Guest essay by Leo Goldstein

I would like to bring to the attention of American readers that they can submit comments on the EPA regulations in accordance with Executive Order 13777, “Enforcing the Regulatory Reform Agenda,” signed by President Trump on February 24, 2017. The deadline for submission is May 15, so we have only three full days. H/t John Droz, Jr..

Comments can be as short as one line or as long as the regulations.gov site allows. You can also include audio or video attachments, although only the written comments will be considered an official statement. Off the top of my mind, I can recommend NIPCC Summaries, many articles by Prof. Richard Lindzen, as well as various materials from this outstanding resource, WattsUpWithThat. If a web page cannot be adequately saved as a PDF file, its content can be copied to Word then saved as PDF. You are also welcome to attach The Brief Summary of Science, written by me with input from Prof. Fred Singer, Prof. Will Happer, and Prof. Richard Lindzen (but not formally endorsed by them).

The comments will be received by the newly-assembled Regulatory Reform Task Force, which is to

“attempt to identify regulations that:

(i) Eliminate jobs, or inhibit job creation;

(ii) are outdated, unnecessary, or ineffective;

(iii) impose costs that exceed benefits;

(iv) create a serious inconsistency or otherwise interfere with regulatory reform initiatives and policies;

(v) are inconsistent with the requirements of section 515 of the Treasury and General Government Appropriates Act, 2001 (44 U.S.C. 3516 note), or the guidance issued pursuant to that provision in particular those regulations that rely in whole or in part on data, information, or methods that are not publicly available or that are insufficiently transparent to meet the standard of reproducibility; or

(vi) derive from or implement Executive Orders or other Presidential directives that have been subsequently rescinded or substantially modified.”

Read the Tips for Effective Comments & Restrictions. The most important ones, in my opinion, are:

● “Be concise but support your claims. Explain your views as clearly as possible, avoiding the use of profanity or personal threats. Explain why you agree or disagree; suggest alternatives and substitute language for your requested changes. Provide specific examples to illustrate your concerns and suggest alternatives.

● Base your comments on sound reasoning, scientific evidence, and/or how you will be impacted by the agency’s proposal. Describe any assumptions and provide the technical information and/or data that you used. If you estimate potential costs or burdens, explain how you arrived at your estimate in sufficient detail to allow for it to be reproduced.

● Address trade-offs and opposing views.

● The comment process is not a vote – one well-supported comment is often more informative to the agency than a thousand form letters.

● Multimedia submissions (audio, video, etc.) must be accompanied by a written comment. The written comment is considered the official comment and should include discussion of all points you wish to make.

● EPA will generally not consider comments or comment contents located outside of the primary submission (i.e. on the web, cloud, or other file sharing system).

● The inclusion of any copyrighted material without accompanying proof of one’s explicit right to redistribute that material will result in the comment being blocked from online viewing at Regulations.gov.”

So far, this opportunity has been hijacked by environmental activists and their followers. Meanwhile, the former mainstream media was saying that public input was not solicited.

The dream came true: we, The People, can petition the government to repeal any EPA regulation and the government will listen. But we only have three days to do so. Go to the Evaluation of EPA Regulations on regulations.gov, click the Comment Now button at the top right, speak your mind, and attach supporting documents.

From NASA Goddard via the OCO-2 Satellite

Carbon dioxide is the most important greenhouse gas released to the atmosphere through human activities. It is also influenced by natural exchange with the land and ocean. This visualization provides a high-resolution, three-dimensional view of global atmospheric carbon dioxide concentrations from September 1, 2014 to August 31, 2015. The visualization was created using output from the GEOS modeling system, developed and maintained by scientists at NASA. The height of Earth’s atmosphere and topography have been vertically exaggerated and appear approximately 400 times higher than normal to show the complexity of the atmospheric flow. Measurements of carbon dioxide from NASA’s second Orbiting Carbon Observatory (OCO-2) spacecraft are incorporated into the model every 6 hours to update, or “correct,” the model results, called data assimilation.

As the visualization shows, carbon dioxide in the atmosphere can be mixed and transported by winds in the blink of an eye. For several decades, scientists have measured carbon dioxide at remote surface locations and occasionally from aircraft. The OCO-2 mission represents an important advance in the ability to observe atmospheric carbon dioxide. OCO-2 collects high-precision, total column measurements of carbon dioxide (from the sensor to Earth’s surface) during daylight conditions. While surface, aircraft, and satellite observations all provide valuable information about carbon dioxide, these measurements do not tell us the amount of carbon dioxide at specific heights throughout the atmosphere or how it is moving across countries and continents. Numerical modeling and data assimilation capabilities allow scientists to combine different types of measurements (e.g., carbon dioxide and wind measurements) from various sources (e.g., satellites, aircraft, and ground-based observation sites) to study how carbon dioxide behaves in the atmosphere and how mountains and weather patterns influence the flow of atmospheric carbon dioxide. Scientists can also use model results to understand and predict where carbon dioxide is being emitted and removed from the atmosphere and how much is from natural processes and human activities.

Carbon dioxide variations are largely controlled by fossil fuel emissions and seasonal fluxes of carbon between the atmosphere and land biosphere.

For example, dark red and orange shades represent regions where carbon dioxide concentrations are enhanced by carbon sources. During Northern Hemisphere fall and winter, when trees and plants begin to lose their leaves and decay, carbon dioxide is released in the atmosphere, mixing with emissions from human sources. This, combined with fewer trees and plants removing carbon dioxide from the atmosphere, allows concentrations to climb all winter, reaching a peak by early spring. During Northern Hemisphere spring and summer months, plants absorb a substantial amount of carbon dioxide through photosynthesis, thus removing it from the atmosphere and change the color to blue (low carbon dioxide concentrations). This three-dimensional view also shows the impact of fires in South America and Africa, which occur with a regular seasonal cycle. Carbon dioxide from fires can be transported over large distances, but the path is strongly influenced by large mountain ranges like the Andes. Near the top of the atmosphere, the blue color indicates air that last touched the Earth more than a year before. In this part of the atmosphere, called the stratosphere, carbon dioxide concentrations are lower because they haven’t been influenced by recent increases in emissions.

Joseph Fournier writes on Facebook of the surprising thing he’s found:

I have quantified the average ‘lag’ between the seasonally detrended monthly rate of CO2 concentration change at both the South Pole and at Mauna Loa and there is virtually ZERO LAG as indicated by the symmetric function around the y-axis. The second curve is the ‘lag’ in the number of months between when the Pacific Trade Winds decelerate and when the seasonally detrended monthly rate of change in the tropospheric CO2 concentration as measured at the South Pole station reaches its maximum growth rate. This model ignores empirical data as it shows that all the CO2 emissions are in the North Hemisphere and yet monitoring stations in both hemispheres suggest a common area source in the tropics.

This is what the emission intensity vs latitude distribution looks like: