W l l March I. 2009 Draft Proposed NCEE Comments on Draft Technical_Support Document for Endangerment Analysis for Greenhouse Gas A Emissions under the Clean Air Act Based on;TSD Draft of March 9, 2009 ‘ A I , March I, 2009 ` Oftice of Policy, Economics, and Innovation · Office of the Administrator U.S. Environmental Protection Agency · ‘ _ Washington, DC 20460 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA V ii March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! This page intentionally left blank » \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA Y PREFACE ’ We have become increasingly concerned that EPA and many other agencies and countries have paid too little attention to the science of global warming. EPA and others have tended to accept the findings reached by outside groups, particularly the IPCC and the CCSP, as being correct without a careful and critical examination of their conclusions and documentation. If they should be found to be incorrect at a later date, however, and EPA is found not to have made a really careful review of them before reaching its decisions on endangerment, it appears likely that it is EPA rather -than these other groups that may be blamed for this error. . We do not maintain that we or anyone else have all the answers needed to take action now. Some of the conclusions reached in these comments may well be shown to be incorrect by future research. Our conclusions do represent the best science in the sense of most closely corresponding to available observations that we currently know ori however, and are sufficiently at variance with those of the IPCC, CCSP, and the Draft TSD that we believe they support our increasing concern that EPA has not critically reviewed the findings by these other groups. As discussed in these comments, we believe our concerns and reservations are sufficiently important to warrant a serious review of the science by EPA before any attempt is made to reach I conclusions on the subject. We believe that this review should start immediately and be a continuing effort as long as there is a serious possibility that EPA may be called upon to implement regulations designed to reduce global warming. The science has and undoubtedly will continue to change and EPA must have the capability of keeping abreast of these changes if it is to successfully discharge its responsibilities. The Draft TSD suggests to us that we do not yet have that capability or that we have not used what we have. We would be happy to work with and assist anyone who might wantto undertake such a A serious review of the science. ii _ March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA ‘ This page intentionally left blank . ii March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Executive Summary I EXECUTIVE SUMMARY These comments are based on the draft Technical Support Document for Endangennent Analysis for Greenhouse Gas Emissions under the Clean Air Act (hereafter draft TSD) issued by the Climate Change Division of the Office of Atmospheric Programs on March 9, 2009. I Unfortunately, because we were only given a few days to review this lengthy document these comments are of necessity much less comprehensive and polished than they would have been if I more time had been allowed. We are prepared, however, to provide added information, more detailed comments on specific points raised, and any assistance in making changes if requested . by OAR. _ A The principal comments are as follows: A I 1. The current Draft TSD is based largely on the IPCC AR4 report, which is at best three years out of date in a rapidly changing field. There have been important developments in areas that deserve careful attention in this draft. The list includes the following five: • Global temperatures have declined—extending the current downtrend to ll years with a particularly rapid decline in 1907-8; in addition, the PDO went negative in September, 2007 and the AMO in January, 2009, respectively. At the same time atmospheric CO2 levels have continued to increase and CO2 emissions have accelerated. _ • The consensus on past, present and future Atlantic hurricane behavior has changed. Initially, it tilted towards the idea that anthropogenic global warming is leading to (and will lead to) to more · frequent and intense storms. Now the consensus is much more neutral, arguing that future Atlantic tropical cyclones will be little different that those of the past. · • The idea that warming temperatures will cause Greenland to rapidly shed its ice has been greatly diminished by new results indicating little evidence for the operation of such processes. A • One of the worst economic recessions since World War II has greatly decreased GHG emissions compared to the assumptions made by the IPCC. To the extent that ambient GHG levels are relevant for future global temperatures, these emissions reductions should greatly influence the adverse effects of these emissions on public health and welfare. The current draft TSP does not reflect the changes that have already occurred nor those that are likely to occur in the future as a result of the recession. In fact, the topic is not even discussed to our knowledge. 2009 DRAFT iii \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA • A new 2009 paper finds that the crucial assumption in the GCM models used by the IPCC . concerning strongly positive feedback from water vapor is not supported by empirical evidence I i and that the feedback is actually negative. • A new 2009 paper by Scafetta and West suggests that the IPCC used faulty solar data in dismissing the direct effect of solar variability on global temperatures. Their research suggests that solar variability could account for up to 68% of the increase in Earth’s global temperatures. These six developments alone should greatly influence any assessment of ‘i‘vulnerability, risk, and impacts" of climate change within the U.S. But these are just a few of the new developments since 2006. Therefore, the extensive portions of the EPA’s Endangerment TSD _ which are based upon the old science are no longer appropriate and need to be revised before a new TSD is issued for comments. Not only is the science of the TSD out-of—date but there are a number of other disturbing inconsistencies between the temperature and other scientific data and the GHG/CO2 hypothesis that need to be carefully explored and explained if the draft TSD is to be credible. Despite the _ complexity of the climate system the following conclusions appear to be well supported by the available data (see Section 2 below): A. By far the best single explanation for global temperature fluctuations is variations in _ the PDO/ENSO. ENSO appears to operate in a 3-5 year cycle. PDO/AMO appear to operate in about a 60-year cycle. This is not really explained in the draft TSD but needs to be, or, at the very least, there needs to be an explanation as to why OAR p believes that these evident cycles do not exist or why they are much more unimportant than we believe them to be. i' , B. There appears to be a strong association between solar sunspots/irradiance and global . temperature fluctuations. It is unclear exactly how this operates, but it may be through indirect solar variability on cloud formation. This topic is not really explored in the Draft TSD but needs to be since otherwise the effects of solar variationsmay be misattributed to the effects of changes in GHG levels. C. Changes in GHG concentrations appear to have so little effect that it is difficult to find any effect in the satellite temperature record, which started in 1978. U iv March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Executive Summary D. The surface measurements (HADCRUT) are more ambiguous than the satellite measurements in that the increasing temperatures shown since the mid-1970s could either be due to the rapid growth of urbanization and the heat island effect or by the l increase in GHG levels. However, since no such increase is shown in the satellite record it appears more likely that urbanization and the UHI effect are the most likely cause. If so, the increases may have little to do with GHGs and everything to do with the rapid urbanization during the period. Given the discrepancy between surface temperature records in the 1940-75 and 1998-2008 and the increases in GHG levels during these periods it appears even more unlikely that GHGs have much effect on measured surface temperatures either. These points need to be very carefully and I fully discussed in the draft TSD if it is be scientifically credible. E. Hence it is not reasonable to conclude that there is any endangerment from changes in GHG levels based on the satellite record, since almost all the fluctuations