Comments to the EPA on Greenhouse Gases and Clean Air Act, April 17, 2009

8/14/2019 Comments to the EPA on Greenhouse Gases and Clean Air Act, April 17, 2009

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Docket ID No. EPA-HQ-OAR-2009-0171; FRL-8895-5

Comments on the Proposed Endangerment and Cause or Contribute Findings forGreenhouse Gases under Section 202 (a) of the Clean Air Act, April 17, 2009

Submitted by

Dennis E. Hedke

Consulting Geophysicist

Hedke-Saenger Geoscience, Ltd

8100 E. 22nd St. North, Bldg 2200, Suite 3Wichita, KS 67226

316-737-2600

June 23, 2009


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TABLE OF CONTENTSPAGE

List of Figures 4

INTRODUCTION 6

The Science Is Not Settled 6Overtly Politicized 6

The IPCC 8

Lacking Citations of Eminently Qualified Scientists 9Supreme Court Decision Based on Misinformation 10

COMPARISON OF EPAFINDINGS WITH REAL DATA

Item 1: 2

The global atmospheric concentration has increased about

38% from pre-industrial levels to 2009, and almost all of the

increase is due to anthropogenic emissions.

Item 2: 15

Historic data shows that current atmospheric concentrations

of the two most important directly emitted, long-lived GHGs

(CO2 and CH4) are well above the natural range of

atmospheric concentrations compared to the last 650,000years.

Item 3: 16

Warming of the climate system is unequivocal, as is nowevident from observations of increases in global average air

and ocean temperatures...

Item 4: 22

widespread melting of snow and ice, and rising globalaverage sea level.

Item 5: 24There is strong evidence that global sea level gradually rose in

the 20th

century and is currently rising at an increased rate.

Item 6: 26

Ocean CO2 uptake has lowered the average ocean pH

(increased acidity) level by approximately 0.1 since 1750., and


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Ocean acidification is projected to continue, resulting in the

reduced biological production of marine calcifiers, including

corals.

Item 7 29

It is likely that hurricanes will become more intense...

Item 8 32

Increases in regional ozone pollution relative to ozone

levels without climate change are expected due to higher

temperatures

Item 9 38

Climate warming may increase the possibility of large,

abrupt regional or global climatic events (e.g.,

disintegration of the Greenland Ice Sheet or collapse ofthe West Antarctica Ice Sheet .

Item 10 43

Actual data indicates a disconnect between CO2concentration and temperature, refuting the assumption of

global warming due to CO2 (Author Comment)

CONCLUSIONS 45

RECOMMENDATIONS 6

REFERENCES 47

APPENDIXPetition Against Kyoto Protocol


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LIST OF FIGURES (abbreviated captions)

Figure 1. Qualitative illustration of greenhouse warming.

Figure 2. The radiative greenhouse effect of doubling the concentration of CO2, as comparedwith four of the uncertainties in the atmospheric CO2 computer climate models.

Figure 3. Local CO2 concentration for the northern hemisphere, determined through chemicalanalyses between 1812 and 1961.

Figure 4a. Reconstructions of surface temperature variations from six research teams.

Figure 4b. Comparison of temperature data as developed by Mann, et al, and the far moreaccurate rendition appearing in the lower part of the figure, as produced by the IPCC in its own

1995 report.

Figure 4c. Surface temperatures in the Sargasso Sea, a 2 million square mile region of theAtlantic Ocean, with time resolution of 50 to 100 years and ending in 1975, as determined byisotope ratios of marine organism remains in sediment at the bottom of the sea.

Figure 5. Globally averaged temperatures over the past 30 years, based on satellite data, ascompiled by the University of Alabama Huntsville.

Figure 6. The correlation between the loss of cold climate weather stations and temperature

increases is unequivocal.

Figure 7. Antarctic sea-ice over the past 30 years.

Figure 8. The extent of Arctic sea ice at January 17, 1980, and January 18, 2009.

Figure 9. Arctic temperatures 1938-2006.

Figure 10: Global sea level measured by surface gauges between 1807 and 2002 and by satellite

between 1993 and 2006.

Figure 11. Calcification rate vs sea surface temperature (SST) rise.

Figure 12. Great Barrier Reef Calcification Observations (1903-1922 vs 1979-1998)

Figure 13: Annual precipitation in the contiguous 48 United States between 1895 and 2006.

Figure 14: Annual number of strong-to-violent category F3 to F5 tornados during the March-to-August tornado season in the U.S. between 1950 and 2006.

Figure 15. Annual number of Atlantic hurricanes that made landfall between 1900 and 2006.

Figure 16. Annual number of violent hurricanes and maximum attained wind speed during thosehurricanes in the Atlantic Ocean between 1944 and 2006.


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Figure 17. Total ozone at Mauna Loa 1963-2007.

Figure 18. Global Data from NASA Earth probe TOMS, spring 2000.

Figure 19. Global Data from NASA Earth probe TOMS, summer 2000.

Figure 20. Global Data from NASA Earth probe TOMS, fall 2000.

Figure 21. Global Data from NASA Earth probe TOMS, winter 2000.

Figure 22. Average Summer Temperature record at Angmagssalik, Greenland 1892-2009.

Figure 23. Southern Greenland Temperatures 1787-2007.

Figure 24. Antarctic Ice Sheet Elevation Change 1992-2003.

Figure 25. Sea ice surrounding and including Antarctica

Figure 26. Arctic-wide surface temperature anomalies 1878-2001.

Figure 27. Arctic surface air temperature compared with total solar irradiance.


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I. INTRODUCTION

These comments are a continuation and expansion of comments I read into the record at

the Public Hearing at Potomac Yard on May 18, 2009. As a scientist, I am appalled by

some of the findings which are the subject of the ensuing comments; appalled because

of the clear lack of credible evidence to support these findings.

As a United States citizen I consider the intent of the findings to be very problematic. Theprimary intent, as I read the findings is to do everything possible to constrain the

emission of carbon dioxide (CO2) into earths atmosphere. The EPA and related agencies

believe this to be urgently necessary to save the planet. I strongly disagree.

The Science is Not Settled

As difficult as it may be for many of you (Administrator, reviewers) to accept, the

science on the multitude of issues bundled in the discussion of global warming is far

from being settled. If I believed it was, I certainly would not be spending my time poringover real data, and converting that evidence into this document. As I mentioned in thehearing, there are upwards of 31,000American scientists and engineers, including more

than 9,000 PhDs, who have signed a Petition (Exhibit 1) that registers our strong

objection to the United States enjoining any aspect of the Kyoto Protocol, or anythingresembling it in the future, such as what your are proposing in these Findings.

I can assure you that each and every one of us has signed this Petition believing morestrongly than ever that the preponderance of the evidence strongly supports our general

contention that mankind is largely NOT responsible for the atmospheric variations which

are, in your terminology, very high confidence of being naturally induced.

Overtly Politicized

Since the EPA has chosen to move in every sense in more political directions than any of

us would have ever imagined, we consider it to be fair game, and we will exert

substantial counter political force upon this issue. While the actual science should have

settled this matter long ago, fraudulent and deceptive political forces have been engagedfrom the side the EPA now stands with, and lets be clear, this political battle is on.

I cite the following:

The global warming scare is being used as a political tool to increasegovernment control over American lives, incomes and decision making. It

has no place in the Society's activities. - Award-Winning NASA

Astronaut/Geologist and Moonwalker Jack Schmitt who flew on the

Apollo 17 mission (1).

