Reengineer: to reorganize the operations of (an organization) so as to improve efficiency

The Trump Administration has begun a comprehensive reengineering effort in the federal Executive Branch agencies. The agencies of concern regarding climate change include US EPA, NASA and the Departments of Energy, Interior and Commerce. The focus of the effort will be on societal and economic value added and will concentrate on current and potential future value.

The early focus at US EPA will be on the 2009 Endangerment Finding and the Powerplant Rule, both of which impose current and future societal and economic costs. EPA’s vehicle emission standards represent a virtual mandate for a transition from fossil fueled vehicles to electric vehicles. Many classes of vehicles are not commercially available as EVs. EVs are also significantly more expensive than their fossil fueled equivalents, even with substantial federal subsidies.

The Powerplant Rule would require coal and natural gas generators to equip both existing and new generators with systems capable of collecting and later storing 90% of the CO2 they emit. EPA has declared that these CCS systems are Best Available Current Technology and are commercially available, though there has been no successful demonstration of CCS at that capture percentage. It has been estimated that CO2 capture at that level would impose a 25-40% parasitic power consumption penalty on powerplant net output, thus dramatically increasing power cost.

The early focus at the Department of Energy will likely be on the Office of Energy Efficiency and Renewable Energy. DOE has advocated for “all-electric everything” for decades and has distorted building energy efficiency by focusing on efficiency at the site of use, rather than on full cycle efficiency. DOE has also conducted numerous renewable generation R&D programs. DOE would also have been the lead agency regarding building sector decarbonization.

The Department of Interior is responsible for federal lands, including land use for oil & gas exploration and production as well as for installation of renewable generation facilities. DOI has acted to exclude large areas of federal land from oil and gas activity, coal mining, uranium mining and other mineral mining activities.

The Department of Commerce is home to NOAA, which has been heavily involved in collection and analysis of near-surface temperature measurements in cooperation with NASA’s Goddard Institute of Space Studies.

It is likely that many of these activities add little or no societal and economic value while imposing significant societal and economic costs.
The outside audit of government spending and financial control systems is long overdue. Early results from the audit activities of the Department of Government Efficiency (DOGE) suggest that current government spending controls are totally inadequate, particularly in light of the levels of spending involved. It also appears that internal Agency and Departmental audits and audits by the Office of Management and Budget have been inadequate, as has Congressional oversight.

Reports of EPA “throwing gold bars off the Titanic” in the final months of the previous Administration and “parking” $ billions in banks and NGOs do not inspire confidence in the process.

From: Cato Institute

By: Travis Fisher and Joshua Loucks

Date: March 17, 2025

Answering Frequently Asked Questions about the Inflation Reduction Act’s Energy Subsidies

Last week, Cato published Policy Analysis No. 992, titled “The Budgetary Cost of the Inflation Reduction Act’s Energy Subsidies: IRA Energy Tax Credits Could Cost $4.7 Trillion by 2050.” This work is significant because the IRA is the largest climate subsidy package in US history (possibly in world history), yet no one has a clear picture of just how much the IRA’s energy provisions will cost American taxpayers.

Our analysis is also timely because members of Congress are debating which parts of the IRA to reform or repeal. We find that energy spending under the IRA is much higher than government estimates would indicate, up to $4.7 trillion, and faces no binding cap. The energy subsidies in the IRA could continue to climb each year through 2050.

We hope Congress will fully repeal the IRA’s energy subsidies as part of the coming budget reconciliation package. At a minimum, the IRA’s significant spending deserves scrutiny. Along those lines, we appreciate the feedback we have received on our estimates of the cost of the IRA’s energy subsidies. Here are our responses to some of the most common questions and critiques of our policy analysis. (continue reading)

Answering Frequently Asked Questions about the Inflation Reduction Act’s Energy Subsidies

The Trump Administration has paused funding of climate change research and of numerous climate related initiatives and incentives. The pauses are intended to permit the new department and agency leadership to identify how the funding is moving into the markets, who is receiving the funding and for what they are using the funding.