appear to be due to natural causes and not human-caused pollution as defined by the Clean Air Act. The surface record is more equivocal but needs to be carefully discussed, which would require substantial revision of the Draft TSD. · F. There is a strong possibility that there are some other natural causes of global temperature fluctuations that we do not yet fully understand and which may account for the 1998 temperature peak which appears on both the satellite and surface temperature records. This possibility needs to be fully explained and discussed in the _ Draft TSD. Until and unless these and many other inconsistencies referenced in these .» comments are adequately explained it would appear premature to attribute all or even any of what warming has occurred to changes in GHG/CO2 atmospheric levels. These inconsistencies are so important and sufficiently abstruse that in our view EPA needs to make an independent analysis of the science of global warming rather than adopting the conclusions of the IPCC and CCSP without much more careful and independent EPA staff review than is evidenced by the Draft TSP. Adopting the scientific conclusions of an outside group such as the IPCC or CCSP without thorough review by EPA is not in the EPA tradition anyway, and there seems to be little reason the change the tradition in this case. If their I conclusions should be incorrect and EPA acts on them, it is EPA that will be blamed for 2009 DRAFT v \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA — inadequate research and understanding and reaching a possibly inaccurate determination of endangerment. Given the downward trend in temperatures since 1998 (which some think will continue until at least 2030) there is no particular reason to rush into decisions based on a scientific hypothesis that does not appear to explain most of the available data. Finally, there is an obvious logical problem posed by steadily increasing US health and welfare measures and the alleged endangerment of health and welfare discussed in this draft TSD i during a period of rapid rise in at least CO2 ambient levels. This discontinuity either needs to be carefully explained in the draft TSD or the conclusions changed. vi March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! ` Table of Contents I - Table of Contents · 5 1. Draft TSD Is Seriously Dated and the Updates Made Are Inadequate ...........,.............................. 1 D 1.1 Where to Find a Discussion of Various Topics in These Comments ..,.....,............................... 1 1.2 Global Temperatures Have Declined'Significantly ................................................................... 1 1.3 IPCC Global Temperature Projections Look Increasingly Doubtful ......................................... 3 1.4 Consensus On Past, Present and Future Atlantic Hurricane Behavior Has Changed ................ 6 1.5 Changes in Outlook for Greenland Ice Sheet .......................................................................... 10 1.6 Serious Recession Has Greatly Decreased GHG Emissions Compared to the Assumptions Made by the IPCC ......................................... L ..................................................,...................... 13 1.7 Long-temi Water Vapor Feedback Reported to Be Negative .................................................. 14 1.8 Scafetta and West: GHG Contribution to Global Warming May Be Much Smaller than { Alleged by IPCC .......................................’ . .............................................................................. 2 6 2. Some Major Inconsistencies in the Science of Global Warming that Need to be Explained ...... 29 ` 2.1 What Is Science? ..........................,........................................................................................... 29 2.2 What Determines Changes in Global Temperatures? .............................................................. 30 2.2 Evidence for a Predominant Influence of Carbon Dioxide .......... . ..............................,............ 35 2.3 Pacific Decadal Oscillation/Atlantic Multidecadal Oscillation and ENSO as Explanations for ‘ Global Temperature Changes ....................................,...................,......................................... 40 . 2.4 Solar Variability ....................................................................................................................... 44 2. 4.1 CERN Study .,....................................................... Z ...................................................... 46 2.5 Urban Heat Island Effects and Other Problems of Surface Temperature Measurements ............. 49 [2.4.4 Copeland and Watts ..................................................................,................................. 56 2.4.5 Summary of Evidence for CO2 and Sun/Cosmic Ray Warming Hypotheses ............... 58 ?? 2.4. 6 Landscheidt (2003) Paper ..................................................................................... 59 2. 4. 7 Other Recent Research ............................................................................................... 59 2.4.8 Are Sunspot Cycles Telling Us Anything? .................................................................. 59 2.5 Solar Variability May Determine Major Climate Oscillations ............... . ................................ 61 2.6 Conclusions with Regard to the Best Explanation for Global Temperature Fluctuations ....... 61 3. Contrast between Continuing Improvements in US Health and Welfare and their Alleged Endangerment Described in the draft TSD ........................................................ . ........................... 64 3.1 · An Inconsistency: Enhanced Greenhouse Effect May Be¤Overestimated by IPCC ................ 67 3.2 A Second Inconsistency: Do Changes in CO2 Cause Changes in Temperature'? .................... 70 3.3 A Third Inconsistency: IPCC Climate Models Inconsistent with Observed Temperatures ..... 70 4. Detailed Comments .... Q ............................ ; ......................................................................................... 73 4.1 Executive Summary ............................................................................................................. ' .... 7 3 4.2 Part II ....................................................................................................................................... 73 4.2.2 New Paper Predicts 10 Year GW "P0sq20nement" ................................................... 74 4.3 Part III ......................................... . ............................................................................................ 74 4.4 Part IV ...................................................................................................................................... 74 5. Conclusions ........................................................................................................................................ 75 References ......................................................................................... . ........................................................ 77 ‘ About the Comments ................................................................................................................................ 81 Endnotes ..................................................................................................................................................... 83 2009 DRAFT vii \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! ' NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA A List of Figures Figure 1-1(a), (b), and (c): Monthly Global Temperature Anomalies (°C) as Measured At The Surface (Filled Circles) and in the Lower Atmosphere by Satellites (Open Circles) ............,............... 2 Figure 1-2: IPCC AR4 Figure 26 Updated ..................................................,.....,........................................... 4 Figure 1-3. Observed Tropical Cyclone Activity in Atlantic Basin, 1946-2007 (Black Lines) and Fit to Absolute Tropical Atlantic SST (Thick Brown Line, Top) and Relative Tropical Atlantic . SST (Thick Light Blue Line, Bottom) ..................................................................,.. Q ............... 9 ‘ Figure 1-4. The K-transect in West Greenland at 67°N .............................................................................. 11 Figure 1-5. Variations in annual velocity along the K-transect over 17 years ............................................ 12 Figure 1-6. Variations in: Velocity at Various Sites in August 2006 ........................................................... 13 Figure 2-1: One View of Temperature Variation during the Holocene ...................................................... 