Perhaps you are of the opinion that Astronaut Schmitts is the only dissenting

opinion in NASA, a contributing organization in the findings. Read on.


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Award-winning NASA Astronaut and Physicist Walter Cunningham of

NASAs Apollo 7 was awarded the NASA Exceptional Service Medal and

Navy Astronaut Wings, is a member of the American Geophysical Unionand fellow of the American Astronautical Society. Cunningham rejected

climate fears in 2008. He states:

It doesnt help that NASA scientist James Hansen was one of the early

alarmists claiming humans caused global warming. Hansen is a

political activist who spreads fear even when NASAs own data

contradict him,Cunningham wrote in an essay in the July/August 2008

issue of Launch Magazine. NASA should be at the forefront in thecollection of scientific evidence and debunking the current hysteria over

human-caused, or Anthropogenic Global Warming (AGW). Unfortunately,

it is becoming just another agency caught up in the politics of globalwarming, or worse, politicized science. Advocacy is replacing objective

evaluation of data, while scientific data is being ignored in favor of

emotions and politics (1)

We in the other domain in the scientific community are very highly confident that

when, not if, but when the American people have finally awakened, the politics will in no

way favor the Administrator of the EPA, if she decides to stay on the track she iscurrently on. To be fair, she did not start the vehicle that is now carrying this political

monstrosity, but she has not applied any brakes whatsoever, nor has she even attempted

to downshift one solitary gear. Instead, she, with her able-bodied Czar, has now workedto synchronize the body EPA with the body House Energy & Commerce Committee.

You are no doubt now keenly aware that even White House reviewers of these findingshave clearly demonstrated just how far removed the document is from dealing with the

reality of what your findings and, hence, remediation methodologies would do to

virtually cripple the American economy. All of this to chase and attempt to corral a

colorless, odorless, tasteless and virtually harmless gas that is essential to a human andplant life on this planet. Senator John Barrasso could have, and, in my opinion, should

have taken the Administrator to even greater lengths in extracting the multiple

weaknesses of the document.

Trust me, your politics will not only NOT win out, but each and every one of your

associates will find their way to the true court of public opinion as the climate continuesto do what the climate has done since the beginning of time, change with each and very

season, and each and every solar cycle, of whatever length it chooses. The evidence that

these cycles and occurrences are natural and anything but human-induced isoverwhelming once you actually study it at base level. Relying on the IPCC as one of

your primary sources is absolutely incredulous, and you proudly tout that fact over and

over again. Please see below.


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The IPCC

As you are well aware, this is merely the backbone of your politicization of the issue, butI feel compelled to bring this entity to light on its own, in the unlikely event that some

reviewer is not fully up to speed on what it actually represents.

The Intergovernmental Panel on Climate Change (IPCC), as you know, actually has

nothing whatsoever in place that would mimic actual peer-reviewed architecture.

Instead, it operates in total vacuum, and when a real scientist actually raises a challenge,based on factual evidence, he or she is virtually shut out of the ongoing, ultimately

published findings.

As you are well aware, a multitude of highly regarded and internationally respected

scientists have chosen to withdraw from the organization because they could no longer

tolerate the ongoing wrongdoing that became ever so obvious. To be sure, many equally

eminent professionals remain in the ranks, in hopes that they may someday actually be

able to bring the truth to light, but I wonder just how much more patience they have.

The Working Group Assessment Reports are in many cases in serious error, and it takesnearly an act of Congress to bring forth a correction. As was pointed out in a recent book

by Christopher Horner (2),

The 2001 Third Assessment Report clearly acknowledges the reality

that, In climate research and modeling, we should recognize that we are

dealing with a coupled non-linear chaotic system, and therefore that thelong-term prediction of future climate states is not possible. (my

emphasis)

And we have this from an actual IPCC Expert Reviewer, Dr. Vincent Gray:

Yes, we have to face it. The whole [IPCC] process is a swindle, The

IPCC from the beginning was given the license to use whatever methods

would be necessary to provide evidence that carbon dioxide increases

are harming the climate, even if this involves manipulation of dubiousdata and using peoples opinions instead of science to prove their case.

The disappearance of the IPCC in disgrace is not only desirable but

inevitableSooner or later all of us will come to realize that thisorganization, and the thinking behind it, is phony. Unfortunately, severe

economic damage is likely to be done by its influence before that

happens.

Yet another:

The quantity of CO2 we produce is insignificant in terms of the natural

circulation between air, water and soil... I am doing a detailed assessment

of the UN IPCC reports and the Summaries for Policy Makers, identifying


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the way in which the Summaries have distorted the science.- SouthAfrican Nuclear Physicist and Chemical Engineer Dr. Philip Lloyd, a UN IPCCco-coordinating lead author who has authored over 150 refereed publications. (1)

The last quote above was derived from the U.S Senate Minority Report, produced for the

public benefit and released December 11, 2008. It includes multiple comments similar to

both those above, but from 650 renowned international scientists, who have seen thework of the IPCC, in many cases first hand as these testimonies indicate.

Lacking Citations of Eminently Qualified Scientists

As I read the Technical Support Document (TSD), I was stunned by the lack of citation

of nearly every one of the multitude of esteemed climatologists, atmospheric scientists,geophysicists, astrophysicists, etc who should be routinely cited and quoted throughout

such a document. Yet, they are spuriously, I would suggest intentionally, avoided at all

costs, so as to allow unabated discourse on the full range of subjects you have placed atthe publics disposal.

These are the men and women I am referring to who have impeccable credentials,voluminous peer-reviewed articles in prestigious journals, and integrity beyond measure.

I list them with their institutions so that you may contact them for further information.

The technical discussion to follow will include multiple references to the outstanding

work these people have done to advance understanding of global climate science. I couldfill many more pages, but this listing represents substantial wisdom:

Richard Lindzen, Alfred P. Sloan Professor of Meteorology,Massachusetts Institute of Technology

S. Fred Singer, Professor Emeritus, University of Virginia, The Science& Environmental Policy Project

Roy Spencer, Principal Research Scientist for the University of Alabamain Huntsville and the U.S. Science Team Leader for the Advanced

Microwave Scanning Radiometer (AMSR-E) on NASAs Aqua Satellite

Patrick J. Michaels, Professor of Environmental Science, University ofVirginia, former Virginia State Climatologist, Senior Fellow in

Environmental Studies, CATO Institute

Christopher Monckton, Senior Fellow, Science & Public PolicyInstitute, former Science Advisor to Margaret Thatcher

Craig D. Idso, Chairman, Center for the Study of Carbon Dioxide and

Global Change

Willie Soon, Astrophysicist, Harvard-Smithsonian Center for

Astrophysics, Chief Science Advisor, Science & Public Policy Institute


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Sally Baliunas, Astrophysicist, Harvard-Smithsonian Center for

Astrophysics

William Happer, Cyrus Fogg Brackett Professor of Physics, Princeton

University

Roger Pielke Climatologist, University of Colorado, Senior Research

Scientist at the Cooperative Institute for Research in Environmental

Sciences (CIRES) at UC-Boulder

I could name at least one hundred other individuals who you should be looking to for

advice on this very important issue.

Supreme Court Decision Based on Misinformation

The Supreme Court decision handed down on April 2, 2007 was based not on sound

scientific context, as is often alluded to in the decision, but rather largely upon thesubstantial misinformation handed down by the IPCC, and other groups providing

supporting evidence.

