June 30, 2009

By: Calvin B. Parnell, Jr. PhD and P.E.

 

Congress and EPA are Preparing a Major Tax on GHG Emissions.

Congress just passed the “Clean Energy”, “Green Jobs”, “Climate Change”, “Global Warming”, “Cap and Trade”, or “Green House Gas Bill” depending upon who is talking. What is in this bill and why do those who support it want it passed by the Senate this fall? It is confusing when one reads the news papers and watches the news. I am going to do my best to explain in simple English why so many in the media and elected officials have chosen the path of having the U.S. do the following:

1.      Redefine CO₂ as an air pollutant to be regulated under the Clean Air Act (CAA). It is not an air pollutant (as defined by the CAA) and has never been regulated under the authority of the CAA although many environmentalists have labeled green house gasses (GHG) as air pollutants for years. (Why now?)

2.      Congress is asked to approve the Waxman-Markey bill consisting of more than 1000 pages that mandates industries to significantly reduce GHG emissions by 2020 and 2050. (Why?)

 

The answer to these two questions is relatively simple:

Politicians and media subscribe to the theory that global warming is caused by increasing concentrations of CO₂ in the atmosphere and we in the U.S. must lead the way by reducing GHG emissions.

 

·         The media has helped to convince the public that this theory for global warming (climate change) is irrefutable. (It is not!)

There are computer models that predict catastrophic events in the future (2050) if the CO₂ concentrations continue to rise.

·         The climate change alarmists want the U.S. to take a leadership role in reducing our emissions of GHG, no matter the cost and irrespective of whether it will lower the concentrations of CO₂ in the atmosphere that they believe is causing global warming.

 

One possibility of why we have so many names for the Waxman-Markey bill is that politicians want to generate as much support as possible from the voting public. Who can be against a “Green Jobs”, “Clean Energy”, preventing “Climate Change” or reducing emissions of GHG? Using the different descriptions of this bill can result in confusing the public so that no one really knows the justification. There is a reason for creating the confusion. The media propaganda has been relatively successful in convincing the public and many politicians (both republicans and democrats) that we are experiencing global warming. The global warming theory is as follows:

 

Increasing concentrations of CO₂ (carbon) in the atmosphere as a consequence of burning fossil fuels causes the global warming.

 

Is global warming caused by increasing concentrations of CO₂?

 

EPA researchers Alan Carlin and John Davidson recently received publicity because they produced a report that was not forwarded to the high level group deciding the “Endangerment Findings” within EPA.  (It was shelved by his supervisor and they were told not tell anyone what was in their report.) Their report suggested that EPA should consider reevaluating the science supporting the global warming theory. These actions fuel a perception that there are those in EPA who do not want anyone to question the science of global warming. Is it possible that this theory is incorrect?

 

On April 17, 2009, the EPA Administrator responded to the court mandate. The “Endangerment Findings” were that GHGs “in the atmosphere do threaten the public health and welfare of current and future generations” and GHG emissions from new motor vehicles pose a threat of climate change.

 

A request for public comment was issued allowing 60 days for the public to respond. A number of requests to extend the public comment period on “Endangerment Findings” were rejected by EPA. Why? Is it possible that EPA did not want additional public input on this finding? It is a very significant finding and there is some question whether this finding is justified. The administrator’s finding is supportive of the Waxman-Markey bill. There is a perception that the bill’s supporters want to generate revenue by taxing emitters of GHG and are using the emotional support of the global warming which is supposed to be caused by increased concentrations of CO₂ in the atmosphere as the justification.  

 

The magnitude of mandated reductions of GHG emissions is enormous. According to EPA’s emissions inventories (April 15, 2009), we emit a total of less than 0.15 billion tons of “real air pollutants” (SO₂, NO_x, NMVOC, CO). The Waxman-Markey bill is mandating that we reduce our emissions of GHG from a projected 8 billion tons in 2020 to 6 billion tons. The reduction of 2,000,000,000 tons of GHG is 13 times more than the total emissions of real air pollutants! Real air pollutants are regulated under the authority of the CAA to limit public exposure to concentrations that will not cause health effects “with an adequate margin of safety”. The range of CO₂ concentrations that are of concern relative to global warming will not cause health effects according to EPA’s technical support documents for “Endangerment Findings” which states the following:

“Current ambient concentrations of CO₂ and other GHGs remain well below published exposure thresholds for any direct adverse health effects, such as respiratory or toxic effects.”