32 Figure 2-2: Pacific Ocean Water Temperatures during a positive and negative PDOs ............................... 34 Figure 2-3: Sixty-year Cycle in Global Temperatures Showing Clear Trends .................,......................... 34 Figure 2-4: Global Temperatures and CO2 Levels, 1880-2003 ............................................................,...... 36 Figure 2-5: Global Temperature Anomaly and CO2 Levels, 1940-70 .....................................................,.. 37 Figure 2-6: Global Temperature Anomalies and CO2, 2002-8 .................................................................... 38 Figure 2-7: Common Identifications Made of Causes for Global Temperature Fluctuations ..................... 42 Figure 2-8: MSU Data with Addition of Center Lines.... ................................ Q ,........... . .............................. 43 Figure 2-9: Solar Modulation of Galactic Cosmic Rays, 1957-2001 .......................................................... 47 Figure 2-10: Galactic Cosmic Rays and Climate: Past 500 myr .......... . ...................................................... 48 Figure 2-11: Galactic Cosmic Rays & Temperatures: Last 1100 yrs .......................................................... 48 Figure 2-12; Temperature Reconstruction for the Central Alps over Last Two Millennia, Obtained from i O-18 Composition of Speleothem from Spannagel Cave, Austria ........................................ 49 Figure 2-13: Satellite (UAH MSU LT) and land-based (HADCRUT3) Temperature Anomolies Compared .................................................................................,.............................................................. 50 Figure 2-14: Relation of Sunspots (or Lack Thereof) to Little Ice Age Periods ......................................... 53 Figure 2-15: Solar Irradiance since 1611 .................................................................................................... 54 Fig 2-?: Sunspot Cycles Derived Entirely from Global Temperature Data ................................................ 56 Figure 2—?: Decay in Sun’s Magnetic Field since 1999 ............................................................. 4 ................. 60 _ Figure 3-1: Yields of Major Cash Crops such as Corn and Wheat ............................................................. 64 _ Figure 3-2. Average Annual Heat-Related Mortality Per Standardized Million People in the U.S. ........... 65 Figure 3-3. Trends in ozone air quality ....................................................................................................... 65 _ List of Tables Table 2-1: Correlation between Global Temperatures and Various Explanatory Factors ........................... 36 ’ viii March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! I List of Acronyms _ List of Acronyms A AR4 Fourth Assessment Report of the IPCC AMO Atlantic Multidecadal Oscillation <>C Degrees Centigrade CAC Command and Control CCSP Climate Change Science Program - CERN European Organization for Nuclear Research CFC Chlorofluorocarbon ` CO Carbon Monoxide CO2 Carbon Dioxide Draft TSD March 9, 2009 version of the TSD · I EPA Environmental Protection Agency · GHG Greenhouse Gas i ~ IPCC P UN Intergovernmental Panel on Climate Change — i NOAA National Oceanic and Atmospheric Administration I NOX Nitrogen Oxides V OAR USEPA Office of Air and Radiation PDO Pacific Decadal Oscillation SO2 Sulfur Dioxide TSD Technical Support Document _ TSI Total Solar irradiance US United States · t US$ United States dollar ` . ` UHI Urban Heat Island UNCED United Nations Conference on Environment and Development I UNEP United Nations Environment Programme USEPA United States Environmental Protection Agency _ 2009 DRAFT I ix \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! ' List of Acronyms 2009 DRAFT xi \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis forGHG Emissions under CAA xii March 16, _ \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Draft TSD Is Seriously Dated and Updates Made Are Inadequate 1. Draft TSD Is Seriously Dated and the Updates Made Are A - Inadequate The draft endangerment TSD is largely a dated document which relies heavily on the Fourth Assessment Report (AR4) of the U.N.’s Intergovernmental Panel on Climate Change (IPCC). A lot has happened in those intervening three years since then. The IPCC’s AR4 was published in l the spring of 2007, but to meet the deadline for inclusion in the AR4, scientific papers had to be published by late 2005/early 2006. So, in the rapidly evolving field of climate change, by A grounding its TSD in the IPCC AR4 the EPA is largely relying on scientific findings that are, by early 2009, largely 3 years or more out of date. The six developments described here should in our view greatly influence any assessment of "vulnerability, risk, and impacts" of climate change _ ‘ within the U.S. Therefore, the extensive portions of the EPA’s Endangerment TSD which are based upon the old science are no longer appropriate and need to be revised. 1.1 Where to Find a Discussion of Various Topics in These Comments Section 1 summarizes six of the many important new developments since the cut—off date for the IPCC AR4 report that need to be reflected in the Draft TSD. Section 2 summarizes some of the critical inconsistencies between the Draft TSD and dataconcerning the causes of global warming. Section 3 summarizes data showing continuing increases in US health and welfare ` despite increasing GHG levels. Section 4 presents detailed comments on the Draft TSD. The final section 5 summarizes the conclusions reached in these comments. A ` 1.2 — Global Temperatures Have Declined Significantly Global temperatures have declined (Figure la)—extending the current run of time with a statistically robust lack of global temperature rise to eight years (Figure lb), with some people ~ arguing that it can be traced back for 12 years (Figure lc). 2009 DRAFT 1 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endan erment Analysis for GHG Emissions under CAA Global Temperature Anomalies, January 2000- October 2008 -? 2,...2....--.....»._-,......,._--,.........,._..,Q2; -_¢....._.,.-....-_, ..2-... -....2.2- 2..2 I .6 [gal, ‘ U G 5 , nr *-5; 2.. -, up ,• ;__ I · e .4 s,__ ,·~·,»* 5 _ - (zr~—·..______ ’,F»¤.__ {LI ( _; \ T0 rf; ··»——--» --» .__ 5; B ° Err ,..v · ‘’‘· *-. M., r' I" E {jj} m`>:€.Y*·(;L-,-___ 3_· $t;r_C> _ il _r` €*r%£·;,»*»t-.“_____ I, Ei; -2) __l IIIIJ! "§‘·¤?-5jI.Jl";.I-:?*I 4—""· ··,._ E 2 rv _ I _ ’r .· ‘—’ *93 _ 1 I "•“r CRU Surface Observatrons r · »,.· r rl A ` I #·i>~ UAH Satellite Observations ‘ `y\}·’ .._ 2 r——,——.-~— r~r-·.-—T-»,--,·--.~—·,--—r··,—r—-—~.—-—~—T-—.·»·—-.~~-—-e ·—,»·-.·-~-——,—-r- .-—»·-—#—-ir-r—-—,—-1-——.»——.—;1~~ 2006 2007 2008 2009 _ Global Temperature Anomalies, January 2001- October 2008 n? U .,,.,, .. ,.,\ .... ..., ,. ,,_. .._b, ...\. .- _.,, . A .,.,. .. J5 · 2 gr ··~ - 9 ar S-} .5 I......... I , M I " ` E I ~~·= J P—~»’;*E'*"$’I ’ * ( t ·" I J ·§*r ¤r,:*0·• ré wi rr·‘¥r“II{ _3k »""' 5"lr:""·.Tg-flll A-l;·lo’?g·L—DA fl`I|l,%Ir‘b 4 ‘ 2 "I L`Ai& ':€!"`I..I'! U"- I J1 C”'?:__"`ILTiY§" ‘“"··`&·(nY`?*,,-__ g . ‘ I JI_‘iIl]> I.,} V1 T atl `··' 4* |r ·.. _ E -I ‘ "*' In I It IW? I 3 ¤ § 1 _r -·;•e· CRU Surface Observations II V I"" I'lI" I " I ·®— UAH Satellite Observations “·* I}·t’ .2 ev-,~,»-.,.,-,»,», ».,- ~.»,,·..~e~e»»,,~,.,-,--»~,,~.-.~,,-,.-,»»,»».,», -,.. -,»,,~»,~,—.~.,e»,--,.T¤»,°L-M,- 2000 2001 2002 2000 2004 2005 2006 2007 2008 2009 ’ Global Temperature Anomalies, January 1997- October 2008 e .8 r “*“*·"“‘j{j“*“·**"*“—*·"“*"~“*"*"“‘····"·`*—"·*““"‘—*"`*"“· aj angry I rl *, >» . · • . ,:1 _ P , -1%- M _` _ E -4 r~·—e···a¢··r* Mrrrrer ere- rr T- FEW »·,» * 9 W E I A <,> ,r_ I Iir{ ,¥5?·Iri:- :,5 2 — ·e~r ~ ~:•rr·<%~~~r»¥r*=·~ r·»re _·- I <‘·· =¥;7··i§a»r zgr ` ‘··· I EI- E; B3 r___rT¤ Ly rl . I pr 0 I I ‘—?‘_ r·' ,2 ··2 " O Q -~•—· CRL} Surface Observalioirb . L ——»;::~ UAH Satelllte Observetlons #,4 · ··**“*··*··r“··~···rMMw·*~"···*~······:‘*~·**··*···‘*r“**··"·‘····"r··‘·*·“**··*··‘r"r~·*·*···* 1995 1998 2000 2002 2004 2005 2008 2010 Figure 1-1(a), (b), and (c): Monthly Global Temperature Anomalies (°C) as Measured At The Surface (Filled Circles) and in the Lower Atmosphere by Satellites (Open Circles) V ` 2 March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! A Draft TSD Is Seriously Dated and Updates Made Are Inadequate Top (a), Last three years, January 2006—Oct0ber 2008; Middle (b) Last eight years, January 200l—October 2008; Bottom (c), last 12 years, January 1997-October 2008. a Sources: Hadley Center; University of Alabama—Huntsville. In addition, both the PDO and AMO have turned negative in September, 2007 and January, J 2009, respectively (see section 2.2 below for a discussion of the crucial role played by ‘ PDO/AMO in global temperature changes). The last time that this happened, in the 1960s and 1970s, the climate in at least North America experienced record cold temperatures and generally lower temperatures and global temperatures declined). At the same time atmospheric CO2 levels have continued to increase and CO2 emissions have accelerated. A _ 1.3 IPCC Global Temperature Projections Look Increasingly Doubtful Because of recent substantial decreases in global temperatures, the IPCC projections for large increases are looking increasingly doubtful. This is illustrated by this graph comparing the two: IPCC AR4 TS Fig. 26 Updated J __,.