Why would I state that the IPCC is linked to misinformation? That discussion is multi-

layered, and follows in sections below. At this juncture, I will simply say that the IPCC isbecoming less and less credible with each passing day, and each passing alarmist

declaration it makes on national and international stages. I suggest the day is not far

distant when its credibility will be so minimized that it will cease to exist as a body ofany measurable influence in this debate.

The split decision (5-4) resulted in the Chief Justice John Roberts issuing the dissentingopinion. He properly addressed the very high uncertainty of attempting to quantify even

just the emissions sourced by vehicular operation:

This gets us only to the relevant greenhouse gas

emissions; linking them to global warming and ultimately

to petitioners alleged injuries next requires considerationof further complexities.

As EPA explained in its denial of petitioners request forrulemaking,

predicting future climate change necessarily involves acomplex web of economic and physical factors including:

our ability to predict future global anthropogenic emissionsof [greenhouse gases] and aerosols; the fate of these

emissions once they enter the atmosphere (e.g., what

percentage are absorbed by vegetation or are taken up by


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the oceans); the impact of those emissions that remain inthe atmosphere on the radiative properties of the

atmosphere; changes in critically important climate

feedbacks (e.g., changes in cloud cover and ocean

circulation); changes in temperature characteristics (e.g.,

average temperatures, shifts in daytime and eveningtemperatures); changes in other climatic parameters (e.g.,

shifts in precipitation, storms); and ultimately the impact ofsuch changes on human health and welfare (e.g., increases

or decreases in agricultural productivity, human health

impacts).

. Petitioners are never able to trace their alleged injuries

back through this complex web to the fractional amount ofglobal emissions that might have been limited with EPA

standards. In light of the bit-part domestic new motor

vehicle greenhouse gas emissions have played in whatpetitioners describe as a 150-year global phenomenon, andthe myriad additional factors bearing on petitioners

alleged injurythe loss of Massachusetts coastal landthe

connection is far too speculative to establish causation.

Chief Justice John Roberts

I side heavily with the minority, dissenting opinion. Those four justices actuallyunderstood both the complexity and the substantial uncertainty inherent in the EPAs

task, and therefore properly concluded that this matter should not have been returned to

the EPA to then proceed down the path it is on today.

Nonetheless, we are where we are, and now it is up to the new dissenters to attempt to

steer you back in a direction that is supported by the scientific facts, voluminous as they

are. The forthcoming comments will be as direct as I know how to make them.

*****************************************************


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II.COMPARISON OF EPAFINDINGS VS REAL DATA

This comparison will commence with the Executive Summary of the Technical Support

Document associated with the Endangerment Findings

Item 1: From page ES-1, Observed Trends in Greenhouse Gas Emissions andConcentrations

The global atmospheric concentration has increased about 38% from pre-industrial

levels to 2009, and almost all of the increase is due to anthropogenic emissions.

This statement appears at first reading to be very conclusive and very simple. However, it

is actually neither. Firstly, what is the source of the conclusion that almost all of the

increase is due to anthropogenic emissions?

Commonly accepted estimates of the actual contribution of CO2 to the greenhouse via

human causes range from 3-5%, meaning 95-97% of the greenhouse gases reaching thatatmosphere are due entirely to natural causes. As you are also well aware, the dominantcontributor to the greenhouse effect is water vapor, H2O, registering about 95% of the

influence of the greenhouse gases.

In fact, the radiative effect of CO2 is absolutely minor as compared to H2O, and

experimental results have proven that to be the case. But the EPA leans on IPCC

modeling, which is severely flawed. Alternate modeling, as conducted by numerousresearchers outside the IPCC, has demonstrated that instead of warming, CO2 effects on

the atmosphere, could produce counteracting effects, the net result of which is

insignificant, immeasurable temperature increase.

I include two figures that demonstrate the hypothetical effects of the two approaches, as

well as the uncertainties in computer models associated with attempting to estimate theradiative effect of increasing CO2 concentration. Scientifically, it is currently impossible

to establish that one modeling effort is superior to the other. This much can be said with

very high confidence: the number of researchers supporting the second hypothesis greatly

outweighs that of the first.


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Figure 1. Qualitative illustration of greenhouse warming. Present GHE is the current greenhouse effect

from all atmospheric phenomena. Radiative effect of CO2 is the added greenhouse radiative effect from

doubling CO2 without consideration of other atmospheric components. Hypothesis 1 IPCC is the

hypothetical amplification effect assumed by IPCC, Hypothesis 2 is the hypothetical moderation effect.

[After Soon, (3)]

Figure 2. The radiative greenhouse effect of doubling the concentration of CO2, as compared with

four of the uncertainties in the atmospheric CO2 computer climate models [After Soon, (3)].


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My belief is that these two illustrations speak very strongly against the EPAs contention

that almost all of the increase in CO2 concentration is due to anthropogenic causes. It is

simply not the case, and it is not possible to prove otherwise.

If 5% of the greenhouse effect is due to human-induced causes, and 3% of the overall

greenhouse is composed of CO2, the math tells us that the human-induced factor isapproximately equivalent to 0.15% of the overall greenhouse effect. No amount of

credible modeling will yield a result that shows the human-induced effects are as strong

as your report suggests they are.

Speaking of modeling, I cite statements by Australian David Evans, who devoted six

years to carbon accounting and building models for the Australian Greenhouse Office. Hestates

since 1999 new evidence has seriously weakened the case that carbon

emissions are the main cause of global warming, and by 2007 the

evidence was pretty conclusive that carbon played only a minor role and

was not the main cause of the recent global warming.

He also states:

1. The greenhouse signature is missing. We have been looking and measuring foryears, and cannot find it.

2. There is no evidence to support the idea that carbon emissions cause significantglobal warming. None. (emphasis mine)

Why would he make such statements?

Because thats what the data tells us. He goes on to say,

Each possible cause of global warming has a different pattern of where in

the planet the warming occurs first and the most. The signature of an

increased greenhouse is a hot spot about 10 km up in the atmosphere overthe tropics. We have been measuring the atmosphere for decades using

radiosondes.they show no hot spot. Whatsoever. (emphasis mine)

If there is no hot spot, then an increased greenhouse effect is not the cause

of global warming. So we know for sure that carbon emissions are not a

significant cause of the global warming.

There is plenty of evidence that global warming has occurred, and theory

suggests that carbon emissions should raise temperatures, but there are noobservations by anyone that implicate carbon emissions as a significant

cause of the recent global warming. (4)

On this point, I conclude that the data speaks loudly and clearly that human-induced

factors related to the greenhouse effect are minimal.


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Item 2: From page ES-1, Observed Trends in Greenhouse Gas Emissions andConcentrations

Historic data shows that current atmospheric concentrations of the two most

important directly emitted, long-lived GHGs (CO2 and CH4) are well above the natural

range of atmospheric concentrations compared to the last 650,000 years.

I respectfully disagree with Jansen, et al (5), whose ice-core related hypotheses do not

correlate at all well with other sources of CO2 estimates, such as carbon isotope massbalance modeling of atmospheric vs oceanic CO2, as conducted by Segalstad (6).

Chemical CO2 measurements conducted by numerous researchers, and compiled by ErnstGeorg-Beck (7), demonstrate that CO2 concentrations were as high as 450 ppm as

recently as 1812, and that levels reached 411 ppm around 1945. A diagram supporting

these data is shown below.