 

What happens if manufacturing plants, power plants, and cars and trucks in the U.S. reduce our emissions of GHG by 2 billion tons as prescribed by the Waxman and Markey Bill (H.R. 2454)?

• Will China or India reduce their emissions of GHG? (Probably not!) It is being reported that the number of coal fired power plants being built and put in production in these two developing countries will exceed our mandated reduction of GHG by 2020. China and India have an expanding manufacturing industry and need the relatively inexpensive electricity from coal to compete with the U.S.  Their coal fired power plants will almost assuredly not have the pollution controls that US plants have as mandated by the Clean Air Act.
• What happens if we reduce our GHG emissions and China and India increase their emissions of GHG by the same (or more) than we reduce. Will the rate of increased concentrations of CO₂ in the atmosphere be reduced? (The answer is NO! If this is the case, the justification of the Waxman-Markey bill based upon global warming does not “hold water”.) When someone brings this to the attention of the public, the response of the bill’s supporters is “this is a jobs bill.” In reality, it is a TAX Bill!

The cost of reducing GHG emissions by 2,000,000,000 tons could be very expensive. Unlike current controls for criteria pollutants, there are no abatement strategies for reducing CO₂ leaving a smokestack. The most logical and effective method of reducing emissions of CO₂ are to shut down coal fired power plants and limit the vehicle miles driven. Shutting down coal fired power plants will make it difficult to meet the public demands for electricity in the future and will likely increase the costs. There are pundits who are stating that the projected cost per person or family are small but do they really know how to calculate these costs?

What if this whole global warming concern caused by increased concentrations of CO₂ is based upon “junk” science? Is it possible that some other cause could be responsible for the periodic increases in global temperature? What if the computer models predicting disasters in 2050 are WRONG? The following is likely if our elected senators pass this bill this summer or fall:

• If CO₂ concentrations do not control the warming of the globe and we pass the Waxman-Markey bill, we will be reducing GHG emissions with no impact on global warming. It is possible that our country will lose manufacturing industries seeking less expensive labor and energy in other countries.

·         Thousands of reputable scientists, me included, remain convinced that it is possible that the science in support of global warming is not sound.

•  
  • There are reports that the increase in temperatures estimated by the global warming researchers preceded the increase in CO₂ concentrations.  This suggests that the increase in CO₂ concentrations could have been the result of increasing temperatures rather than CO₂ concentrations being the cause of the increased temperatures.
  •  There are reports that temperatures higher than what we have been experiencing recently occurred in the past when the CO₂ concentrations were much lower. How could this be? If the global warming theory is correct, CO₂ concentrations cause the warming. If we had low concentrations of CO₂, there should have been low temperatures.

The concept of justifying this bill because a computer model predicts disasters in 2050 is problematic. Computer models are often wrong.

Computer models are woefully inadequate to properly model a system as complex as a planetary climate system. Global warming theory relies heavily on results of computer models designed to predict the Earth’s climate. The results of computer models to forecast near term weather patterns are often incorrect.  Consider that the justification of this bill is in part an assumption that modelers can predict 40 years of climactic variability.

It is likely that the elected officials voting for this bill will not be around in 2050. Who do we hold accountable if they are not around and especially if they put this burden on us and our grandchildren with no ultimate benefit? This bill robs future generations of freedom and binds them to a tax bill with no opportunity to provide input. We used to call this taxation without representation. At the very least, there should be an expiration date or a sunset provision on this legislation which would require evaluation for considering of renewal in the future.