__w____._.s__.L%£.>i>_§;.lmv_LL1!r_<>_0_lrr)_,s”_.______”_ M ·-*HJadCRUT ________________,________________, , _ ···-UAH LT (Adj. to Sfc] L __;_,__ r,. ~‘·‘ ` ~ A ‘ :.3;, ....._.__.....__._.._._._.._ —··¤2 . OJ ~ Commit :::4 . . . __—_ 0 4 _-—i_ l J A *`; l ·— M §·~·~·—r···—~—·· ··· ,,2 J. M. ._...._._..__...._m;%_.__...._.i_.__._._.___2.______ i E r V {2 2 A . 0.1 " *···——··——~—·*···———·—j·—·——-——-———— — g 1990 1995 2UOO 2005 2010 2015 2020 2025 ·2009 DRAFT 3 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA Figure 1-2: IPCC AR4 Figure 26 Updated Source: http:llicecap.us/images/uploads/ipccchart.jpg; part of article by Marlo Lewis on Planet Gore at http://planetgore.nationalreview.com/post/‘?q=MTYwMjRiZjJhMmUxYWE2MmQONDZhOGM 0M2Q3ZWUzMmE; as reproduced on icecap.us on August 14, 2008 If global temperatures are viewed as suggested in Figure 2-8 below the large downward drop in 2007-8 appears to be simply a return to the 1978-97 _range and might not be particularly noteworthy. If, on the other hand, global temperatures are viewed as an increasing trend, which the Draft TSD appears to do, then the 2007-8 drop would appear to bring temperatures well outside the likely range suggested by the IPCC projections. So if the former viewpoint is taken, then the Draft TSD needs to explain how it could be that there has been such a great divergence from the IPCC projections. _ [The climate system is extremely complicated and the GHG/CO2 hypothesis together with other recognized influences ("climate forcings") on climate do not fully explain all of the available historical climate observations even for the current Holocene Epoch. The IPCC is basically using computer models to predict future climate and temperatures. These models are only as good as the relationships they assume and the data that they use. The most prominent alternatives to the GHG explanation for GW during the Holocene primarily attribute much more significance to solar variability} These argue that changes in the sun’s eruptional activity, solar » wind, and magnetic field, among other characteristics, have been major determinants of global temperatures here on Earth. Since this has not been taken into account in almost all the IPCC models to date these models may need to be changed to do so if they are to more accurately reflect reality. Unfortunately, despite every effort to consciously avoid doing so, it is all too easy to develop models that explain historical data by "fitting the data"; it is much harder to 1 ld. See also Theodore Landscheidt (2003), and Richard Mackey (2007). For a summary of recent I developments in the Svensmark discussion see Jacopo Pasotti, Geophysics: Daggers Are Drawn Over Revived Cosmic Ray—C/imate Link, 319 SCIENCE 144 (January 11, 2008). See also Vincent Courtillot, Yves Gallet, Jean-Louis LeMoueI, Frederic Flateau, and Agnes Genevey, Are There Connections between the Earth’s Magnetic Field and Climate, 253 EARTH AND PLANETARY SCIENCE LETTERS _ 329-39 (January 30, 2007). These findings are at considerable variance with the IPCC discussion of the contribution ofisolar variability to climate. See P. Forster, V. Ramaswamy, P. Artaxo, T. Berntsen, R. Betts, D.W. Fahey, J. Haywood, J. Lean, D.C. Lowe, G. Myhre, J. Nganga, R. Prinn, G. Raga, M. Schulz and R. Van Dorland, 2007: Changes in Atmospheric Constituents and in Radiative Forcing. ln: Climate Change 2007: The Physical Science Basis. Contribution of Working Group lto the Fourth Assessment Report of the Intergovernmental Panel on Climate Change [Solomon, S., D. Qin, M. Manning, Z. Chen, M. Marquis, K.B. Averyt, M.Tignor and H.L. Miller (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New York, NY, USA, pp. 188-93. 4 March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Draft TSD Is Seriously Dated and Updates Made Are Inadequate accurately predict future events using such models. One comparison of model predictions with actual observations by Douglas Hoyt finds that the models were successful in one case, unsuccessful in 27 and tied with observations in 4.2 So the ultimate test of the significance of GHGs in GW may not come as a result of new scientific inquiries using current knowledge but rather from experience over coming years and decades and comparisons of this experience with the predictions that have been made. If global temperatures should decline further despite continuing increases in GHG levels, as some skeptics and experts on solar cycles have predicted, advocates of the GHG explanation for GW may have a difficult time explaining the new data in ‘ terms of their hypothesis.3 If, on the other hand, temperatures start increasing rapidly at the same time that solar activity decreases, the skeptics may have a difficult time explaining how that could be. In 2007 the IPCC concluded that they were at least 90 percent certain that human q emissions of GHGs rather than natural climate variations were warming the planet. That leaves up to a 10 percent risk according to the IPCC that this conclusion might be in error. Some observers have pointed out that the solar magnetic field has been unusually low since a sudden drop in late 2005 and that the next sunspot cycle 24 appears to be late starting and that this may presage a colder period for global temperatures.4 If the increase in temperatures is not largely 2 Douglas Hoyt, "Greenhouse Warming Scorecard," April 2, 2006, available at . http://www.warvvickhughes.com/hoyt/scorecard.htm 3 Three of the four principal indices of global temperatures recorded their highest temperatures in recent years in 1998, so can be said to have been declining since then (see http://wattsupwiththatwordpress.com/2008/03/08/3-of—4—gIobal-metrics—show-nearIy—flat-temperature- anomaly-in—the—last-decade/#more—828). As usual, it is hard to distinguish random climate changes from a new trend. But all fourof the indices show surprisingly large drops between January 2007 and January 2008, which may or may not be a precursor of further declines. This 2007-8 decline is more or less equal to the temperature increases since 1900, depending on which index is used. Graphs for all four can be . found at Anthony Watts, January 2008 - 4 sources say "g/oba//y coo/er" in the past 12 months, February 19, 2008, available at http://wattsupwiththatwordpress.com/2008/02/19/ianuary-2008—4—sources4say- gIobally-cooIer—in-the—past-12—months. Anthony Watts, Where Have All the Sunspots Gone? February 13, 2008, available at http://wattsupwiththat.wordpresscom/2008/02/13/where—have-all-the—sunspots-gone lt is interesting but hardly conclusive to compare the four temperature charts referenced in supra note 8 or a comparison of t _the four (http://wattsupwiththatwordpress.com/2008/02/27/a-look—at-temperature-anomalies—for-aIl—4- global—metrlcs) with the observed geomagnetic averaged planetary index shown by Watts in his February 13 entry, particularly the sharp drop in late 2005 with no rebound as of early 2008. Watts believes that this drop may be significant in terms of the Sun’s internal dynamo, and may imply much lower global temperatures to come. The relative influence of recent solar variability versus GHG changes is questioned, however, by research published in 2007 which concludes that: There is considerable evidence for solar influence on the Earth’s pre-industrial climate and the Sun may well have been a factor in post-industrial climate change in the first half of the last century. Here we show that over the past 20 years, all the trends in the Sun that could have had an influence on the Earth’s climate have been in the opposite direction to that required to explain the observed rise in ` global mean temperatures. 