Figure 3. Local CO2 concentration for the northern hemisphere, determined through chemical

analyses between 1812 and 1961. Data plotted as an 11 year moving average. Data coverage and

important scientists indicated in dark grey/black. The data around 1820 are considered

provisional. Data series used: time window 1857-73: 13 yearly averages; from 1873-1927, 83

data points. From 1927-1961, 41 data records, of which 11 were interpolated [After Georg-Beck

(5)].

The EPA Technical Support Document (TSD) cites a series of gradually increasing

smooth curves for CO2, CH4 and N2O, based on ice core proxies dating back 650,000

years. In the bulk of the references I have managed to locate, the general trends are highlyfluctuating, and some have reached as high as 7,000 ppm, during the Cambrian period.

As you may be aware, abundant plant and the beginnings of animal creatures were

managing to get along just fine in spite of these elevated concentrations of CO2.

The question must be asked: Just exactly what is the right concentration of CO2? I submit

that no one in the EPA can provide a credible answer to that question. We do know thattoday, right now, US submarines routinely allow concentrations of 8,000 ppm CO2.


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[I realize that does not speak to the atmosphere, where you are purporting that elevated

CO2 is endangering life on this planet, due presumably to the heating introduced. Again,

the data simply does not support your contentions.]

A very large number of researchers strongly disagree that mankind has been largely

responsible for the increasing nature of CO2 over the past hundred years or so. Thesuggestion that ice core data alone resolves this matter is not supportable. What we know

about ice core data is that, firstly, it is not in any way, shape or form a closed system.

Secondly, we know that with increasing time and ice overburden, the pressure forcesmuch CO2 out of the system, so that apparent CO2 concentration measured in cores

today is certain to be below what it was initially. This has led to erroneous reporting of

the stable CO2 concentrations that seem to much lower than we measure in todaysatmosphere. The measurements do not directly relate. Ice cores are among the least

reliable data sources pertaining to CO2 concentration.

************************************************************************

Item 3: From page ES-2, Observed Effects Associated with Global ElevatedConcentrations of GHGs

Warming of the climate system is unequivocal, as is now evident from

observations of increases in global average air and ocean temperatures,

widespread melting of snow and ice, and rising global average sea

level.

The TSD provides, as evidence for this statement, graphic support and related discussion

on pages 26-27, based on a National Research Council study that produced suggested

temperature patterns over the past 2000 years. The study claims that the studies yield agenerally consistent picture of temperature trends during the preceding millennium,

including relatively warm conditions centered around 1000 A.D. (identified by some as

the Medieval Warm Period) and a relatively cold period (or Little Ice Age) centered

around 1700. The graph below, relates to this discussion:


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Figure 4a. Reconstructions of (Northern Hemisphere average or global average)

surface temperature variations from six research teams.

While I appreciate the efforts to compile this summary and the proxies utilized by this

group of researchers, I register strong disagreement with their findings. My

disagreement is based on the fact that their temperature anomaly characterization doesnot match at all with known historical conditions. For example, during the Medieval

Warm Period, abundant farming occurred on the Greenland landmass, which is not seen

today. Further, grapes were routinely grown in England in support of wineries, which

again is not possible today. Yet, your graphic summary would indicate that temperatures

today exceed those of the Medieval Warm Period, which is certainly not the case.

In addition, actual temperatures during the Little ice Age were such that the ThamesRiver would freeze over for many months out of the year, for many years running. This

would take great temperature contrast, and your graphic depiction on virtually each of the

studies indicate maximum temperature deviations of less than 1 degree Celsius. In fact,the Mann and Jones multiproxy (2003) shows a maximum temperature deviation of less


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than 0.3 degrees Celsius. That is further evidence as to why their work for the IPCC has

been discredited.

I agree that warming of the climate system is unequivocal, and that global average air and

ocean temperatures are increasing. This should naturally induce the melting of snow and

ice in some, but not all, regions on the earths surface. Whether we can actually note sealevel increasing, I suggest is doubtful, as the data will show.

But first, let us understand something about real temperature, not that as suggested by thefamous An Inconvenient Truth, wherein the world was fraudulently exposed to the now

infamous and totally debunked Hockey Stick graph, so manipulatively laid in view by

Mann, shown below in Figure 4b.

Figure 4b. Comparison of temperature data as developed by Mann, et al, (Upper) and the farmore accurate rendition appearing in the lower part of the figure, as produced by the IPCC in its

own 1995 report.


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One of the best proxies I have observed with respect to the most likely temperature

record dating back some 3,000 years is reproduced below.

Figure 4c. Surface temperatures in the Sargasso Sea, a 2 million square mile region ofthe Atlantic Ocean, with time resolution of 50 to 100 years and ending in 1975, as

determined by isotope ratios of marine organism remains in sediment at the bottom ofthe sea (6). The horizontal line is the average temperature for this 3,000-year period.

The Little Ice Age and Medieval Climate Optimum were naturally occurring, extended

intervals of climate departures from the mean. A value of 0.25 C, which is the changein Sargasso Sea temperature between 1975 and 2006, has been added to the 1975 data

in order to provide a 2006 temperature value [After Keigwin (8)].

As Im sure you are aware, Manns filtering of the real data was caught by astute

researchers Ross McKitrick, and Steven McIntyre, both Canadians who just happened tobe in the right place at the right time to actually critically review the science that the

IPCC was only too anxious and willing to share with the world. The eventual removal of

the highly fabricated graph by the IPCC was a major source of embarrassment to thatpolitical body, proving that it was, indeed, junk science.

The point of Figure 4c is to emphasize that we certainly are warming, and have beensince the merciful cessation of the Little Ice Age. Some Russian scientists have reviewed

sunspot characteristics of the recent decades, and suggest that if the current trends

continue, we may be headed for a repeat of that, or a similar event. So, yes the snow

should be melting, etc. There is no data or evidence whatsoever that we are anywhere outof expected ranges of temperature fluctuation at present.


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There is other evidence of misinformation as to the actual temperature record that appears

below. The first figure provides current data as to global temperatures over the past 30

years, as compile very accurately by the Earth Science System Center, University ofAlabama Huntsville (9).

Figure 5. Globally averaged temperatures over the past 30 years, based on satellitedata, as compiled by the University of Alabama Huntsville [After Christy (9)].

This data speaks volumes about actual temperatures over the past 30 years.Pay particular attention to the anomaly that begins in 1989 and locally maximizes at

1991, terminated by Mt. Pinatubos Inconvenient Eruption.

What you do not see in this graphic depiction is the influence of inadvertent data

manipulation that occurred due to the shutdown of 6,000 or so weather stations in coldweather climates in Canada and Siberia.

That data is presented below, and I want you to carefully study the impact the shutdownhad on global temperatures, which are summed from all gathering stations to produce

the daily, monthly, whatever type record.

The actual depictions provided below show the very significant impact due to the suddendisappearance of these very relevant weather recording stations.


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Figure 6. The correlation between the loss of cold climate weather stations andtemperature increases is unequivocal.

As can readily be seen, global temperatures did not actually rise, but the input of a

significant number of cold weather climate stations did, in fact, cease due togovernmental issues. Ill leave it to you to actually compare these recorded results withthose of the broader global picture over the same period. I suggest the evidence is

unequivocal. Study it carefully. (10)

There is abundant additional information that calls into question the very key point of

data gathering, handling, etc. For example, the number of weather stations located in

urban areas, on asphalt parking lots nonetheless, inappropriately spaced from buildings the list goes on and on.

