Lord Monckton to Scott Pruitt: Proposed repeal of the “Clean Power Plan”


5 January 2017
The Hon. Scott Pruitt
Administrator
Environment Protection Agency
Dear Administrator Pruitt,
EPA-HQ-OAR-2017-0355
Proposed repeal of the “Clean Power Plan”
It has been suggested that I should write to let you know of the results of my team’s scientific research establishing that worldwide concern about Man’s influence on global temperature arose from an elementary and substantial error of physics first perpetrated some decades ago when climate scientists borrowed feedback theory from its originators in electronic network analysis but without sufficiently understanding it.
In response to doubled CO2 concentration global warming will not be up to 10 Celsius degrees, as some have suggested, and will not even be the 3.3 C° that is the current mid-range prediction of the fifth-generation models of the Climate Model Inter-comparison Project. We have formally demonstrated that it will be only 1.25 C°.
This result was reached by three distinct methods – one by measurement, two by mathematics. The empirical method and the two theoretical methods cohere in their results, which have also been confirmed by independent tests at the National Physical Laboratory.
For four decades since 1979, when Dr Jule Charney wrote a report for the U.S. National Research Council predicting that for every doubling of CO2 concentration there would be 1.5 to 4.5 C° global warming with a best estimate of 3 C°, the error of physics has misled climatologists into exaggerating their predictions of global warming. The error was built into five generations of computer models of the climate. Fixing it slashes the official global-warming estimate. There will be some global warming, but it will be small, harmless and beneficial. Global-warming mitigation is now demonstrated to be entirely unnecessary.
The error arose because climate scientists mistakenly thought that the entire difference (usually estimated at 33 C°) between the Earth’s surface temperature with and without greenhouse gases was caused entirely by direct warming driven by greenhouse gases and by the knock-on effects of that direct warming, known as temperature feedbacks.
In reality, two-thirds of the 33 C° difference between what is called “emission temperature” and today’s surface temperature arose not from greenhouse gases but from feedbacks consequent upon the emission temperature itself. Climatologists had used a version of the feedback loop that omitted the emission temperature from the input to the calculation. As a result, the feedbacks induced by emission temperature had hitherto been wrongly counted as part of the feedbacks induced by the direct warming from greenhouse gases.
Our paper demonstrates that feedbacks (though mentioned 1000 times in IPCC’s 2013 Fifth Assessment Report) cannot add much more than about a sixth of a degree to the 1.1 C° global warming directly caused by doubling CO2 concentration, so that the total warming of little more than 1.25 C° in response to doubled CO2 concentration, little more than a third of the models’ mid-range estimate, will be small, harmless and beneficial. No action of any kind need be taken to prevent it.
I should also report an economic analysis of global-warming mitigation policy that I carried out for the World Federation of Scientists some years ago. You will recall that the Stern Review of the economics of mitigation conducted in 2006 for the then Socialist government in the U.K. concluded that, owing to the possibility that there might be as much as 11 C° warming in the 21st century, there was a 10% probability that global warming would bring the world to an end by 2100 (Dietz et al., 2007). For this reason, Stern chose an artificially low discount rate of only 1.4% for the intertemporal investment appraisal of mitigation policies. Using that rate, and based on his mid-range estimate of 3 C° manmade warming by 2100, he concluded that the centennial welfare cost of global warming would be 3% of global GDP.
However, Stern’s notion of up to 11 C° warming by 2100 is now universally recognized as fanciful. Therefore, his assumption of a 10% probability of warming-driven extinction by 2100 and his derivation therefrom of his 1.4% intertemporal discount rate are unjustifiable. At the U.S. Treasury’s central discount rate of 7%, Stern’s welfare cost of 3% of GDP falls by nine-tenths to just 0.3% of GDP, even if Stern is right that there will be 3 C° warming this century rather than the 1.25 C° that is the current trend and that is consistent with our result.
Taking into account the fact that global warming in response to doubled CO2 will not be 3.3 C° but only 1.25 C°, and that anthropogenic warming this century will be about the same, there is a considerable net welfare benefit in burning coal, oil and gas. Therefore, there was never any economic case for the Clean Power Plan and there is now no scientific case either.
The moral dimension should also be considered. Some 2 million of the 1 billion worldwide who have no electricity die of particulate emissions from smoke in their cooking fires. Many millions more die of other factors arising from lack of access to affordable, continuous, reliable, low-tech, base-load power from coal-fired power stations. It is very likely that a Holocaust of such deaths is occurring every year. Unnecessary global-warming mitigation policies are now the main reason for this invisible genocide.
Agree to send the attached papers to reliable scientists and economists outside the EPA for independent review, and to let the scientists and economists know that their reviews will be sent to me?
Yours truly,

Viscount Monckton of Brenchley

Comments

  1. Climate Crisis? Al Gore and Michael Mann Fail Science 101

    In this post I will address Michael Mann’s assertion that record cold temperatures are the result of man-made CO2 as detailed in a recent Climate Reality Project article, mentioned by Al Gore in his “Tweet.” Before I go any further, without addressing any of his claims, the important take home is that even if Al Gore and Michael Mann are 100% correct in their analysis and conclusion, the solutions they offer will only make matters worse.

    If CO2 causes more draught, biofuels like Ethanol are idiotic solutions as best.
    If CO2 causes more rain, then solar is an idiotic solution at best.

    https://co2islife.wordpress.com/2018/01/05/climate-crisis-al-gore-and-michael-mann-fail-science-101/

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    1. Regarding the substance of the letter by the Viscount Monckton, repeal of the Clean Air Act is not politically feasible. Amendment of the Act is feasible.

      The sub-section that needs to be amended is 111(d)(1). This section may be unconstitutional because the Congress has delegated authority to the executive in terms that are too broad.