2009 DRAFT 5 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA due to higher GHG levels, as currently hypothesized by the IPCC, reducing GHG emissions may have less effect than the advocates of GHG emission controls now believe.5 All this is not to argue that the GHG explanation of current global warming is wrong—only that the climate l system may be more complicated than our current understanding of it and that there exists more uncertainty than is often acknowledged. The important thing is to take these uncertainties into account in proposing an effective and efficient control approach rather than ignoring them and making guesses as to what assumptions to make as to climate sensitivity to increased GHG levels or adopting a single hypothesis that discounts the substantial evidence of the impact of solar variability on Earth’s climate. Given these mayor uncertainties, it would be very easy to conclude that very little could . reasonably be said about how to value the economic benefits of reducing GHG emissions. This paper, however, argues that some very important conclusions can nevertheless be reached in spite of these uncertainties and without assuming them away. 1.4 Consensus On Past, Present and Future Atlantic Hurricane Behavior Has Changed - W The consensus on past, present and future Atlantic hurricane behavior has changed in our ` view. Initially, it tilted towards the idea that anthropogenic global warming is leading to (and will lead to) to more frequent and intense storms. Now the consensus is much more neutral, arguing that future Atlantic tropical cyclones will be little different that those of the past (e.g. Knutson et al., 2008; Vecchi et al., 2008). Trying to identify a statistically significant and robust human signal in the observed history of Atlantic basin tropical cyclones, whether over the past 100+ years, or in recent decades, is probably untenable. This conclusion is based on increases in hurricane activity in recent decades · See Mike Lockwood and Claus Frohlich, "Recent Oppositely Directed Trends in Solar Climate Forcings - and the Global Mean Surface Air Temperature," Proceedings Of The Royal Society A, 2007, available at http://publishing.royalsociety.org/media/proceedings a/rspa20071880.pdf. For a contrary view see Henrik Svensmark and Eigil Friis-Christensen, "RepIy to Lockwood and FrohIich—The Peristent Role of I the Sun in Climate Forcing" (March, 2007), available at http://vnMN.spacecenter.dk/gublications/scientific- report-series/Scient No. 3.pdf. Lenscheidt supra note 7, would presumably also not agree. Nicole Scafetta and Bruce Wood, ls Climate Sensitive to So/ar Variability? PHYSICS TODAY, March 2008, pp. 50-51, conclude that the Sun "couId account for as much as 69% ofthe increase in Earth’s ‘ average temperature," contrary to the conclusions of the IPCC. "Furthermore, if the Sun does cool off, as some solar physicists predict will happen over the next few decades, that cooling could stabilize Earth’s ‘ climate and avoid catastrophic consequences predicted in the IPCC report." - 6 March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! A Draft TSD Is Seriously Dated and Updates Made Are Inadequate _ · far exceeds that generally projected by climate models run with observed changes in X anthropogenic emissions, and there is ample (and growing) evidence that the Atlantic hurricane ‘ 1 record is characterized by multi-decadal oscillations that are tied to multi-decadal oscillations in j oceancirculation, atmospheric circulations, and patterns of sea surface temperature variability. 2 That these multi-decadal oscillations can be traced backward in time for at least several centuries, is strong indication that they are a natural part of the earth’s climate system, rather than being primarily driven by human alterations of the earth’s atmosphere. This conclusion has important implications for the future, as it suggests that as the sign and strength of the natural ' cycles controlling hurricane behavior wax and wane, so to will the future activity of Atlantic · tropical cyclones, both in frequency and intensity. The contrary conclusion——that anthropogenic "global warming" is largely controlling the activity of Atlantic tropical cyclone activity- portends, conversely, an ever—stormier future. V While we have tried to present clear evidence that the scientific tide seems to be turning in the direction of a predominately "natural" origin of past, present, and future, Atlantic tropical cyclone variability, the draft TSD appears to rely on out-dated findings to support its claims of a significant anthropogenic impact on current and future Atlantic hurricane activity in their current draft versions of climate change summary documents. We hope that the revised draft TSD will revised in this regard. . Hurricane researchers Gabriel Vecchi, Kyle Swanson, and Brian Soden published a paper in . Science magazine which summarizes their view of the subject. They lay out the arguments for . each case: _ Anthropogenic case: There is a strong correlation between sea surface temperatures (SSTs) in the tropical Atlantic Ocean and Atlantic tropical cyclone activity. And, in recent decades, as the global temperatures have risen_(presumably from human activities) so too have the SSTs in the tropical Atlantic which has promoted an increase in the frequency and intensity of Atlantic hurricanes. As climate - models run with increasing levels of atmospheric greenhouse gases indicate Atlantic SSTs will h increase in the future, so too will Atlantic tropical cyclone activity. Natural case: There is a strong correlation between the SST changes in the tropical Atlantic Ocean relative to tropical SST s in other ocean basins and Atlantic tropical cyclone activity. ln recent decades, the 2009 DRAFT I 7 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! · NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA tropical Atlantic Ocean-has warmed faster than other tropical oceans and thus, Atlantic tropical hurricane activity has picked up, both in frequency and intensity. As climate models run with increasing atmospheric concentrations of greenhouse gases do not project that the tropical Atlantic will warm faster than other tropical oceans, future tropical cyclone in the Atlantic will be driven by natural fluctuations in the pattems of tropical SST increases rather than simply an I overall SST increase. l g i Vecchi et al. (2008) suggest that empirical evidence is insufficient atthe current time to draw a distinction between the two scenarios. However, if one were to turn to purely physical I arguments or to the latest state-of—the—science dynamical calculations from high temporal and ` spatial resolution modeling efforts, one would begin to gather enough weight to start to tip the W scale in the direction of natural cycles. Vecchi et al. (2008) lay _out these lines of evidence and summarize their conclusions in Figure l-3. ° 8 1 March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Draft TSD Is Seriously Dated and Updates Made Are Inadequate Atlanwciro icalcyclona wer dissi ationimiex anomalies DD P DD D D DD DD DD s.sr mo Based on Absolute SST, AX fh)r,»· r “""“ l\1*mu;1iobSu‘i¤:d PDI (1946-200]) / **"· ' ri? .. ¤—•—-¤ Fl·»—r;·yr::¤r¤iv1s¤rva:rlPt’3l (1946—2D0h ' l _ Dj ‘ M? snr Fiféwear Pblbascd unobserved nbwlusc SST (‘19··l6·-ZD¤7);r¤= 0.79 fD¤"ff E lm" Slazisticalieyerrrfuldewsswnling ofglobaldirrrawirniodeisi19·1i»~—2‘l0D) A _,,»·*»—"¤\, S r,,_t D r - DD D . » D D DD x` M ‘‘!/‘‘ ' Da .·-·—~:$;i`\.¢* ‘·*’¥· - 0 ·· fndivsiiralrumlci -~·»~ m•er.•»g·ru{2·1r¤iodois ··~· wi »·<,:>» . "·-at `S 9 fi jo _ r Ds-; if I l g.; so D ‘ ju $ 5; `§i§`J>i¤*'$e;¥<' i` ; ‘ D ig .*·~ I ‘i¤*,·*2 ag, 4 D D s F M 1 ' $5 -1.0 V - ~-‘‘ J T: r,_ kgs D ‘ DE ‘ ,i D,!J`—£?§·D€ S ` ! D ~ D ··‘`» D ,,, ·¤ := »·- r R; 1, {_ D_, r . » A Q if .;, g . _ ,l·¥¤ ~D»rD si ·» E Lo D lg w ra SD- , D7 1D. , ap V5 | A 7(` g'\`,! e #5 · - Di r Q T ‘· TW W ' r jr ‘* D 4 §D· ·D,*D.\ l ~·» ¢` D D»1·:Da¤!¥TDDDDD"T€‘{D DD DD D .._s DD ,rrD .D D DD D D D is rg g 0 I A lajfk lj fi — ·· V- · -»-·.· - 4 . . , , ,, _D1. ,_A_g,,_D ,,,7, Q_ ri ~.» r ‘ } `$ ` ~ i`·r ¤ ;_-·’ _ D.E..m..&..,,;~ Iiigxlrrescixriirxnnwdclprujecliuqvs{m·e·:ap:_iuni D ALB ` *;.*5 hh - D S i 1960 1980 » 2000 2020 2040 2060 3080 2100 Year :,- *°·° --m»¤r¤1¤¤‘a»»mu runcwwzcura in .-_ D Fiv¤—ywzar»¤bserxrr»d PM f19¤56~2¤G7Z• Mg E ` .... Five-yeair PDI based uri ulrserml 1·ol.iki·:e SST (‘19=16—2007l·; reil.?9 ii 'U ‘ $!.azi1_tical 5-year PN dewnsrallrsg of glam! clkrmte models (1*2-164100} ::1 L lnriivfrioalsircdel •- rPr·.•é·r.vgrief2¤iri»vdc1s L - E ao g V g 4.0 ` · E .. High-resolution medal pmicclmm (s·r>r.·Dc;w¤liou) 'E 2.0 D D #{/1 jr D ;\ _ T’gYW*·~~' - •§‘ V V. yyxl ig"} }$;‘\'·*€& A 1*. `r ` ·,v` Q? D 3 . Dx D r D , ` q i i -··»,.» Q §D D_1,,r - —” DD D < · '*{· r" ‘· " `. V li I '. 