The Administration has been accused of taking a sledgehammer to the projects rather than using a scalpel to carefully dissect the range of projects and defund those it judges to be unworthy of funding. Unfortunately, many of the ongoing or proposed projects have been funded through grants to NGOs which then determine which projects will be funded and at what levels. That approach effectively removes Executive Branch agency managers from direct oversight and control of the projects.

Using a “scalpel” approach to analyzing the large number of individual projects and activities is a laborious and time-consuming process, during which funding continues to flow to the projects regardless of their value. While the funding flowing to individual projects and activities might be relatively modest, the total funding at stake is $ billions. The “sledgehammer” approach effectively halts the flow of funding to all projects and activities until the projects and activities have been evaluated and continued funding approved or terminated.

One type of project which is almost certain to be terminated is tactical projects which use unrealistic concentration pathways and overly sensitive climate models to create scary scenarios intended to scare the populace into accepting radical climate policies. These studies are designed to support and reinforce the consensus climate crisis narrative which is not accepted by the Trump Administration.

Projects intended to advance understanding of the climate and how and why it changes are likely to receive continued funding as the review process proceeds. Such projects have largely been ignored by the IPCC, as they do not universally support and advance the consensus climate change narrative.

The Administration has also paused funding for the participation of US government funded scientists in the IPCC Assessment Report Process, since the process does not assess all relevant research, but focuses on research which supports or advances the climate change consensus. The Administration is also frustrated with the process of developing the IPCC Summary for Policymakers, which is driven by politicians and does not represent a true summary of the conclusions of the IPCC Working Groups, but rather a source of political and media climate crisis hype.

The Administration has also paused funding for the UN Green Climate Fund and the UN Loss and Damage Fund. The Administration is not supportive of the intended activities and projects to be funded by the Green Climate Fund and is suspicious of the standards of evidence to be used to determine incremental loss and damage alleged to have been caused by climate change.

The Administration is also likely to eliminate or dramatically reduce US funding for and participation in the UNFCCC Conferences of the Parties, which have become “all sound and fury, signifying nothing”. (HT: William Shakespeare)

From: Roy Spencer, Ph. D.

By: Roy W. Spencer, Ph. D.

Date: March 3, 2025

Hey, EPA, Why Not Regulate Water Vapor Emissions While You are At It?

Some Background

I will admit that the legal profession mystifies me. Every time I say anything related to environmental law, one or more lawyers will correct me. But I suppose “turnabout is fair play”, since I will usually correct any lawyers about their details describing climate change science.

Lawyers aren’t like us normal people. Their brains work differently. I first suspected this when one of my daughters took the LSAT and gave me examples of questions, most of which my brain was not wired to answer correctly. I became further convinced of this when she went to law school, and told me about the questions they deal with, how lawyers can impress judges just by being novel in their arguments, etc.

I know I could never be a lawyer (even after staying at a Holiday Inn Express), and I never even played one on TV. But I did co-author a paper in Energy Law Journal (relating to the Daubert Standard) on my view that science cannot demonstrate causation in any rigorous way in the theory of human-caused climate change.

Regulating CO2: Is the EPA Really Trying to Help Us?

The regulation of CO2 emissions (and some other chemicals) by the EPA has also mystified me. However many of the EPA’s ~185 lawyers worked on the 2009 Endangerment Finding, they must have known that regulating CO2 emissions from U.S. cars and light-duty trucks would have no measurable impact on global climate, including sea level rise (which was a major argument in Massachusetts v. EPA).

None.

But apparently actually trying to “fix” the climate “problem” is not the EPA’s concern.

Their reason for existence is to regulate pollutants (and it doesn’t matter if Nature produces far more of a “pollutant” than people produce). And once they start regulating it, they won’t stop with certain thresholds. They will keep lowering the threshold. This keeps everyone in jobs. (continue reading)

Hey, EPA, Why Not Regulate Water Vapor Emissions While You are At It?

An Urban Heat Island (UHI) is a localized area, typically in a city, where temperatures are significantly higher than the surrounding rural areas due to human activities and modifications of the landscape. This phenomenon is caused by factors such as increased impervious surfaces, limited vegetation, and the heat generated from buildings and vehicles.

U.S. EPA--https://www.nsf.gov/news/mmg/mmg_disp.jsp?med_id=75857&from=mn

A heat wave is essentially a 3-5°F temperature anomaly from regional climatology which persists for 2 or more days, as discussed in the previous commentary. Conditions in an urban heat island are essentially a virtually continuous “heat wave” relative to the current temperatures in the rural areas surrounding the urban area. The figure above illustrates the temperature impact of varying levels of development within an urban heat island. Tall, dense infrastructure and large paved areas are major contributors to urban heating.

One of the suggested responses to climate change is the development of “15-minute cities”, to minimize personal vehicle travel and encourage walking and the use of bicycles and public transit to move around the cities. These cities would offer the normal services residents require including medical and dental offices, emergency care facilities, schools, retail stores, health clubs, etc. To support the services in the 15-minute cities, the population density of these cities would have to be several times the population density of typical large cities; and, population density increases the UHI effect.

The photo below is an example of a city environment required to support high population density. The tall, dense buildings effectively block the wind and cause the heat collected and generated in the city to be trapped.

 
Detailed attention to building spacing and orientation, building construction, and the inclusion of green spaces would be essential to prevent such very densely populated cities from becoming even more intense urban heat islands.

If climate change is increasing the frequency and/or intensity of heat waves, as is suggested by IPCC AR6, then an increase in city size and population density, as would be the case with 15-minute cities, would appear to be a step in the wrong direction from the standpoints of public health and safety, particularly during the summer months. The normal elevation of temperature caused by the UHI effect would increase the temperatures in the areas surrounding the cities, as shown in the first graphic above. The temperatures in the cities and in the regions surrounding the cities would be further increased by the occurrence of heat waves in the regions. The cities would tend to be less affected by cold waves because of their internal heat gains and the effects of wind blocking.

There are also significant sociological issues with very high population density developments. The US experience with such developments, frequently referred to as “projects”, has not been positive, though most of this experience is with rental properties rather than owned residences.

From: Climate Etc.

By: Ross McKitrick

Date: February 21, 2025

Debunking the 2023 hike in the Social Cost of Carbon

I have a new paper out in the journal Nature Scientific Reports in which I re-examine some empirical work regarding agricultural yield changes under CO2-induced climate warming. An influential 2017 study had argued that warming would cause large losses in agricultural outputs on a global scale, and this played a large role in an upward revision to the Biden Administration’s Social Cost of Carbon (SCC) estimate, which drives regulatory decision in US climate rulemaking. I show that a lot of data had been left out of the statistical modeling, and once it is included there was no evidence of yield losses even out to 5 C warming.

Background

In 2023 a team of economists working for the Biden Administration concluded the SCC needed to be increased by a considerable amount. The higher the SCC, the costlier the regulatory burden that can be justified by the agency. This not only affected US regulations but Canada’s as well since our own environment ministry adopted the new US values when justifying a sweeping set of new greenhouse gas regulations. I wrote an op-ed about the SCC change in May 2023 in which I drew attention to the important role played by a revision to projected agricultural yield damages. While it is difficult to trace where, precisely, all the changes came from, I estimate about $50 of an approximately $100 increase in the 2030 value of the SCC (holding the discount rate constant) was attributable to the revised agricultural yield damage estimates. (continue reading)

Debunking the 2023 hike in the Social Cost of Carbon

IPCC AR6 Chapter 12, in its section on the Emergence of Climate Impact Drivers, identifies high confidence that increasing mean air temperatures and extreme heat have already emerged in the historical period and medium confidence that decreasing cold spells are beginning to emerge.

The World Meteorological Organization (WMO) defines heat waves and cold waves as follows:

HEAT WAVE: a heatwave can be defined as a period of marked and unusually hot weather persisting for at least two consecutive days.