      The Administrator has power to declare any substance whatsoever as a pollutant.
      The Congress has provided a list of pollutants in the Act, but subsection 111(d)(1) delegates to the Administrator the power to define as a pollutant "...any air pollutant...which is not included on a list...."

      The Administrator could declare Eau de Cologne as a pollutant and if the Supreme Court (SCOTUS) applied the same interpretation of the statute the Court would uphold the Administrator's decision.

      This is inconsistent with the approach SCOTUS has taken in striking down other statutory provisions as being overly broad or vague.

      The issue is whether or not Congress has the power to delegate to the Executive the authority to control by fiat so much of the economy.

      Or does Congress have to specifically extend the list of pollutants and perhaps exclude some naturally occurring substances from the discretionary power delegated to the Administrator.

      The relevant text of s.111(d)(1)
      (1) The Administrator shall prescribe regulations which shall establish a procedure similar to that provided by section 7410 of this title under which each State shall submit to the Administrator a plan which (A) establishes standards of performance for any existing source for any air pollutant (i) for which air quality criteria have not been issued or which is not included on a list published under section 7408(a) of this title or emitted from a source category which is regulated under section 7412 of this title but (ii) to which a standard of performance under this section would apply if such existing source were a new source, and (B) provides for the implementation and enforcement of such standards of performance.

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  2. Christopher Monkton is wrong in his (and many others) assumption that the difference between Earth’s effective emission temperature and its near surface air temperature is the result of so called greenhouse gasses.
    The lapse rate is dictated by gravity, this is why the acceleration rate of gravity is one of the central terms in the equation that calculates it. The ideal gas law also quantifies the relationship between the weight of the atmosphere above on the temperature underneath it.
    The effective radiating temperature of earth to space is found in roughly the middle of the troposphere. Above the atmosphere gets colder, below it gets warmer. So there is no need to invoke magic greenhouse gasses to explain the surface temperature. Gravity distributes the available energy in a vertical column. Potential energy+kinetic energy at the top=kinetic energy at the surface. The average kinetic energy is found in the middle and this is what we measure from space. The average.

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    1. "So there is no need to invoke magic greenhouse gasses to explain the surface temperature. ".

      Nothing magic about the so-called "greenhouse" gases. The main problem is that physicists dumb-down the way the atmosphere works. So you are attacking an analogy of how the atmosphere works used to explain the process to lay-persons.

      As Richard Lindzen explains in lectures you can find on Youtube, via the lapse rate, CO2 shifts the effective top of the atmosphere to a higher elevation at which the atmosphere is cooler and therefore radiates less heat to space.

      In effect, the atmosphere does perform the way you describe, including the "greenhouse" gases, except CO2 etc do not make the atmosphere work like a greenhouse.

      The scientific dispute is not about the mechanism by which the "greenhouse" effect works, but about two other things: the sensitivity or the climate system to a doubling of CO2; and whether or not the water vapour feedback is positive or negative. These are technical questions about the numbers, not about the mechanisms.

      The Viscount Monckton points to the relevant equation and point to the fact that the shape of the equation is a rectangular hyperbola (not in dispute). He argues that the relevant position on the curve is not towards the right where the modelers say it is, but rather on the left. A rectangular hyperbola has a gentle slope on the left and a steep slope on the right. If the value of the feedback parameter is on the left, there is nothing to worry about. Lindzen and Choi came to the same conclusion by a different route in their revised paper. Lindzen and Choi On the observational determination of climate sensitivity and its implications (2011)

      If the Viscount Monckton is correct, there is not much to worry about because water vapour is a much more important "greenhouse" gas than CO2. Modelers assume positive feedback from water vapour and then multiply the effect of CO2 by a factor of 3 to get an alarming result.

      Water vapour has an effect upon climate via its role in cloud formation. The amount of solar energy falling upon the Earth is about 340 Watts per square meter (Wm-2). This is calculated by taking the energy falling on the disk 1360 Wm-2 divided by 4 to convert to a global average.

      Not all of the 340 Wm-2 enters the troposphere . About, 105 Wm-2 (30%) is reflected back into space. (Loeb et al. 2012; Stephens et al. 2012).

      The reflectance is called "Bond albedo". And it varies by season, by year and longer time-scales. Values used for albedo in books range from 0.29 to 0.31, a range of 6%, equivalent to about 6 Wm-2.



      Pallé et al. estimated that from 1984 to 2004, changes in the Earth's reflectance (Bond albedo) spanned a range of 10 Wm-2, plus or minus 5 Wm-2.
      Pallé, et al. Changes in Earth’s Reflectance over the Past Two Decades, Science 304 (2004)

      Stephens et al. and Loeb et al. (cited above) estimated that the Earth's energy imbalance at the top of the atmosphere as measured by changes in ocean heat content was about half of one Watt per square meter.

      The variations in energy flux caused by cloudiness is 10 times the energy imbalance estimated by Loeb et al, and Stephens et al. based on changes in ocean heat content.

      Since clouds account for most of the Earth's albedo, this means that most of the change in the Earth's energy balance results not from "greenhouse" gases but from changes in cloudiness.

      The science is not yet settled on what causes changes in cloudiness, but whether or not we know the mechanism, empirical evidence shows that cloudiness dominates the climate of Earth and variations in cloudiness dominates climate change.

      Svensmark and others claim that they have discovered the mechanism: galactic cosmic rays, actually particles called muons.

      Svensmark, et al. Increased ionization caused by galactic cosmic rays supports growth of aerosols into cloud condensation nuclei, 2017.
      http://orbit.dtu.dk/ws/files/140924453/Svensmark_et_al_2017_Nature_Communications.pdf

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