'l ="¤§·. j* owl YD`} rk; -2% . rf · é E 0 _ D ‘D·‘ DDD= — ra-#»%frii*D* .D:3`2D· L as Lax : =» ·4··r E ¤ »;· ~—2-0 · ir ·~» " ’ a i_ 1. · ~»5D; ~D ru ,/ A il { ‘s L *1 4 2 DD D DD D D D sa Dsr·»»D*·¤s*‘°“r¤· rc if `*’D We D z·’ D ·D =¤'~’ TT1TIiYI'!T‘I3TI‘W¥NNHhTTTF?Ip¥HWT¥HNW¥N1TF¥hTUH7NTTHH¥!1’WNTHI1TUhH7HTH TT'{HW¤ Yi me mso 2000 2020 · me me zoao 2100 s Year Figure 1-3. Observed Tropical Cyclone Activity in Atlantic Basin, 1946-2007 Black Lines and Fit to Absolute Tro ical Atlantic SST Thick Brown Line , D s Top) and Relative Tropical Atlantic SST (Thick Light Blue Line, Bottom) Climate model projections to the year 2100 based upon the observed tropical cyclone/absolute D SST relationshi oran e lines, to and observed tro ical c clone/relative SST relationshi blue P Y 2009 DRAFT - 9 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA lines, bottom). The projections made by high resolution dynamic hurricane models are indicated by the green symbols on the right of each chart (see Vecchi et al., 2008 for additional details). The top chart in Figure 1-3 shows a cumulative measure of annual Atlantic tropical cyclone activity (thick black line), a statistical fit to the observed activity using absolute tropical Atlantic V SSTS (thick brown line) and the climate model projections of the future Atlantic tropical cyclone activity based upon that statistical fit (thin orange line are individual model projections, the thick orange line is the model average). Cleary, under this scenario, Atlantic hurricane activity is _ projected to increase dramatically in the future driven by anthropogenic global warming. The bottom chart of Figure 1-3 shows the results of the scenario in which Atlantic tropical cyclone activity (thick black line) is driven by relative changes in the tropical Atlantic SSTs (thick light blue line). Climate model projections of this relationship are indicated by the thin dark blue lines and the thick blue line model average. In this scenario, global warming has little impact on Atlantic tropical cyclone activity. The current "best thinking" as to the impact of global warming on Atlantic tropical cyclone activity from high resolution dynamical hurricane models is indicated by the elements in green (stars, squares, triangles, bars) at the far right-hand side of each chart. In each case, the high- resolution model results fall within the spaghetti of the model projections depicted in the bottom chart and not within the spaghetti of the top chart. This implies that our best hurricane models are lending their support to side maintaining that there is little impact from global warming, and instead, tropical cyclones are largely modulated by natural variability. F Obviously, there is still a lot of work that needs to be done in the arena of hurricane modeling before this issue can be cleared up, which is the primary message that Vecchi et al (2008) want ( you to take home with you, but, along the way, Vecchi et al. (2008) strongly demonstrate that based upon what we now know, it seems that natural multi-decadal oscillations in the climate of the Atlantic Ocean trump anthropogenic global warming, when it comes to being the dominant driver of 20th and 21st century Atlantic hurricane activity. A _ 1.5 Changes in Outlook for Greenland Ice Sheet _ The idea that warming temperatures will cause Greenland to rapidly shed its ice has been cast into doubt by new results indicating little evidence for the operation of such processes (e.g., ` v_an de Wal et al., 2008; Joughin et al., 2008). _ J 10 March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Draft TSD Is Seriously Dated and Updates Made Are Inadequate A recent article in Science has an alarming title: "Large and Rapid Melt-Induced Velocity Changes in the Ablation Zone of the Greenland Ice Sheet." However, once one examines this 2 paper, there appears to be an amazing twist given the threatening title. To begin, the research l I - ; was conducted by a large team with the Institute for Marine and Atmospheric Research at V Utrecht University, Netherlands; the authors state that "This work was supported by several grants from the Netherlands Organization of Scientific Research and the Netherlands Polar Programme." , Van de Wal et al. focused their attention on measurements that are being made on the ice alon the west coast of Greenland 'ust north of the Arctic Circle Fi ure 2 . For the ast 17 ears . Y ¤ . V annual measurements have been made along the "K-transect" to measure movements of the ice sheet. However, they state "we started more detailed position measurements in 2005 by taking advantage of technological developments of GPS equipment and data processing. The new instruments record hourly position of stakes, which are drilled into the ice. The GPS (single- frequency) units need to be serviced only once in a year and deliver an ice velocity record with a · temporal resolution of 1 day or better.” To say the least, geospatial technologies are showing up A everywhere in our lives from the family car to the golf course and now to our favorite transects in Greenland. ‘ 50km . " .,·‘ _u·=e " ~ be V . =ia »·‘t `r`·, ai -,i_ ` i ‘ :4 i e_$HR it 4 ..»~ » ( 10 i ”* ,i 9 ir - V Ki 8 rr · ,,.t .·.·.. . . I t 5 e__-· 5 · _. c I ~ 3a ` '°‘,; 3 `»`— T ·jj-QQFY _,,· ;_5;j;§;;g g‘_·§Tfg " ¤ ` 7 .... ‘ ,·.vr.r e ~ 1V - V ` *%t ifiiwg erri . iiVe3 rer Rm V e·»e · ···e V · »¤i·ee ~ · Figure 1-4. The K-transect in West Greenland at 67°N The background NASA—Modis/Terra image is dated 26 August 2003. K is Kangerlussuaq, V ' . , E uilibrium Line Altitude. 3 The equilibrium line (indicated by the black line) is at about 1500 m above sea level. The image 2009 DRAFT 11 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA clearly shows zones, from right to left, of snow (Site 10), wet snow (Site 9), dark ice (Site 8), and 0 clear ice (Sites 4, 5, and SHR) (from van de Wal et al., 2008). ` Probably the largest surprise in the article can be seen in the Figure 3 in which we can see the velocity changes at many sites over the 17-year period. The authors note that "The overall _ picture obtained by averaging all stake measurements at all sites for individual years indicates a small but significant'(r:0.79, P < 0.05) decrease of 10% in the annual average velocity over 17 years". Despite all the talk about moulins, melting, rapid acceleration of ice, van der Wal et al. reveal that the ice movement in western Greenland over the past 17 years has slowed significantly! 140 P ` mu , V j i ’ . 1. A . S . . · · aii ""“S‘* r E too ttaz i·· a? i j E. ~ A ` W . * · . i_ — .» -—-v-·Sl-{F1 ° IG H l ·* ._,_,¢.,;._“....€.Z’5 V l 2 yr ` 4 A _* € ‘¤_Al__l g .60 ( zrnzlh - _ Q V ` . . i’‘‘,‘i,, .%*11) _,,, 40 v {xii} · ’ 20, _ . V .. . .. 1990 1995 2000 2005 2010 2015 . Time (yrs) . Figure 1-5. Variations in annual velocity along the K-transect over 17 years Sites with a significant decrease over time are depicted as thick lines. Source: Van de Wal etal. (2008). In discussing their results we find some very interesting language, to say the least. At one place they write "it has been suggested that the interaction between meltwater production and ice velocity provides a positive feedback, leading to a more rapidand stronger response of the ice sheet to climate warming than hitherto assumed. Our results are not quite in line with this view." van der Wal et al. iiuther write "Longer observational records with high temporal resolution in other ablation areas of the ice sheet are necessary to test the importance of the positive-feedback mechanism between melt rates and ice velocities. At present, we cannot conclude that this 12 March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! A Draft TSD Is Seriously Dated and Updates Made Are Inadequate feedback is important." Again, _we tend to say this moulin link to drowning the World Trade Center Memorial is nonsense, and the empirical evidence is overwhelmingly in our favor. p So how did this article ever get titled "Large and Rapid Melt-Induced Velocity Changes in the Ablation Zone of the Greenland Ice Sheet"‘? Well, as seen in Figure l-6, the Garmin’s (or some other product line) showed an unusually large increase in velocity from one site a week in August in 2006. No one says Mother Nature is not capable of surprises, and the research team was a bit taken back by the sudden movement. But when we examine this article, we are most impressed with the results over the 17-year period and the lack of support for the notion that somehow the velocity of ice is increasing during a time of greenhouse gas build-up! .500, rsi. .. _ . I V `··*·i··——S·4 : · 400i, “"‘*"‘"$**'F* i . N ,__ ;.Q;..g§£ · r T E. sony i is — . Q _ g r . ,,, ’ T 2 zoo}. _; . _ qg 5 V » if · Q V > ·*.,, r a t T mg W v 2 " if , ( * ’* ‘ ui . _ . ‘ _ 3-Aug 8-Aug 13-Aug 18—Aug 23-Aug 28—Aug _ » Date Figure 1-6. Variations in Velocity at Various Sites in August 2006 Source: Van de Wal et al. (2008) _ 1.6 SeriousRecession Has Greatly Decreased GHG Emissions Compared to the Assumptions Made by the IPCC One of the worst economic recessions since World War II has greatly decreased GHG emissions compared to the assumptions made by the IPCC several years ago. To the extent that ambient GHG levels are relevant for future global temperatures and to the extent that this may be much more than a minor, short recession, these emissions reductions should greatly influence the adverse effects of these emissions on public health and welfare. The current draft TSP does not 2009 DRAFT . 