So, the fundamental network has some very significant flaws and inconsistencies with

respect to what used to be the Stephenson standards, which have somehow justmanaged to become unimportant. These flaws are never mentioned in any aspect of the

Findings report. That is unacceptable, unscientific, and a matter that needs to be placed

as a very high priority if credible temperature measurements are to be captured fromland-based systems.


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Warming of the climate system is unequivocal, as is now evident from

observations of increases of global average air and ocean temperatures,

widespread melting of snow and ice, and rising global average sealevel.

My response to this statement will deal with the widespread melting of snow and ice.Referring back to Figure 4, I suggest that melting glaciers and other warming related

tendencies should be expected, if we are indeed in a sustained warming period. The

evidence leading up to the last decade seemed to indicate that that is / was the case. Themost current evidence suggests we may be heading into a temperature reversal, if

conditions related to Figure 5 above continue.

As to the widespread melting of snow and ice, please study the graphic below which

clearly refutes that notion for the ice conditions on the continent of Antarctica. Much thesame can be said for the other polar region, that of the Arctic. Satellite imaging over

significantly spaced time spans over the Arctic so not support the claim of widespreadmelting of snow and ice. Again, I would emphasize that we are in a gradual warming

period, commenced at the end of the Little Ice Age. Nonetheless, the polar regions are

having a hard time catching up to the overall warming trends.

Figure 7.Antarctic sea-ice over the past 30 years shows no sign of significant variation above the mean.


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Figure 8. Carefully compare the magenta colored areas which represent theextent of Arctic sea ice at January 17, 1980, and January 18, 2009, respectively.As can be readily seen, the changes are minor, certainly in keeping with agradually warming global climate. The later image included snow cover over theremainder of the earth, while the earlier image focused just on the Arctic region.

(Univ. of Illinois)

The relatively minor changes of sea ice extent in the Arctic comes as no surprise whenone considers the data presented below. This actual record of temperatures in the Arctic,

including Greenland over the period 1938 2006 clearly shows that no long term upward

trends can be identified. In fact, multiple short term spikes of significance demonstrate

the unequivocally that anthropogenic causes are in no way responsible for Arcticconditions.


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Figure 9. Arctic temperatures 1938-2006, showing that temperatures in the late

1930s, and subsequent spikes around 1947and 1986 are significant departuresfrom the average. [After Monckton (11)]

Based on the data and evidence, it is entirely inappropriate to make the claim, as has been

done in this report, that Warming of the climate system is unequivocal, as is now

evident from observations of increases in global average air and ocean temperatures,

widespread melting of snow and ice, and rising global average sea level.


There is strong evidence that global sea level gradually rose in the 20th

century and is currently rising at an increased rate.

The report goes on to state Nearly all of the Atlantic Ocean shows sea level rise duringthe last 50 years with the rate of rise reaching a maximum (over 2 mm per year) in a band

along the U.S. east coast running east-northeast.

I respectfully disagree with Bindoff, et al (2007), and suggest that a more complete

statement about sea level rise would indicate that the average rise over the past 10,000years has been about 4 feet/century. During the entire 20

thcentury, seal level rose 8

inches, barely measurable. In the past three years sea level rise has not been statisticallymeasurable. (13)

Dr. Nils-Axel Mrner, recently retired as the Head of the Department of thePaleogeophysics and Geodynamics at Stockholm University, has been engaged in sea


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level research projects for many decades, and has been a vocal critic of the IPCC

modeling with respect to sea level conditions.

In 2000, Professor Mrner led a team of International Union of Quaternary Research

(INQUA) sea level specialists to investigate claims of rising levels at the Maldive Islands

in the Indian Ocean. "What we found was that sea levels were relatively stable between1790 and 1970, but that around 1970 there was a fall in sea levels of 20 to 30 cm, and

since then the levels have remained stable."

The contention that sea level is rising at an increased rate, due primarily to fossil fuel

consumption is simply not supported by the data. The following compilation speaks very

directly to this issue:

Figure 10: Global sea level measured by surface gauges between 1807 and 2002

(14) and by satellite between 1993 and 2006 (15). Satellite measurements areshown in gray and agree with tide gauge measurements. The overall trend is an

increase of 7 inches per century. Intermediate trends are 9, 0, 12, 0, and 12 inchesper century, respectively. This trend lags the temperature increase, so it predatesthe increase in hydrocarbon use even more than is shown. It is unaffected by the

very large increase in hydrocarbon use.[After Soon (3)]

While the overall trend for more than 150 years has been generally upward at 7 inches

per century, intermediate trends do appear, both higher and lower than this average rate.Yet, we hear over and over again that sea level is rising at an increased rate, and that is

exclusively due to fossil fuel consumption driving CO2 concentration into unacceptable


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levels. That, simply put, is another of the substantial misrepresentations of the science is

settled crowd.

Again, I must ask. What is the right CO2 concentration?

Let the data speak for itself.

************************************************************************

Item 6: From page ES-3, Observed Effects Associated with Global Elevated

Concentrations of GHGs

Ocean CO2 uptake has lowered the average ocean pH (increased

acidity) level by approximately 0.1 since 1750., and

From page ES-5,Projected Risks and Impacts Associated with Future

Climate Change

Ocean acidification is projected to continue, resulting in the reduced

biological production of marine calcifiers, including corals.

Given the closely related subject matter associated with each of these statements, I

choose to treat them conjunctively, so as to maintain the association.

Since, to my knowledge, there was no actual global network measuring pH around 1750,

I must state significant skepticism at that start date for your study. Upon reviewingDenman, et al, (16) it is seen that this statement is based on another of the multitude of

models that are simply not acceptable in providing a real sense of what this planet

actually does with its many complex, intricately woven systems.

The pH assessment proffered by Denman is no doubt linked to temperature models and

so I cite other research which states the following:

The persistence of coral reefs through geologic time when temperatures were as

much as 10-15C warmer than at present, and atmospheric CO2 concentrations

were 2 to 7 times higher than they are currently provides substantive evidencethat these marine entities can successfully adapt to a dramatically changing global

environment. [Idso (17)].

The research conducted by Craig Idso at the Center for the Study of Carbon Dioxide and

Global Change represents some of the most advanced, leading edge work available for

scientific review of ocean systems. Yet, your entire report is devoid of any of the researchresults that are available from this, as well as a number of additional credible sources.

As to actual data and a historical linkage to what is actually happening in this system, wehave the following:


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Figure 11. Calcification rate vs sea surface temperature (SST) rise. [After Idso (15)]

What is clearly indicated by the data is that calcification rates increase in a linear trend

over the temperature range studies. This result is in direct contradiction to models that

apparently do not account for even the simplest input into the system, temperature.

But, lets get back to the point of pH and acidification.

What does actual research show? Again, I cite a direct quote from Idso:

In another study, Pelejero et al. (18) developed a reconstruction of seawater pHspanning the period 1708-1988, based on the boron isotopic composition (

11B) of

a longlived massive coral (Porites) from Flinders Reef in the western Coral Sea of

the southwestern Pacific. Results indicated that "there [was] no notable trendtoward lower

11B values" over the 300-year period investigated. Instead, they say

that "the dominant feature of the coral 11

B record is a clear interdecadaloscillation of pH, with

11B values ranging between 23 and 25 per mil (7.9 and 8.2

pH units)," which "is synchronous with the Interdecadal Pacific Oscillation."