COLD WAVE: a cold wave can be defined as marked and unusually cold weather, which can be associated with a sharp and significant drop of air temperatures near the Earth’s surface and persisting for at least two consecutive days.

Heat wave definitions vary by country, largely as a function of their climates. For example:

• a period of at least 3 consecutive days in which the average maximum temperature across more than half the country exceeds 28°C (82.4°F) (Denmark)
• at least five days in a row with a daily high exceeding 25°C (77.0°F) (Sweden)
• three consecutive days with temperatures at 39°C (102°F) or higher (Greece)
• a period of at least five consecutive days in which the maximum temperature in De Bilt exceeds 25°C (77°F). During this period the maximum temperature in De Bilt must exceed 30°C (86°F) for at least three days. (Netherlands, Belgium, Luxembourg)
• at least three days above 25°C (77°F) across much of the country. Greater London has a threshold of 28°C (82°F). (UK)
• temperatures exceeding 25°C (77°F) for five or more consecutive days. (Ireland)
• temperatures between 28°C (82°F) in Newfoundland and 35°C (95°F) in interior (British Columbia)
• five consecutive days at or above 35°C (95°F), or three consecutive days at or over 40°C (104°F) (Australia)
• temperature threshold ranging between 27°C (81 °F) in Greymouth and 32°C (90°F) in Gisborne.  (New Zealand)
• temperature reaches or exceeds 90°F (32.2°C) for three consecutive days (US Northeast).
• temperature reaches 100°F (37.8°C) for three or more consecutive days over a wide area (California)

Cold wave definitions are less country or region specific. For example:

• a rapid fall in temperature within a 24-hour period requiring substantially increased protection to agriculture, industry, commerce, and social activities. (US National Weather Service)
• temperature below 20°F

The relatively mild temperatures which define heat waves in much of Europe and portions of Canada and New Zealand lead to a significant increase in heat waves, whereas the requirement for a rapid decrease in temperature within a 24-hour period and a 20°F temperature lead to a significant decrease in cold waves. There is greater interest in heat waves than in cold waves, since heat waves support the global warming / climate change narrative, despite the fact that cold causes more than an order of magnitude more deaths annually than heat according to data reported by Lancet.

While both heat waves and cold waves are described as extreme weather, temperatures at or below 20°F are far more dangerous (~78° below body temperature) than temperatures at or above 77-95°F (3-20°F below normal body temperature).

Clearly, some extremes are more extreme than other extremes.

From: AEI

By: Benjamin Zycher

Date: February 12, 2025

The Collapse of Offshore Wind Power Is Only the Beginning

The “clean energy transition” — the wholesale replacement of conventional (for the most part fossil) energy with such unconventional technologies as wind and solar power — has been the raison d’être for great masses of the well-off living in comfort in Western economies for many years. And they now are grieving. Why? Because that transition, aided with massive subsidies and guaranteed market shares and other policy subventions, is collapsing both in the United States  and in Europe.

Again, why? Because unconventional energy is not and cannot be competitive. Even with the policy favoritism bestowed upon it, it imposes very large economic and environmental costs upon large numbers of ordinary working people. Let us begin with recent cancellations of offshore wind power projects in the United States. In January, “Orsted A/S recorded a … $1.7 billion hit on its earnings as the costs of offshore wind farms, particularly in the US, keep rising.” Also in January, “Shell disclosed a $996 million write-off following its withdrawal from the Atlantic Shores Offshore Wind project.” In early February, the New Jersey State Board of Public Utilities “cancelled the bidding process for the state’s fourth offshore wind solicitation, citing the uncertainty driven by recent federal actions affecting the industry.”