13 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA reflect the changes that have already occurred nor those that are likely to occur in the future as a · result of the recession, but it needs to. In fact, the topic is not even discussed to our knowledge. 1.7 Long-term Water Vapor Feedback Reported to Be Negative A newly published paper in a peer—reviewed journal (Paltridge, 2009) reaches the potentially highly significant conclusion that The upper—level negative trends in q are inconsistent with cIimate—model ~ ‘ calculations and are largely (but not completely) inconsistent with satellite data. Water vapor feedback in climate models is positive mainly because of their roughly constant relative humidity (i.e., increasing q) in the mid-to- · · upper troposphere as the planet warms. Negative trends in q as found in the A NCEP data would imply that long-term water vapor feedback is negative- A that it would reduce rather than amplify the response of the climate system to external forcing such as that from increasing atmospheric CO2. This paper is of particular significance because it concludes with a number of important qualifications that a key assumption in the GCM models concerning a strong positiveiwater feedback is incorrect since it is negative rather than positive. The following (from Gray, 2009) explains why this assumption is so crucial and why a change in it is not only expected but of great significance: 1. Introduction There are about 20 different General Circulation Model (GCM) groups _ around the world that have been conducting extensive numerical modeling simulations of the likely changes in global mean temperature that should be expected to occur from a doubling of atmospheric carbon dioxide (CO2). Carbon dioxide has so far risen about 33 percent (to 385 ppm) over its pre- · industrial values and about 15 percent during the last 30 years. It is expected that there will be a doubling of atmospheric CO2 by the latter part of the 21st century. Most of these GCM simulations indicate that there will be a 2-5oC (4-9oF) increase in global mean temperature by the time this · doubling takes place. Such large warming as obtained by the GCMs would cause great changes to human society. These large warming scenarios are highly unlikely, however. The GCMs greatly exaggerate the potential warming that will occur. These exaggerations are due to: 1. GCMs assume that an increase in atmospheric CO2 will cause weak global warming and an increase in global precipitation that will lead to a large increase in upper—Ievel water vapor and cloudiness. They simulate that this increase in water vapor and cloudiness will block large amounts of infrared radiation emitted to space. New observations by satellite and reanalysis data, however, do not support these GCM assumptions. The · global warming that has occurred since the mid—1970s has been . associated with a modest decrease of global upper tropospheric water 14 March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Draft TSD Is Seriously Dated and Updates Made Are Inadequate vapor and an increase of Outgoing Longwave Radiation (OLR). These » measurements contradict model predictions. 2. GCMs do not currently accurately model the gIobe’s deep-water ocean circulation. Accurately modeling the global ocean’s deep circulation is fundamental to any realistic understanding of global temperature change, as this circulation appears to be the primary control of global surface temperature. The global warming we have seen since the mid—1970s and over the last 100 years is likely largely due to reductions in the rate of global ocean deep water circulation (or the MOC) which is viewed as being driven by global ocean salinity variations. CO2 changes play no role in these ocean changes. · The most basic AGW question appears to be how we would expect upper level water vapor changes to respond to increases of CO2. The GCMs - - program a very large (and in my view, quite unrealistic) upper level water » . vapor increase as a response to CO2 doubling. This is a consequence of the GCM’s faulty sub-grid convective parameterization schemes and the strict interpretation of the Clausius-Clapeyron (CC) equation to upper level temperature changes which dictate that water vapor increase with temperature increase. Observations indicate that this is not occurring. The cumulus convective schemes employed by the GCMs develop unrealistic high amounts of water vapor which block too much OLR and cause artificial warming which is 2-4 times greater than the warming that would result from the CO2 blockage of OLR by itself. A Observations and other theoretical analysis indicate that little or no upper level water vapor increase will occur with a doubling of CO2. If this is true then the CO2 induced global temperature increases will be only a quarter or a third as much as the GCMs currently indicate. All the various data sets (Figure 1) that I and some of my colleagues have been working with indicate that upper level water vapor (near the radiation emission level) should not necessarily rise with increases of CO2 and global temperatures. Rather than rise, there appears to be a tendency for a slight upper tropospheric decrease in water vapor as upper level temperature and CO2 have increased. This would allow about as much water vapor induced OLR to space after CO2 amounts have increased as they had before. Little water vapor induced warming should result. There are good theoretical arguments for this being the case. [This does not mean that lower tropospheric water vapor and net precipitable water content will not slightly rise as CO2 amounts double.] Thunderstorms and cumulonimbus (Cb) activity are the primary mechanisms to bring mass into the global upper troposphere. Such deep convective activity is highly concentrated at any one time to only about 2-3 percent of the global area. The mass that goes up in the deep convective cloudsis then advected outward from the convective areas to the environment and sinks in response to the upper tropospheric radiational ‘ cooling, cirrus evaporation cooling, and the need for mass balance (Fig 2). ` The vertical gradient of saturation vapor pressure in the upper troposphere is very large. Upper level subsidence requires that upper level water vapor and RH values remain low. There appears to be no way a few A 2009 DRAFT 15 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! I NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA _ i percent increase in deep convection with CO2 doubling could raise upper level water vapor amounts enough to significantly reduce OLR beyond the V reduction of OLR by_ the increased CO2 by itself. _ A 1950 Rznnulysis Data 2003 y 1984 és, gl 4 2004 ` } 7 A ISCCP Dato Scfiwarlz . was-ma Figure 1. Data sources utilized in this study. NCEP/NCAR Reanalysis data (1950-2008) of wind, thermodynamics and OLR derived radiation, and data from the International Satellite Cloud Climatology Project (ISCCP) for the period of 1984-2004 which contain a variety of radiation components are examined. ”~.ri A gg (Wim ) { zen g I t 230* _ ` ·` V 226 I C ‘ if Emission _' . ‘ —' _ V ..1, .... * ···· · * ···· ·‘ is g,_`,,'·5 {{>_;*r .‘..