Furthermore, they calculated changes in aragonite saturation state from the FlinderspH record that varied between ~3 and 4.5, which values encompass "the lower and

upper limits of aragonite saturation state within which corals can survive." Despite

this fact, they report that "skeletal extension and calcification rates for the Flinders


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Reef coral fall within the normal range for Porites and are not correlated with

aragonite saturation state or pH."

Thus, contrary to acidification-alarmist claims that historical anthropogenic CO2

emissions have already resulted in a significant decline in ocean water pH and

aragonite saturation state, Pelejero et al.'s 300-year record of these parameters(which, in their words, began "well before the start of the Industrial Revolution")

provides no evidence of such a decline. What is more, and also contrary to what

one would expect from climate-alarmist claims of how sensitive coral calcificationrate is to changes in pH and aragonite saturation state, they found that huge cyclical

changes in these parameters had essentially no detectable effect on either coral

calcification or skeletal extension rates.

As a final note on this subject, I refer to a graphic from Idso that summarizes actual coral

growth characteristics at none other than the Great Barrier Reef, possibly the most

famous and widely recognized reef system in the world.

Figure 12. Great Barrier Reef Calcification Observations (1903-1922 vs 1979-1998)

This actual data compilation should shed some truthful light on what the oceanic system

has been doing while the recent warming period has been influencing global conditions.

I strongly disagree with the statements issued in this report with respect to ocean

acidification and the expected negative influence on marine calcifiers.


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Item 7: From page ES-4,Projections of Future Climate Change with ContinuedIncreases in Elevated GHG Concentrations


Discussion of this topic in the TSD is minimal, and where it is discussed, it is morefocused on Pacific conditions rather than Atlantic, and even in that case, virtually no

evidence is provided to support the contention above.

Since this is certainly a hot button issue among many citizens, it is very disconcerting

that the finding is totally unsupported by any data, when there is actually abundant data

contrary to the statement above.

I will take the liberty to include a brief discussion with data pertaining to rainfall, since

the finding does make mention of this issue, to the effect that due to Elevated GHGs

we should expect to see intensity of precipitation events. This intensity will,

theoretically, bring more flooding events, and other negative effects, all due to that nastyCO2 increase. Again, this statement is based on the modelers, who cant seem to

become satisfied with the actual historical data, to wit:

Figure 13: Annual precipitation in the contiguous 48 United States between 1895and 2006. U.S. National Climatic Data Center, U.S. Department of Commerce

2006 Climate Review (20). The trend shows an increase in rainfall of 1.8 inchesper century approximately 6% per century. [After Soon (3)]

As can be clearly seen in this fundamental graphic depiction of rainfall history in the

lower 48 states, the rainfall trend has been gradually increasing at about a 6% rate. Itwould seem to me that this would be a rather advantageous effect, rather than a


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detriment. I seriously doubt that this trend will suddenly shift to introduce greater

intensity of precipitation events.

Hurricanes are very significant weather events, and I do not want to minimize the

importance of being able to adequately anticipate trends that might be associated with

them. Climatologists have certainly been studying them for decades, if not centuries, andI wish them every success in advancing predictability of these sometimes very large

tropical systems.

However, this is not about hurricaneprediction. This is about, once again, blaming the

future hurricane events on emissions of CO2. As the data clearly indicates, this is not the

case, and it IS important to let the data do the talking. But first, take a look at anotherrelated severe storm event, the tornado. Is global warming responsible for more tornadic

activity in the United States?

Figure 14: Annual number of strong-to-violent category F3 to F5 tornados

during the March-to-August tornado season in the U.S. between 1950 and 2006.U.S. National Climatic Data Center, U.S. Department of Commerce 2006Climate Review (19). During this period, world hydrocarbon use increased 6-

fold, while violent tornado frequency decreased by 43%. [After Soon(3)]

I do not see much ambiguity in this data. Are tornados not severe storms that are

supposed to manifest in greater, more intense activity due to Global Warming?

Just exactly how did the findings committee arrive at the conclusion that more intense

storms will come about as a result of increased GHG emissions?


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Enough of rainfall and tornadoes, which of course happen frequently alongside

hurricanes. Lets see what the hurricane data tells us, given the fact that we have a very

substantial database, not just in this country, but worldwide.

Figure 15. Annual number of Atlantic hurricanes that made landfall between1900 and 2006 (20). Line is drawn at mean value. [After Soon (3)]

Firstly, as the data clearly shows, while we have been experiencing a material increase in

GHGs over the course of the past century, there is absolutely no discernable change in thenumber of Atlantic hurricanes making landfall.

Next, as to that projected increase in intensity being due to GHGs increasing.

Take a look at the graph below, and try to convince yourself that the intensity of

hurricanes is increasing, and then relate that background issue to CO2 emissions.

Here is what one of the primary providers of data for that graphic has to say about therelationship between anthropogenic global warming and what we observe in our

atmosphere:

It is a blatant lie put forth in the media that makes it seem there is

only a fringe of scientists who dont buy into anthropogenic global

warming. - U.S. Government Atmospheric Scientist, Stanley B.Goldenberg (20), of the Hurricane Research division of NOAA.


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Figure 16. Annual number of violent hurricanes and maximum attained windspeed during those hurricanes in the Atlantic Ocean between 1944 and 2006(21,22). There is no upward trend in either of these records. During this period,

world hydrocarbon use increased 6-fold. Lines are mean values. [After Soon (3)]

Based on the data just presented that provided a brief review of various characteristics

related to rainfall, tornadoes and hurricanes in this country, and surrounds, I strongly

disagree with the contention that


************************************************************************

Item 8: From page ES-4,Projected Risks and Impacts Associated with Future

Climate change

Increases in regional ozone pollution relative to ozone levels without

climate change are expected due to higher temperatures and weaker

circulation in U.S. and other world cities relative to air quality levels

without climate change.


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Due to these elevated ozone levels, we are expected to see increased risks with respect to

respiratory infection, aggravation of asthma, and premature death.

I am not in any way an expert on health issues, and I have no intention of attempting toargue this case on those merits. However, I do wish to challenge the notion that ozone

characteristics will be in any way influenced by increased GHG emissions.

Firstly, it should be abundantly clear by now why, in my opinion, based on multiple data

representations, greenhouse gas emissions have almost no effect on global temperature, at

least none that we can accurately measure, and have a high confidence we see GHGsignature in the data.

Ozone levels have been the subject of much study for many decades running. While somewould claim that that is because we managed to legislate a solution to the problem of

ozone depletion, I disagree, due to what the actual data shows.

First, take a look at ozone trends over the period 1963-2007.


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Figure 17. Total ozone at Mauna Loa 1963-2007. There is virtually no change inthe annual variance over the entire period. Measured in Dobson Units. [Courtesy

of NOAA, and Milloy (23)].

We can map ozone character just as we can map CO2 character, etc., and it certainly hasbeen mapped. NASA captured ozone character via the Total Ozone Mapping

Spectrometer (TOMS) satellite. The series of figures below show the seasonal cyclicnature of ozone concentration around the globe. Although not shown here, The datademonstrate an annual repeated pattern that has shown very little real variation over the

time it has now been monitored. So, the purported claim that we have solved the problem

is, frankly, nonsense. All those bad chlorofluorocarbons we expunged from theatmosphere by replacing Freon as a refrigerant with another chemical compound resulted

in approximately zero effect on the ozone hole, as it so religiously called.