The “cap and trade” feature of the Waxman-Markey bill authorizes EPA to limit GHG emissions. Permits would be issued to authorize a certain level of GHG emissions. Fees would be accessed per unit of GHG emissions with a corresponding cap or limit in place. There are opportunities for the emitting source to seek “off sets”. “Off sets” are displaced CO₂ emissions from fossil fuels that are a consequence of the source sponsoring renewable green energy projects. For example, a coal fired power plant can sponsor a wind farm in a developing country. The CO₂ that would have been generated from equivalent power generation using fossil fuels could be used by the U.S. power plant to meet its cap.

It seems that many of those who should be concerned are trying to soften the impact of the bill rather than doing their best to defeat it. We live in changing times and difficult decisions are being made at a very fast pace. I do not believe Waxman-Markey bill will benefit this country. Global warming or global cooling will occur irrespective of our actions to reduce GHG emissions. Climate changes are much more difficult to predict with computer models than some would have you believe. The hypothesis that global warming (or cooling) is consequence of mans’ activities remains a hypothesis.

More to come.

Previous blog: Global Warming and Green House Gases (GHG) - What is the problem?

 

Dr. Parnell is a Regents Professor in the Department of Biological and Agricultural Engineering and is the Cotton Chair. He has been conducting research on Air Pollution Engineering for over 40 years. He has been teaching undergraduate and graduate classes in air pollution engineering for more than 18 years.

by Dr. Calvin B. Parnell, Jr.

The following are specific comments on GHG reporting for fugitive emissions from cattle feed yards surfaces:

• EPA specified in the proposed GHG emissions reporting rule that the mandatory reporting in 2010 should only include CH₄ and N₂O from manure management. CH₄ from enteric fermentation was not included in the mandatory reporting proposal. This action can be interpreted as EPA deciding that enteric fermentation will not be regulated.  The justification for excluding reporting emissions of CH₄ from enteric fermentation of beef cattle emissions is not clear and should be addressed.  The most likely control for this source is reducing the number of cattle on feed which may be politically unacceptable. According to the EPA emissions inventory estimates, 17% of the total agricultural emission of CH₄ is attributed to beef cattle enteric fermentation. This is in contrast to less than 0.5% of the total U.S emissions of CH₄ from manure management. If the goal is to significantly reduce GHG emissions to slow the global warming process,  there is very little benefit to  requiring all beef cattle feeding operations to report their emissions of CH₄ from manure management

·         Likewise, the magnitude of the N₂O emissions in units of CO₂e from manure management for beef cattle feed yards are very small relative to the total U.S. emissions of N₂O (2.2%) and relative to the total emissions from all agricultural sources (3%). (These emissions take into account the global warming potential of 310.) The determination of emission factors for N₂O for fugitive sources is very difficult. The protocol of measuring concentrations downwind, subtracting upwind (background) and calculating fluxes will not work for this species. Background N₂O concentrations are reported to be 319 ppm. Based upon our engineering calculations, the downwind concentrations of N₂O will be approximately 20 to 30ppb (0.02 to 0.03ppm). The measurement uncertainty associated with the resulting emission fluxes (factors) is too large.

 

Calculations: (Reference EPA. 2009. Emissions Inventories)

GHG emissions of CH₄ with a global warming potential of 21 using 2005 as the reference year:

1.      Total emissions (CO₂e) from all sources of CH₄ in the U.S. in 2005= 562 million metric tons (10⁶ tonnes);

2.      Total agricultural emissions (CO₂e) from all sources of CH₄ in 2005= 186*10⁶ tonnes;

3.      Total enteric fermentation emissions (CO₂e) from all sources of CH₄ from all beef cattle on feed yards in the U.S. in 2005=98*10⁶ tonnes

4.      Total beef cattle manure management CH₄ emissions (CO₂e) from all beef cattle on feed yards in the U.S. in 2005=2.4*10⁶ tonnes

 

GHG emissions of N₂O with a global warming potential of 310 using 2005 as the reference year:

1.      Total emissions (CO₂e) from all sources in the U.S. in 2005=316*10⁶ tonnes)

2.      Total agricultural emissions of N₂O (CO₂e) from all agricultural sources in 2005= 223 million metric tons (10⁶ tonnes)

3.      Total manure management beef cattle emissions (CO₂e) from all sources of N₂O from all beef cattle on feed yards in the U.S. in 2005=6.5*10⁶ tonnes

 

Table 1. Mass fractions of GHG emissions in units of CO₂e from beef cattle operations. (Reference EPA. 2009. Emissions Inventories)

 

 

·         EPA selected a mandatory reporting threshold of 25,000 metric tons (10³ tonnes) for all sources. This threshold was justified using an economic approach. The data used to calculate the costs included many assumptions and estimates that are questionable. With the EPA’s published emissions inventory (April 15, 2009), an alternative means for determining mandatory reporting thresholds is available and could provide a more logical means for determining which facilities should be required to report.

