Observation vs. Supposition - ORIGINAL CONTENT

Most government environmental regulations are based on observations of atmospheric concentrations, exposure durations and adverse health effects. Specific sources of emissions of the pollutants in question are measured individually and the combined exposure levels calculated. Studies are conducted to determine the safe exposure to each pollutant as a function of concentration and frequency and duration of exposure. The technologies available to control emissions from each of the sources of concern are evaluated to determine their technical and cost effectiveness. Regulations are then developed which establish the emissions limits for each controlled source required to establish and maintain safe exposure.

This regulatory approach has worked well when applied to the emissions of pollutants which remain largely local or regional. It has been used to limit vehicle tailpipe emissions, powerplant emissions, refinery emissions and other industrial and commercial emissions. It has also been applied to eliminate the use of tetraethyl lead in gasoline and to ban the use of lead in paint and other coatings in combination with the application of the Linear No Tolerance (LNT) concept to emissions other than ionizing radiation.

However, this regulatory approach is not well suited to the regulation of “globally well-mixed trace gases” such as CO2, for several reasons. While atmospheric concentrations can be measured, no individual nation can regulate the atmospheric concentration of a “globally well-mixed trace gas” which is emitted by multiple sources in every nation on the globe. Control of exposure duration is also not possible because exposure is continuous globally. Finally, there are no observed adverse health effects at current exposure levels, or at exposure levels an order of magnitude higher than current exposure levels.

The supposed ”global” effort to control CO2 “pollution” is based on supposition of adverse effects on global climate which would lead to adverse human heath effects. This supposition is based on the outputs of numerous climate model studies which suggest the possibility of large global temperature increases, more frequent and more intense extreme weather events and ultimately crop failure. The timing and severity of these changes is very much a function of the climate model chosen and the starting assumptions for the model run.

However, current observations dispute the supposition. The potential atmospheric warming effect of CO2 is essentially “saturated”, in that additional CO2 concentrations would have a minor effect on atmospheric temperatures (<1°C for a doubling of CO2 concentration). Observations confirm that the additional atmospheric CO2 concentration has contributed to increases in agricultural production and to global greening, both as a result of CO2 fertilization and the ability of plants to use available water more efficiently Observations do not confirm any increase in the frequency or intensity of extreme weather events and actually suggest some reductions in frequency and intensity, with the exception of heat waves which are typically not extreme (climatology plus 3°F for 2-3 or more days).

The current atmospheric CO2 concentration is well below the optimum concentration for plant growth and also well below the concentration at which adverse human health effects might be expected.

The supposed “endangerment” is unsupported and, in fact, countered by observations. It is an unreasonable basis for regulation.