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Wake up everybody. The panic by Congress and EPA over Global Warming is going change the way we live and it is not justified!

 

By Dr. Calvin B. Parnell, Jr.

Introduction:

As a consequence of recent actions taken by the courts and EPA, a natural occurring gas in nature, carbon dioxide (CO₂), will be likely be a regulated pollutant under the authority of the Clean Air Act (CAA). This action was initiated by environmentalists, lawyers, politicians, and some misguided scientists. A Supreme Court decision in April, 2007 forced EPA to determine whether (or not) emissions of greenhouse gases (GHG) cause or contribute to air pollution or whether the science is too uncertain to make a reasoned decision. 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. These findings and the associated technical support documents are open for public comment for 60 days following publication in the Federal Register. If the endangerment findings are not changed by the EPA administrator following a review of public comments by EPA, CO₂ will be regulated as an air pollutant under the CAA. If this occurs, it will be a mistake. The CAA was not designed to regulate non-pollutants.

 

In a related action, Congress is considering a law that will mandate reductions of GHG from sources in the U.S. by 2020 and beyond. (On May 21, 2009, the House Energy and Commerce Committee passed this law by a vote of 33 to 25. HR 2454 is now being considered by the House and Senate.) In contrast to EPA’s Endangerment Findings, the American Clean Energy and Security Act (ACESA) sponsored by Chairmen Waxman and Markey is a law. If passed, the reductions of GHG specified in ACESA are “mandated”. This law provides EPA with the enabling authority and mandate to limit emissions of GHG just as EPA regulates SO₂, NO_x, CO, and VOC emissions under the authority of the CAA.

 

Rules vs. Laws

The difference between proposed EPA rules and regulations and law are major. The differences are subtle and not fully understood by the public. There is no public comment period for ACESA as we have for EPA’s endangerment findings. The ACESA is a law just like the CAA. Changes are made by having Congress amend the law.

 

There were several GHGs including in EPA’s endangerment findings. CO₂, N₂O, and CH₄ are the three most prevalent GHGs. None of these are classified as air pollutants at this time. A concept of determining the equivalent mass of CO₂ per unit mass of the non-CO₂ GHG is being used for reporting and regulatory purposes. For example, one pound of natural gas (CH₄) emitted to the atmosphere is equivalent to 21 pounds of CO₂ and one pound of N₂O emitted to the atmosphere is equivalent to 310 pounds of CO₂. EPA published the annual emissions of all sources of GHG emissions in the U.S on April 15, 2009. All GHG emissions are listed in units of CO₂ equivalents (CO₂e).

 

On April 10, 2009, EPA proposed a rule to require U.S. sources to report all GHG emissions from their operations by a specified date in the future. It is anticipated that this action is a prelude for regulation and enforcement. (The comment period for this proposed rule ends June 9, 2009.)

 

 

The following is a summary of what is happening right now:

 

April, 2007 – The Supreme Court decision forced EPA to determine whether (or not) emissions of greenhouse gases (GHG) cause or contribute to air pollution.

 

April 15, 2009 - EPA published the inventories of annual emissions of CO₂e and conventional CAA air gaseous pollutants for all sources in the U.S.

 

April 17, 2009 - EPA has proposed that CO₂e be regulated as a pollutant under the CAA with the Administrator’s endangerment findings.

 

May 21, 2009 - The House Energy and Commerce Committee passed HR 2454 by a vote of 33 to 25. It is currently being considered by the House and Senate. Very specific limits on annual U.S. emissions of CO₂e are being placed on all sources by 2020 and 2050. The limiting of annual emissions of a pollutant or a proposed pollutant is in effect regulation of that pollutant!

 

Should CO₂e be treated as an air pollutant under the CAA?

The CAA was passed by Congress in 1970. It was the law that authorized the formation of the EPA. The conventional air pollutants regulated under the authority of the CAA were selected because of potential health and welfare effects. The definition of air pollution (Cooper and Alley, 2004) is as follows:

 

“Air pollution is the presence in the outdoor atmosphere of any one or more substances or pollutants in quantities which are or may be harmful or injurious to human health or welfare, animal or plant life or property, or unreasonably interfere with the enjoyment of life or property including outdoor recreation.”

The CO₂e concentration has risen from the pre-industrial concentration of 278ppm to 379ppm in 2005. The global concentration of CO₂e is the result of CO₂e emissions from sources in countries all over the world not just sources in the U.S. The U.S. cannot force other counties to reduce their GHG emissions. If we reduce our CO₂e emissions by one billion tons, will India and China do the same? (It is unlikely that developing countries will voluntarily reduce their emissions of GHG. Most of these developing countries do little to reduce emissions of conventional air pollutants. In contrast, the U.S. through the efforts of EPA and State Air Pollution Regulatory Agencies (SAPRA) have been successful regulating and enforcing limits of air pollution emission rates from all sources, protecting public health and welfare. Are GHG air pollutants?