Figure 18. Global Data from NASA Earth probe TOMS, spring 2000. Notice the two whiteozone holes at each of the poles. [After Milloy (23)]


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Figure 19. Global Data from NASA Earth probe TOMS, summer 2000. Notice the expanded

ozone hole at the south pole, and the disappearance of the hole at the north pole. [After Milloy

(23)]


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Figure 20. Global Data from NASA Earth probe TOMS, fall 2000. Notice the reappearance of

the two white ozone holes at each of the poles. [After Milloy (23)]


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Figure 21. Global Data from NASA Earth probe TOMS, winter 2000. Notice the expanded

ozone hole at the north pole, and the disappearance of the hole at the south pole. [After Milloy

(23)]

I can assure the reader who may be interested that the above seasonal patterns are

repeated each and every year, and that there is no discernable difference from the firstyears data captured by the probe (July 1996), to the last (December 2005), a total of

about 9.4 years running. Compare December 1996 with December 2003:

http://junkscience.com/Ozone/ozone_seasonal.html

Yet, we have this from scientific reporters from the BBC:

August 24, 2006

"Leading scientists in the United States say the hole in the ozone layer of the Earth's

atmosphere above the Antarctic appears to have stopped widening." (BBC)

I will conclude this section with a quote from Steve Milloy:

So there we have it. The conceptual "ozone layer" is not some delicate, static and fragilewrapping about the outer atmosphere but rather a dynamic and highly volatile

component, both created and destroyed by solar radiation. Ozone creation is a continuous

process, so we can not "run out" of stratospheric ozone. The more ozone (O3) isdestroyed, the more free oxygen radicals (O1) are available to bind with free oxygen (O2)

to create ozone (O3), the same applies with free oxygen (O2).


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Item 9: From ES-4,Projected Risks and Impacts Associated with Future ClimateChange

Risk to society, ecosystems and many natural Earth processes increases

with increases in both the rate and magnitude of climate change.

Climate warming may increase the possibility of large, abrupt regionalor global climatic events (e.g., disintegration of the Greenland Ice Sheet

or collapse of the West Antarctica Ice Sheet .

As has been the case is many of the previous sections, much of the TSD discussion is

wrapped around what I will term runaway modeling. This suggested nomenclature is

placed here because it is obvious that so much of what is being developed at greattaxpayer expense is based purely on conjecture, and very little on fact.

Lets focus for the moment on Greenland, and beginning with actual temperature history:

Figure 22. Average Summer Temperature record at Angmagssalik, Greenland

1892-2009. [After Michaels (24)]

As one reviews the context of Figure 21, it is inescapable that temperatures trended down

from around 1930 to about 1990, then trended up until the present. This pattern is not too


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dissimilar from the annual average U.S. temperature, except for the temperature range,

where we varied from about 51-55 degrees F, while Greenland varied from about 4-8

degrees C. In essence, they experienced almost twice the average summer temperatureextremes as we did for the entire year.

Angmagssalik is a southern Greenland weather station. Weather records dating back to1780 are available for southern Greenland, and the trend for the whole region on an

annual basis is similar to that for Angmagssalik, except for a minor detail. The highest

temperatures recorded in the southern region occurred around 1930, where the averageannual temperature was about 8.8 degrees C. The recent maximum occurred around

2001, with an average annual temperature of about 8.2 degrees C.

Figure 23. Southern Greenland Temperatures 1787-2007. [After Michaels (24)]

You need to know that there was no increase in sea level from the period 1820-1930, andfurther that the Greenland Ice Sheet was in no danger of disintegration during the

warmest time in its modern history. If current temperature trends (beyond dates in Figure

22) are any real indication, then I would anticipate that the ice sheet may well be

thickening at the present and into the future.


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In fact, Theres nothing very new going on in Greenland, according to Patrick

Michaels (24).

So, lets talk about Antarctica.

It actually appears that the ice is building up on the continent, as opposed to meltingaway, as some suggest. Lets be clear, the Western peninsula may be experiencing a

temporary loss of ice, but I would not expect that condition to persist.

The actual data shows us that the elevation change of the East Antarctic Ice Sheet has

been undergoing buildup since around 1995, and may have maxed locally around 2001.

This evidence is presented below, courtesy of Davis (25).

Figure 24. Antarctic Ice Sheet Elevation Change 1992-2003. [AfterMichaels (24), and Davis (25)].

The data and therefore the evidence implies that the East Antarctic Ice Sheet has been

building steadily since around 1993. A more conservative view would suggest the apex ofbuildup occurred 2001. In any event, it would appear that recent time history indicates

that ice at East Antarctic is in no imminent danger of disintegration.


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Escalating Ice Loss found in Antarctica: Sheets Melting an

Area Once Thought to Be Unaffected by Global Warming

-Washington Post, January 14, 2008

Postwriter Michael Kaufman (24, 26) was only too anxious to report just publishedresults by Eric Rignot and colleagues: Climate changes appear to be destabilizing vast

ice sheets of Western Antarctica that had previously seemed relatively protected from

global warming raising the prospect of faster sea-level rise than current estimates(27).

Rignot, et al.s study is at variance with all recent simulations of 21st

century climate inthe Antarctic, which predict a gain in ice because of increasing snowfall (24). The

increased snowfall would be anticipated due to warming temperatures, if temperatures do

indeed continue to rise.

Rignot, et al are not alone in the rush to get Antarctica to cooperate with their modeling.British researchers Andrew Shepherd and Duncan Wingham summarized six recent

studies of Antarctic ice and concluded that it is most likely that the East Antarctic icesheet is gaining about 6 cubic miles of ice per year, and the West Antarctic is losing

about 12, for a net loss of 6 cubic miles per year (24, 28). They do submit, however, that

the data are so poor that it is difficult to assume there have been any major changes in thepast decade.

Shepherd and Wingham also summarized recent findings for Greenlands ice andestimated a net annual loss of 25 cubic miles. When combined with the data from

Antarctica, the loss figures contribute to an annual sea-level rise of 0.01 inches per year,

an amount far too small to measure (24).

I present all of this as background in placing into full context the misinformation

circulating around the fears about sea level rise due to the supposed disintegration of the

ice sheets of both Greenland and Antarctica.

Now, lets take a look at some more of the actual data.


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Figure 25. Sea ice surrounding and including Antarctica [After Michaels (24)]

As can readily be seen, there is no evidence whatsoever that the ice mass on and aroundAntarctica is such that there should be any cause for concern as to its longevity. In fact,

shortly after the Kaufman News article it became known that the departure from the

norm was its largest ever on January 2008. Needless to say, that development got nopress whatsoever.

Based on the actual evidence as indicated above, I strongly disagree with the statement

"Climate warming may increase the possibility of large,

abrupt regional or global climatic events (e.g.,disintegration of the Greenland Ice Sheet or collapse of

the West Antarctica Ice Sheet .)

That statement is utterly nonsensical.


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Item 10: Actual data indicates a disconnect between CO2 concentration and

temperature, refuting the assumption of global warming due to CO2.