It is easy enough to blame Donald Trump’s recent executive order “withdraw[ing] from disposition for wind energy leasing all areas within the Offshore Continental Shelf (OCS),” but that is a mere symptom of a far more fundamental reality: Offshore wind power is even less economic than other forms of unconventional electricity; ultimately, the excess costs for all of them must be paid by power consumers and taxpayers. (continue reading)

The Collapse of Offshore Wind Power Is Only the Beginning

The State of New York enacted the Climate Change Superfund Act in December, 2024. The Act asserts that climate change has caused damage in the state and seeks to recover some portion of the alleged cost of that damage from elements of the fossil fuel energy industry alleged to be responsible for some portion of that damage as a result of the CO2 caused by emissions resulting from the use of their fuels. The Act is similar to the Vermont Climate Superfund Act of May, 2024.

“With nearly every record rainfall, heatwave, and coastal storm, New Yorkers are increasingly burdened with billions of dollars in health, safety, and environmental consequences due to polluters that have historically harmed our environment,” Governor Hochul said in a statement.

An appropriate topic for any discussion of lawfare, whether lawsuits alleging violation of existing laws or legislation leading to new law, is the issue of standards of evidence.

Standards of evidence refer to the amount of evidence or certainty required to prove a fact or claim in legal cases. The three primary standards of proof are:

1. Proof beyond a reasonable doubt
2. Preponderance of the evidence
3. Clear and convincing evidence.

The Governor of the State of New York listed record rainfall, heatwaves and coastal storms as the weather extremes of concern. The preponderance of the evidence, as collected and analyzed by the IPCC in its Sixth Assessment Report (AR6, Chapter 12) indicates no linkage between global warming and climate change and the frequency and intensity of extreme weather events with the exception of heatwaves, which are affected by increasing average temperatures.

The frequency and intensity of coastal storms have not increased, though the financial damage from such storms has increased as the result of the increasing value of the infrastructure exposed to the storms. However, when the damage estimates are adjusted for changes in GDP, there is proof beyond a reasonable doubt that there is no climate change driven trend. There is also clear and convincing evidence that tropical cyclones are responsible for the preponderance (80%) of extreme weather-related damage in New York.

The New York Climate Change Superfund Act fines fossil energy industry companies for the purported damage caused in the state by the CO2 emissions resulting from the use of their fuels, even though the sale of those fuels in the state was legal and even though the State of New York and its counties and cities were consumers of those fuels. The State has apparently arbitrarily set the total amount of the fines to be collected, since any damage by extreme weather events attributable to fossil fuel CO2 emissions would only be some fraction of the total estimated damage and the portion of the damage attributable to fossil fuel use in New York would be some small fraction of that total. Establishing an estimate of the damage attributable to emissions in New York State would require attribution studies, which rely on unverified and unvalidated climate models.

The Climate Change Superfund Act is the subject of a lawsuit filed by 22 states based on constitutional grounds.

From: Climate Etc.

By: Russ Schussler

Date: February 19, 2025

Unraveling the Narrative Supporting a Green Energy Transition

The purpose of this article is to summarize and debunk many of the issues in the narrative surrounding  the proposed green energy transition as applies to the electric grid.  The issues are so numerous that this piece is at once both too long and too short. A full unraveling deserves a book or series of books. This posting however challenges the narrative through summary comments with links to previous posts and articles which can be read for a more detailed explanation or for greater depth.

The Narrative

Efforts to hasten a “green transition” find support in a powerful and compelling narrative. The following statements are widely believed, embraced and supported by various “experts”, a large part of the public and far too many policy makers:

1. Renewable Energy can meet the electric demand of the United States and World
2. Renewable Energy is economic
3. Renewable Energy sources can provide reliable electric service to consumers and support the grid
4. Renewable energy sources are inexhaustible and widely available
5. Clean Energy resources don’t produce carbon and are environmentally neutral
6. Renewable Energy Costs are decreasing over time
7. It will become easier to add renewables as we become more familiar with the technologies
8. The intermittency problems associated with wind and solar can be addressed through batteries.
9. Inverter based generation from wind, solar and batteries can be made to perform like conventional rotating generator technology
10. Battery improvements will enable the green transition
11. We are at a tipping point for renewables
12. Wind, Solar, and Battery technologies collectively contribute to a cleaner environment, economic growth, energy security, and a sustainable future
13. The world is facing severe consequences from increased CO2 emissions.
14. There will be an inevitable and necessary transition to clean economic renewables
15. Green Energy will allow independence from world energy markets
16. The clean grid will facilitate clean buses, trucks, tanks, planes
17. The third world will bypass fossil fuels and promote global equity
18. Replacing fossil fuels with green energy will have huge health benefits
19. It’s all about Urgency and Action (continue reading)