 

The following is stated in the EPA technical support documents for Endangerment Findings:

“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.”

 

 GHG (CO₂e) are not air pollutants! All living creatures inhale and exhale CO₂. We in the U.S. do not breathe the conventional CAA pollutants (SO₂, NO_x, CO, and NMVOC) except in concentrations regulated by EPA and SAPRA at levels that protect public health and welfare with “an adequate margin of safety”. The concentrations of CO₂e in the ambient air are not being labeled air pollutants to be regulated under the CAA because of health and welfare effects. The justification of this action is the belief that the world is facing a crisis. There are scientists, politicians and many citizens (global warming advocates) who believe the following climate change theory:

 

1. The Globe (world) is warming.
2. This warming is caused by increasing concentrations of CO₂e in the atmosphere. 
3. The causes of these increased concentrations of CO₂e are the burning of fossil fuels (coal, natural gas, and petroleum).
4. We in the U.S. must act now to reduce emissions of CO₂e or it will be too late. Major calamities in 2050 and beyond are being predicted by scientists using sophisticated models.

For those who believe in Global Warming caused by increased concentrations of CO₂e in the atmosphere, the only solution is a reduction the world’s emissions of CO₂e not just reducing CO₂e emissions from U.S. sources. These advocates believe that global warming caused by global concentrations of CO₂e is a fact not a theory and is irrefutable. Some refer to this group as alarmists. Statements have been made by those who support ACESA that we will achieve the reductions in CO₂e annual emissions in the Waxman/Markey bill with a new clean, green industry with many new jobs and a minimum of increased costs for the consumers of electricity and petroleum products.

The concerns of those who question the alarmist’s position are that the catastrophic projections are too dependent on inadequate computer models and that the U.S. will lose jobs, increase the costs of energy (electricity, methane, gasoline and diesel) and lose manufacturing capabilities to other countries. Irrespective of whether you accept Global warming as a fact that can not disputed or you question the science and model predictions, the following must be considered:

 

1. Human exposure to CO₂ concentrations in the range of 200 to 500ppm will have no impact on public health or welfare. GHG should not be regulated as an air pollutant!
2. If we in the U.S. reduce our emissions of CO₂e by the estimated 2 billion tons by 2020 to comply with the mandated reductions in the American Clean Energy and Security Act (ACESA) sponsored by Chairmen Waxman and Markey, will it change the global concentration of  CO₂e? The answer is NO!
3. There is nothing we in the U.S. can do to force developing countries such as China and India to stop building coal fired power plants that provide reliable, inexpensive electricity for their rapidly expanding manufacturing operations. There are reports that China will be adding 300 to 400 1000MW coal fired power plants in the near future. One 1000MW coal fired power plant emits 9 million tons of CO₂e per year. 300 will emit 2.7 billion tons per year. (This is more than our proposed reductions by 2020.) If other countries do not reduce their CO₂e emissions, will the world’s concentration of CO₂e stop increasing? The answer is NO!  
4. The new law (ACESA) is careful to set goals or benchmarks but unclear on how to achieve the mandated reductions. Reducing emission rates of CO₂e is not simple. We have developed mature and effective abatement systems for all of the conventional CAA pollutants (PM, SO₂, NO_x, CO, and VOC) but we have no proven abatement strategy for CO₂e other than shutting down power plants and reducing allowable vehicle miles driven.
5. According to EPA’s publication on emission inventories in April of this year, the magnitude of annual emissions of CO₂e from all sources in the U.S. relative to the total emissions of SO₂, NO_x, CO, and NMVOC in 2005 is 60:1. In other words, we emit more than 60 pounds of CO₂e for every pound of air pollutants causing heath effects. Is EPA equipped to take on this responsibility?
6. The bench marks set by ACESA are mandated and can not be changed other than by seeking amendments to ACESA in the future. What if we can not meet the mandatory reductions, is it possible that EPA will be forced to shut down plants? These are not targets such as miles-per-gallon for new vehicles that are routinely not met.
7. If Congress passes this law, we are stuck with it. It is possible that with the option of using “Cap and Trade with Offsets”, we will be having our U.S. coal fired power plants funding wind farms in developing countries to continue to produce inexpensive electricity from coal.

More to come.

 

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 that 18 years.

 

2 Comments »

1. 

   Excellent and well written article! Genius! Now perhaps everyone will see the light!

   Comment by Russell — May 29, 2009 @ 3:17 pm

2. 

   Hopefully, another wake-up call. I would have a problem funding
   wind farms in China!

   Comment by Ralph — May 31, 2009 @ 4:34 pm

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