act issued by the Administrator of the Environmental Protection Agency (EPA). 

More importantly, the comments provide further documentation in the public record as to major issues with regulating CO2 and several other well-mixed greenhouse gases as pollutants. Of particular relevance to my expertise, the EPA Findings are not scientifically robust; e.g. see

Brief Overview Of Several Climate Science Research Findings

Comments On The EPA “Proposed Endangerment And Cause Or Contribute Findings For Greenhouse Gases Under The Clean Air Act”.

As I wrote in the last weblog listed above

In conclusion, the EPA Endangerment findings is the culmination of a several year effort for a small group of climate scientists and others to use their positions as lead authors on the IPCC, CCSP and NRC reports to promote a political agenda.”

I look forward to reading how EPA responds to the issues that are raised in the comments by the House Members.

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