Unraveling the Narrative Supporting a Green Energy Transition

An appropriate topic for any discussion of lawfare, whether lawsuits alleging violation of existing laws or legislation leading to new law, is the issue of standards of evidence.

Standards of evidence refer to the amount of evidence or certainty required to prove a fact or claim in legal cases. The three primary standards of proof are:

1. Proof beyond a reasonable doubt
2. Preponderance of the evidence
3. Clear and convincing evidence

The State of California sued several major oil and gas companies and the American Petroleum Institute (API) in 2023, accusing the companies of lying about the effects of the use of their products on the climate and seeking compensation for alleged damages and state investment in climate adaptation. The state lawsuit is a variation on the theme ”Exxon knew”, which has been unsuccessful in numerous similar lawsuits, including a lawsuit by New Jersey. More recently, legislation was introduced to provide a path for insurance companies and individuals to sue the companies for damages resulting from wildfires.

Wildfires are a special case, in that they cannot be caused by climate change. Rather, there is clear and convincing evidence that wildfires require a source of ignition at a temperature above the ignition temperature of the available combustible material and possessing sufficient energy to raise the temperature of the available combustible material above its ignition temperature. The common natural source of ignition is lightning. However, faulty electric transmission and distribution infrastructure, accidental spread of cooking and campfires from homeless encampments and intentional arson are also common sources of ignition which cause wildfires.

California has experienced more than 200,000 wildfires in the period since 1878. Relatively accurate records are available after 1925 which show a dramatic decrease in acres burned through 1983, followed by a slow increase largely resulting from electric spark and human ignition, aggravated by poor forest management practices, beyond a reasonable doubt. Most of these wildfires occurred before global warming and climate change became a significant issue.

The preponderance of the evidence surrounding the recent Pacific Palisades and Eaton wildfires establishes that the damage caused by the fires was aggravated by failure to pre-position firefighting resources in anticipation of forecasted severe Santa Ana winds, the unavailability of water in the nearby Santa Ynez reservoir, low water pressure and numerous non-functional fire hydrants in the immediate area of the fires.

The preponderance of the evidence, as collected and analyzed by the IPCC in its Sixth Assessment Report (AR6, Chapter 12) indicates no linkage between global warming and climate change and the frequency and intensity of extreme weather events, with the exception of heat waves, or wildfires.

California has made numerous bad decisions regarding wildfires, including abandoning aggressive forest management projects and failing to build and fill additional reservoirs. Governor Newsom also disbanded a National Guard highly trained volunteer fire service.

Regardless of the above, California has focused the “blame game” on major oil and gas companies and the API, largely because the industry represents “deep pockets” which could help fund the recovery efforts from the recent fires.

From: IER

Date: January, 2025

POLICY BRIEF: American Energy Blueprint

Summary

The American Energy Blueprint is a comprehensive set of policy recommendations to guide the new Trump administration's approach to energy policy. The Blueprint outlines key reforms in areas such as federal land and water use, expanding consumer choice, reducing subsidies, curbing government spending and taxation, streamlining regulations, and modernizing the permitting process.

Federal Lands and Waters

The Biden administration launched an unprecedented attack on energy development on federal lands. From restricting land use to slowing or halting permitting approvals and raising fees, the administration did seemingly everything to make energy development on federal lands more difficult and more expensive as part of its pledge to “end fossil fuels.” The Trump administration should take swift action to reverse these actions and Congress should update statutes to ensure such abuse cannot happen again in the future.