·         The regulation of GHG emissions is limited to emissions inventories (annual emissions). The goal is to find ways to reduce annual emissions of GHG to slow down the increase in CO₂e to prevent climate change or global warming. Forcing small emitters to report their emissions when reduction of their GHG emissions would have little impact on the increase in the concentration of CO₂e in the atmosphere is illogical.

·         Using 2005 as the base year, the total GHG emissions from all sources were 7,110*10⁶ tonnes. The total mass of CO₂e emitted by cattle feed yards of CH₄ and N₂O were (2.4+6.5)*10⁶ = 9 million tonnes. It is assumed that CO₂ emitted by cattle feed yards will not be regulated because it is CO₂ that has been sequestered in the feed. Hence, only emissions of CH₄ (562*10⁶ tonnes) and N₂O (316*10⁶ tonnes) from manure management must be reported. These emissions amount to only 0.43% and 2.1% of the total emissions of CH₄ and N₂O emitted, respectively.

·         The 25,000 tonnes mandatory emission threshold for reporting relative to the total mass of GHG emitted in 2005 is very low threshold. The reductions by 2020 mandated by the H.R.2454 are approximately 2 billion tons (2*10⁹ tonnes). 25,000 tonnes are less than 0.2% of the total reduction mandated by 2020. Why has EPA listed such a low threshold? The many “small emitters” of GHG will be spending much effort to comply with no net benefit to the goal of reducing the atmospheric concentration of CO₂e.

·         The number of cattle on feed yards that would result in required mandatory reporting was listed as 89,000 head. This number is incorrect. Using the data in table 1 and the reported 14 million (10⁶) head as the total number of head on feed yards in the U.S., the 25*10³ tonnes corresponds to 37,600 head not 89,000 head.

 

Calculations: (Reference Table 1)

Beef Cattle Manure Management Emissions (BCMM)

BCMM = [2.4 (CH₄) + 6.5 (N₂O)]*10⁶tonnes/year = 9*10⁶tonnes/year

Emission Factor (EF) = 9*10⁶tonnes/year/14*10⁶ head of cattle on feed

EF = 0.665 tonnes/hd-yr

Number of head on feed to emit 25*10⁶tonnes = 25,000/0.665= 38,000 head on feed.

 

Summary of Comments:

 

1.      GHG emissions should not be regulated as a “regulated” pollutant under the CAA. There are no direct health effects associated with breathing concentrations of CO₂e in the atmosphere. The costs in terms of Title V permitting and associated Title V fees would be overwhelming.

2.      The magnitude of manure management (CH₄ and N₂O) CO₂e emissions from cattle feed yards is very small relative to other sources. It is unlikely that any significant reductions of GHG will be obtained from regulating this source.

3.      The magnitude of enteric fermentation (CH₄) CO₂e emissions from cattle feed yards is significant and is not included in the mandatory reporting. Environment special interests will insist that this source be regulated. This should be addressed by EPA in the proposed rule. How will belching and passing gas be regulated? It seems that the only method to reduce this source of GHG will be to limit the number of cattle on feed yards. This may be unacceptable to the public.

4.      The method used to have all sources emitting 25*10³ tonnes required to report GHG emissions is flawed. It is recommended that some means of exempting small sources of GHG using EPA’s emissions inventories would be a better method. 25*10³ tonnes of CO₂e is less than 0.0000035% of the total GHG emitted in 2005.

5.      The mandatory reporting threshold for cattle on feed yards should be corrected. It is not 89,000 head.

(more…)

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