(Author Comment)

If there has been one single dominant theme in your findings, it has been that CO2 is

the single most hazardous and endangering substance man has ever encountered. Studyafter study and model after model point to this colorless, odorless, tasteless gas as the

primary driver of temperature on this planet.

But, what does hard, credible data indicate with respect to this purported linkage?

Figure 26. Arctic-wide surface temperature anomalies 1878-2001. [After Soon (26)].

Over the time range monitored, the data clearly shows that there is virtually no

correlation between Arctic-wide surface air temperature and CO2 concentration. Otherstudies have demonstrated a similar result.

Some have attempted to place great weight on ice core evidence linking temperature andCO2 concentration, and I have reviewed multiple such studies. However, other

researchers [Jaworski, (30)] reach a different conclusion regarding this suggested linkage:

The man-made climate warming hypothesis is based on the assumption thatmainly through burning fossil fuels the pre-industrial level of CO2 of about 290

ppmv has increased by about 30%. However this assumption is at odds with

direct measurements of CO2 over the past 200 years. Furthermore recentestimates of pre-industrial levels of CO2 have been largely based on analyses of

polar ice cores which do not fulfil the essential closed-system criteria required forreliable reconstruction of the pre-industrial and ancient atmosphere. (30)


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Many researchers have demonstrated, in my opinion unequivocally, that the absolute

primary driver of temperature on this planet happens to be the center of our solar system.I have yet to locate any source that can dispute the evidence that the sun is the primary

driver of global temperature. In support of this claim, please note the following figure.

Figure 27. Arctic surface air temperature compared with total solar irradiance asmeasured by sunspot cycle amplitude, sunspot cycle length, solar equatorial

rotation rate, fraction of penumbral spots, and decay rate of the 11-year sunspotcycle (29,31). Solar irradiance correlates well with Arctic temperature, whilehydrocarbon use (32) does not correlate. [After Soon (3)]

In my opinion, Willie Soon of the Harvard-Smithsonian Astrophysics Center has

compiled in this single graphic the essence of the very strong counter argument to any

who would suggest that CO2 emissions from fossil fuels represent the primary driver ofglobal warming. That correlation, as suggested by Marland, et al, of Oak Ridge National

laboratory (co-contributors to this graphic), simply does not exist. Based on multiple lines

of evidence, certainly including that above, I strongly disagree with the hypothesis thatgreenhouse gas emissions are responsible for global warming.


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CONCLUSIONS

In the broadest sense, I would conclude that the political drivers behind the wheelof this findings vehicle have completely overwhelmed any sense of scientific

support, or lack thereof, for the myriad of complex conclusions drawn and

implied to endanger the citizens of this country.

Given the overarching relationship to the current administrations drive toremake the American economy and industry, I strongly suspect that the EPAAdministrator is doing her level best to please the President. However, thats no

excuse for the blatant disregard for multiple lines of factual evidence that

significantly contradict finding after finding in this nearly 200 page manifesto.

As has been strongly suggested in the memo leaked from the White House, (butco-authored by multiple reviewing agencies), making the decision to regulatecarbon dioxide under the Clean Air Act for the first time is likely to have serious

economic consequences (emphasis mine) for regulated entities throughout the USeconomy, including small businesses and small communities.

Given that the DELIBERATIVE -ATTORNEY CLIENT PRIVILEGE memo wasapparently submitted by the Office of Management and Budget, I would assumethey have a fairly tight grip on the economic implications related to your and the

administrations objectives of cleaning up our environment.

Having reviewed every page of the Proposed Endangerment Finding, I canonly conclude that either you are not competent to manage the scientific input of

your agency, or you are fully cognizant of the lack of credibility of many of the

findings, and have chosen to ignore open scientific protocol and the invitation ofmultiple experts outside the EPA and the enclave of the CCSP. In my opinion,

that is a very serious mistake.

With all due respect to the many scientists who may have been involved insupport of this Proposed Finding, and unable to convince you that your path

is significantly errant, I submit that you have already irresponsibly spent millionsof dollars of taxpayer money in an effort to completely subvert good science, and

you are simply failing in your fiduciary responsibility to the American public.

I am not well informed as to the scientific makeup of the EPA, but it is obviousthat many of the findings included in the document were heavily influenced bythe IPCC, which given the discussion included in the Introduction above, I

suggest significantly tainted your opinion, and virtually eliminated objectivity in amajority of the issues reviewed.


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RECOMMENDATIONS

1. First and foremost, I strongly recommend that you shelve this document, andtake a good, long look at comments incoming from especially the group I

identified in the Introduction.

2. Secondly, once you have seen those comments, I strongly recommend youdeploy that group of scientific leaders in multiple capacities to assist you and

your staff scientists in endeavoring to actually acquire and properly processthe vast database necessary for comprehensive review.

3. Thirdly, I propose that you take a leadership role in redefining priorities inyour agency, such that you address real, dangerous, actual pollutants that have

the potential to do real harm to American and World citizens. You know what

they are, and you know, by virtue of the fact that CO2 is absent from yourdefined list of pollutants, where your priorities should be refocused. You need

to advise the American populace that CO2 is not now, has never been, andwill never become a pollutant of any kind.

4. I recommend that you do everything in your power to insure that near termCongressional hearings related to HR 2454 will include testimonies frommultiple highly qualified experts from the list I provided in my Introduction,

who will be only too happy to fully open the debate related to gaining a

clearer understanding of climate science, global warming and all related

subjects.

5. I recommend that if you find you cannot comply with Recommendation 4above, that you resign from your position, and ask the President to look againat the American landscape in an attempt to find an individual who will, in fact,

look out for the actual interests of American citizens, as related to the true and

necessary protection of Her Environment, as opposed to seeking a Politicalsolution destined to fail and materially undermine Her very economic being.

Respectfully submitted,

Dennis Hedke

Dennis E. Hedke


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REFERENCES

1. United States Senate Minority Report, U.S. Senate Environment and Public

Works Committee, Minority Staff Report (Inhofe),

http://www.senate.gov.minority/ , December 11, 2008.

2. Horner, C.,Red Hot Lies, Regenery Press (2009), p 295.3. Soon, W., et al,Journal of American Physicians and Surgeons, 12, 79-90, 2007

4. Evans, David, The Australian, No Smoking Hot Spot, July 18, 2008.

5. Jansen, E., J. , et al., Palaeoclimate.In: Climate Change 2007: The Physical

Science Basis. Contribution of Working Group I to the Fourth Assessment Report

of the Intergovernmental Panel on Climate Change [Solomon, S., D. Qin, M.

Manning, Z. Chen, M. Marquis, K.B. Averyt, M. Tignor and H.L. Miller (eds.)].Cambridge University Press, Cambridge, United Kingdom and New York, NY,

USA.

6. Segalstad, T., Proceedings of the Third International conference on ClimateChange, 2009, www.CO2web.info

7. Georg-Beck, Ernst, 180 years of Atmospheric CO2 Gas Analysis by ChemicalMethods,Energy & Environment18 No. 2, 2007

8. Keigwin, L. D. (1996) Science 274, 1504-1508.

ftp://ftp.ncdc.noaa.gov/pub/data/paleo/contributions_by_author/keigwin1996/

9 Christy, John,Earth Science Systems Center, University of Alabama Huntsville,10. McKitrick, R., as cited in Red Hot Lies, Horner, Regenery Press 2009.

11. Monckton, Christopher, Would CO2 Emission Cuts Save Arctic Ice and Reduce

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