Administrative Actions:

• Reverse restrictive Biden actions in ANWR and NPR-A, and revoke other Alaska land-use limitations on energy and minerals. Alaska is over twice the size of Texas; two-thirds of it is federally owned and 86% of it is inaccessible by road.
• Reverse the illegal denial of an access road to Alaska’s Ambler Mining District, one of the U.S.’s most potentially prolific sources of valuable rare earth minerals.
• The Bureau of Ocean Energy Management should proceed with Lease Sale 262 in 2025, as planned, and create a new, more comprehensive Outer Continental Shelf (OCS) five-year leasing program, including at least two lease sales per year in the Gulf of Mexico (GOM). With the current OCS five-year leasing program under litigation, the administration should request a voluntary remand to resolve all pending petitions.
• Release a new offshore leasing plan.
• Approve permits for new mines.
• Executive order to reconsider all Biden administration decisions on land withdrawals from energy or mining leasing.
• Reverse the Biden actions requiring higher fees and costs for production in certain areas.
• Review, reverse, and shrink Biden and Obama-era national monument designations. (continue reading)

POLICY BRIEF: American Energy Blueprint

The Clean Air Act (CAA) became law in 1970. It was later amended in 1970 and 1990. Congress considered including CO2 emissions under the Act but elected not to do so both during debate on the Act and during debates on the amendments.

Massachusetts and several other states and cities petitioned EPA to regulate greenhouse gases under the CAA because they were “pollutants”. EPA rejected the petition because it was not authorized to regulate greenhouse gases under the CAA. In 2007, Massachusetts and several other states and cities sued EPA at the US Supreme Court to have EPA regulate greenhouse gases under the CAA. The Supreme Court ruled that EPA could regulate greenhouse gases under the CAA because they were “pollutants”. This ruling ignored the clear intent of Congress regarding the CAA.

US EPA issued an Endangerment Finding (EF) in 2009 regarding emissions of six key well mixed “greenhouse gases”. carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6). The EF was originally targeted at motor vehicle emissions. However, EPA has used it as the basis to control emissions from stationary sources as well.

The CAA requires EPA to base its actions on its own research. However, EPA relied on IPCC as the source of its research results. The EF was not based on observations, but rather on the output of computer models which themselves have proven to be inaccurate and largely unfit for purpose.

The CAA requires EPA to issue National Ambient Air Quality Standards (NAAQS) for pollutants subject to an EF. EPA has failed to issue the NAAQS for CO2 in the 16 years since the EF was issued. Development of an NAAQS for a “globally well-mixed trace gas” whose atmospheric concentration is increasing, largely driven by emissions from other nations, would be a monumental challenge, as would administering it.

The endangerment identified by EPA remains unfound in those 16 years. Public health and safety have not been diminished as a consequence of increased atmospheric CO2 concentrations. Heat-related deaths remain an order of magnitude lower than cold-related deaths. The frequency and severity of extreme weather events have not increased. The rate of sea level rise has not increased. The globe has greened, largely as a result of increased atmospheric CO2 concentrations. Crop yields have continued to increase, in part as the result of increased atmospheric CO2 concentrations.

Research conducted by numerous research teams over the 16 years since the issuance of the EF suggests that the endangerment envisioned by the EPA EF was largely overblown. The climate is not as sensitive to increased atmospheric CO2 concentrations as the EF envisioned. Warming is not occurring as rapidly as reported by the “adjusted” near-surface temperature records or projected by the unverified and unvalidated climate models.

EPA Administrator Lee Zeldin has recommended to President Trump that the 2009 EF be re-evaluated and either revised or rescinded. This action would not conflict with the 2007 Supreme Court decision, since the Court merely ruled that EPA could regulate CO2 under the CAA, not that it was required to do so.

From: Climate Etc.

By: Russ Schussler

Date: January 30, 2025

How the Green Energy Narrative confuses things

Prequel to “Unravelling the narrative supporting a green energy transition.”

There is a powerful but misleading narrative supporting a green energy transition. A follow up piece will look more broadly at the general narrative supporting a transition to net zero.  This prequel will provide some detail on a few  components of the energy narrative and how this misleading narrative was established. The green energy narrative works somewhat like a magician’s patter, overemphasizing many things of irrelevance and distracting the audience from the important things going on. Misdirection ensures small truths are misinterpreted and magnified, leading to completely unrealistic hopes and expectations.

Misleading green narratives often start with Academics. As I noted here:

Overwhelmingly the academic articles I read are good. Usually, the authors carefully describe the limitations of their findings and recommendations. Sometimes they hint as to what remains to be worked out. I’m afraid this does not stop individuals, the media, and some policy makers from ignoring the qualifications and limitations inherent in their findings. The situation is worse when they leave it to the reader to ferret out the limitations of their findings. In very rare instances some academics will go beyond what has been demonstrated with exaggerated claims. I don’t know if this is done through ignorance, accident, hubris or for purposes of self-advancement.

For example, there have been many simple studies examining how much energy might be produced by a green resource, or set of green resources, such as wind and solar power. These studies ignore important issues such as  deliverability, timing, reliability and costs. Based on simple studies the media, activists and policy makers frequently  conclude that such resources can be used near universally on a large scale to provide electric service to consumers effectively, efficiently and economically. (continue reading)

How the Green Energy Narrative confuses things

The IPCC Summary for Policymakers asserts that climate change is causing more frequent and more intense extreme weather events, including tropical cyclones, tornadoes, droughts, floods and heat waves; and, that climate change is increasing the loss and damage these events cause. These assertions are repeated frequently by the US Secretary General, other members of the UN Secretariat and numerous national leaders. The UN Secretary General combines these assertions with a variety of hyperbolic descriptions of the current situation. Interestingly, these assertions regarding causation are not supported by the analyses of IPCC Working Group I. However, they are widely accepted and repeated by the global media.

The UN and numerous of its member nations have requested that the International Court of Justice (ICJ) rule on the legal obligations of governments regarding reducing CO2 emissions to limit the climate change they are accused of causing. While an ICJ ruling would be advisory in nature, it would likely be “played up” by the UN secretariat and the media as requiring “greater ambition” on the part of global governments to reduce CO2 emissions. Nations failing to adhere to the ICJ ruling would likely be accused of Ecocide and subjected to additional lawfare.

Extreme weather events have occurred throughout history. The loss and damage they cause has increased over time, largely as the result increasing infrastructure investment, land use changes and GDP growth. Roger Pielke, Jr. and others have determined that when loss and damage from extreme weather events are adjusted for growth in GDP, the trend lines are flat or slightly negative, indicating that climate change is not exacerbating the effects of the weather events.

Tropical cyclones are an interesting case in point. While there is a defined “tornado season” during which they normally occur, we do not know when a disturbance will occur, whether a particular disturbance will develop into a tropical depression, tropical storm or hurricane/typhoon. We also do not know the track a particular storm will follow or whether it will eventually make landfall and, if so, at what intensity. These uncertainties make it effectively impossible to identify and quantify the extent to which any particular storm might have been affected by climate change, though the purveyors of Attribution Analysis assert that they are able to do so. The damage caused by a storm is a function of its intensity, its track and the value and durability of the infrastructure in its path.

Flooding is another interesting case. Flooding can result from heavy precipitation and/or from storm surge associated with storms offshore. Each conversion of landscape (exposed soil) to hardscape (buildings, parking lots, roads and sidewalks, etc.) increases the runoff resulting from heavy rains and increases the geographical extent of storm surge. The likelihood of flooding increases if facilities to handle runoff are not expanded as the percentage of hardscaped surface increases.

Numerous Pacific Island nations have expressed concerns about the potential effects of rising sea levels. However, sea level has been rising since the trough of the Little Ice Age, prior to the increase in anthropogenic CO2 emissions. The rate of rise of sea level has not increased as the result of climate change according to the tide gauge records. The area of most of these islands has increased or remained stable as sea level has increased.