This is a comment I put on regulations.gov about the proposed new rule.
The key assumption in this rule is that man-made Carbon Dioxide is harmful to the environment by altering our climate. I do not think this is proven. The key elements of the debate on man-made catastrophic climate change are actually pretty simple. Obviously, climate changes and it is warmer than it was 150 years ago, so these facts are not in dispute. It is the “man-made” and the supposed impending catastrophe that are controversial.
Now, if we were to double the amount of CO2 in the atmosphere from the current 400 PPM (0.04%) to 800 PPM physics and chemistry would predict that the atmospheric temperature would increase a trivial 0.75 degrees C. The climate alarmists have used global circulation models (GCM’s) with a climate sensitivity factor that increases this to three or four degrees C by assuming positive feedbacks. These models generally assume that as CO2 goes up, water vapor will increase and since water vapor is a much stronger greenhouse gas than CO2 they speculate that temperature will spiral out of control with catastrophic effects. That is pretty much their case.
The problems with this are twofold. First there are no measurements to support the idea that water vapor will increase with CO2. In fact, the models suggest the highest rate of warming should be in the tropics because most water vapor is there and most heat enters the atmosphere there. But no significant warming has occurred in the tropics (or in Antarctica for that matter), warming has been almost entirely in the northern Northern Hemisphere and especially in the Arctic. Further, if more water is held in the atmosphere wouldn’t we get more clouds? Will the clouds make us warmer or cooler? No one knows, clouds are not in the GCM’s. Second, the GCM’s have not been successful in predicting anything yet. Observations have shown no increase in global temperature since 1998, but the models predicted an increase. The proportion of CO2 in the atmosphere has increased, why no increase in temperature?
We need to remember that man’s burning of fossil fuels contributes only 8% of the CO2 that goes into the atmosphere; respiration, microbial activity, volcanism, ocean outgassing, etc. provide the rest. We also need to remember that the average CO2 in the atmosphere after the dinosaurs and until the ice age (which we are still in) is 800 ppm. Atmospheric CO2 only decreased to 300 PPM (and perhaps less) due to the ice age. The article noted below provides actual evidence (not a computer model) that the additional climate sensitivity due to doubling CO2 to 800 ppm will increase the average temperature 1.093 degrees C. A trivial amount and a fraction of what the IPCC circulation models predict. This makes much more sense and is in line with what has been seen in the Earth’s history. If this article stands the test of time, it kills the entire alarmist argument. Some have said that computing or measuring climate sensitivity to CO2 is a fool’s errand and perhaps this is so. But, either way the alarmist argument is destroyed. It is far from certain that climate change is a problem or even unusual.
Other references (Princeton Professor William Happer and MIT Professor Richard Lindzen):
Dr. Roy Spencer