`.’JJ_.'r _ iii. Hr: _='»" _ 1} it gw; iP¢9·Hs? · Evap. + Figure 2. Idealized portrayal of how deeper and more intense cumulonimbus (Cb) convection can lead to progressively more return flow ` dry subsidence. Enhanced upper level subsidence acts to reduce upper layer water vapor, and enhanced OLR. 2. GCM MODELING PROBLEMS V 916 March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Draft TSD Is Seriously Dated and Updates Made Are Inadequate Skillful initial-value numerical GCM climate prediction will likely never be _ possible. This is due to the overly complex nature of the global atmosphere/ocean/land system and the inability of numerical models to realistically represent and forecast the full range of this physical complexity. Small-Scale Problems. In order to integrate over the entire globe and many years into the future it is necessary that the GCMs have rather large grid spacing. This requires that the GCMs employ sub—grid scale cumulus I parameterization schemes which can often be poor approximations of the complex real—world, non—linear, smaII—scaIe cumulus convective processes. ’ An important deficiency in the global models is the large amount of · compensating up—and-down motion occurring between grid spaces that . cannot be explicitly resolved by the models (Figure 3). These poorly—resolved ~ approximations of sub—grid scale processes are integrated by the models for hundreds of thousands of time steps into the future. This guarantees large errors. Realistic sub—grid scale parameterization schemes have yet to be -deveIoped. Most GCM modelers are unfamiliar with the detailed functioning of the hydrologic cycle. Their models assume that changes in lower and upper tropospheric water vapor occur simultaneously whichthe observations do not verify (Figure 4). Observations show, in fact, that as global warming has occurred since the mid—1970s that lower tropospheric water vapor has increased while upper tropospheric water vapor has decreased. This appears to be a result of there being somewhat more deep Cb convection and a higher rainfall efficiency when the globe is warmer than when it is colder. There are slightly more deep convective updrafts and compensating mass . subsidence drying at upper levels during times when the globe is warmer. Much research on the small scale parameterization of cumulus convection in terms of the large scale circulation patterns was done in the 1970s and 1980s without satisfactory resolution. The topic was too complex to be - resolved during this period. To move forward the GCMs primarily ignored this ` difficult task. They chose not to get ‘down—in—the—trenches’ on such a complex topic. They accepted a few simple compromised schemes (with known problems) and went forward with their broader-scale modeling integrations assuming that their sub-grid schemes were ‘good enough’ or · that the errors would average out in the end. This assumption is not valid. There are many large and complicated variations as to how sub—grid scale cumulus parameterization should be accomplished with respect to differences in latitude, surface characteristics, season, and other conditions. There are no general sub-grid parameterization schemes that can perform this function within various regions and on long climate time—scales. The net effect of the GCM’s sub-grid scale parameterization schemes is to ~ underestimate sub—grid subsidence drying, and to unrealistically suppress " OLR to space. It is thus not surprising that the GCMs produce so much global ’ . warming (~2 to 5oC) for only a relatively small increase (3.7 W/m2) of suppressed radiation to space for a doubling of CO2. It is expected that global rainfall will increase somewhat as human- induced greenhouse gases increase. This increased rainfall is expected to primarily manifest itself in increased and concentrated deep cumulus convection and increased rainfall efficiency in the normal areas where deep 2009 DRAFT 17 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Q NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA · convection and rainfall are already occurring. This somewhat greater and more concentrated rainfall will not bring about global upper—IeveI water vapor and cloud increase anywhere near as much as the GCM modelers have A . assumed. The diagram of Figure 5 gives the author’s concept of how the i globe will handle a doubling of CO2 by the end of the 21st century. We will not see a global warming of 2-5oC as the GCM models indicate but rather a much more modest warming of about 0.3-0.5oC. i J . T . emo l _ I I Wd w l `°"’ l Eiiz icma 1 l i l l l g I U I J 1 I Vertical Motion {ua) |'*"‘*GRm’ ’SPACE"""‘*"’I _,l “é5i`i€`é“`3§“ 3 ___. I .. ____ _ _A__ 7 lo .... y... . .. . .1 J: l—— -.2 i 1 R’~ F r l . ‘ Reel “’“i Vw _°J“»*; 1 1 I ri 1 A &ib-grid E . · r . R’H=8l3% _ 2 { _.. immense up&cl:::+wn y 1 1 A . I 1 1 iTiCl‘llCll1 =z_ I _.·‘°` f”__,_._ d__,,,_.,, ' . ` _,_.,.\ F_,,_,,._ concentralionk} vakssqiséa ..,. .>’ _;}M_; T ...Ll..;l_.,*-._t,;>i Figure 3. Idealized portrayal of how the grid size of the GCMs is too large to accommodate real sub-grid scale vertical motion. GCMs cannot resolve (top) the concentrated rain or the surrounding cloud downdrafts and subsidence within the scale of its grid space (bottom). The top and bottom diagrams contrast the mean vertical motion of the GCM (top) and the real up—and—down vertical motion of nature if deep convection is occurring within a grid space. Note that the unresolved vertical motion of the top diagram allows less OLR to escape to space. 18 ' March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Draft TSD Is Seriously Dated and Updates Made Are Inadequate i N. 100 200 ` "" GCM 300 ; JIOOD g W E M X 2 ~··—·· SCH “ (D ‘\ .. 5 000 M 1 0 § ~ K sc "°° ‘· soo ‘\ 3 sm " 3;..... ..... ousesvmsosix · ` LZ 1000 g I g it 0 .2 .4 is .8 sfu 1.:1 1.4 Correlation Coefficient C V Figure 4. Comparison of correlation coefficient between upper and lower level tropospheric water vapor of the typical GCMs output (red) and that of the Rawinsonde—reanaIysis observations (blue line). The GCM outputs are programmed to have a simultaneous moistening of the lower and upper tropospheric levels, but the observations of upper vs. lower troposphere · moisture shows little correlation. This high correlation of the models causes them to artificially moisten the upper troposphere and block too much OLR to _ space. Adapted from Sun and Held 1996. lncmasnf - · "§£?s2?Li“ sségtlmgts S%l2,'£?i"‘ &“Z"’%i“§s?'? V°”'” ( Wsamisg GCMS F 1 Bn ‘ E` V ..,,· 11 Rasnsass %$;_§§§ . BC _ Space . ms; 1 increase f essessssgs / REAL'"' · aesnsass ¤f`”&`:`»s.*""s=`E`"§"s1ss `°‘3'wC » Albedoto Space l Figure 5. A view of the physical process differences between the global warming for a doubling of CO2 from the GCMs (top) and hypothesized reality (bottom). 2009 DRAFT V 19 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA ° Positive or Negative Water Vapor Feedback? Most geophysical systems react to forced imbalances by developing responses which oppose and weaken the initial forced imbalance; hence, a negative feedback response. Recent GCM global warming scenarios go counter to the foregoing in hypothesizing a positive feedback response. Observations indicate that the specific humidity and relative humidity of the middleand upper troposphere have been going down over the last 4-5 decades (Figure 6). The assumed . . positive water vapor increase with temperature as programmed into the GCMs does occur however at the surface and the lower troposphere. But this simultaneous increase of temperature and water vapor is not found in the upper troposphere near the radiation emission level. It is not the total precipitable water which is most important (measurements show this goes up with temperature) but rather the amount of water vapor near the upper tropospheric emission level which is important. This more closely specifies the amount of OLR. ( l Ynarly évsmga Annrnalluia mr ¤fl"N»9l1'*S; n·3HD ("W50-20DBl ..,.....c.......,...,......... ...... z.....N,., .... 1,-..... .... . ..,. .2........ ................,.,.,.....N.-.. ..., e., ..~...,,.,.,.21.- ....e. ... ..... ,5 _ Fil-“$E3“lQL“é§`éé'él"é`ilL§»l{lK»i§] W. if · °i!1?&E_,_1__-_ _s_i__ _ s____,.___._.___ _ l.‘J . na A rf _ " . ·l¤ ` -l$ » .2 A A Obs. - EA . AT F Figure 8. Clausius-Clapeyron (CC) relationship showing the required ‘ increase of water vapor as temperature increases at constant RH — red line. The observations of upper tropospheric water vapor — green dashed line — do not follow this theoretical relationship. This is likely a result of a warmer climate causing more deep convection and more return flow subsidence (as shown in Figure 2). A changes ima clcuumgoricoz » wl tbl · U V · iN` C 7 . 200 hugh +6% Li W ES`? M 5, -2, . . $2 E fi nw » Q uw 3 Ii IBDD 1 D 1·¤· PG N dll SU GD N Gl} W!-E ¢ 2 4 G Gnmgem spemacmnmvy {Y6} Change in refavve rwn1I¢Ryi‘P6,l Figure 9. James Hansen’s early GISS model showing his assumed increases in specific humidity (q) and RH for a doubling of CO2. Such water A vapor assumptions are completely unrealistic, especially for conditions in the upper troposphere where water vapor typically increases less. 22 March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! l Draft TSD Is Seriously Dated and Updates Made Are Inadequate GMES, 2:zC02~ax.CO2 . ...........\.. _ -.l.“... ...A.. - ` ` 5G 1.2 25 1»·1= "<é "~=%.¤€¤, -2 »H¤·‘.~t-si , 2wz¤1:»;- 5 E al) ‘5` T ¤¤ jg 5 ,/" d`e‘ `T; A {5 lil I ¤¤ -·~’”‘ ;. ji `. 2 if ’ - w’2"’ gl . C . S s QZ ( 2- ' ea ·‘. M ‘ ‘ e __ to new sail mu san sou mu ms sos me ms sm. . Figure 10. North-South verticaI—cross section showing Hansen's early GCM’s model change in temperature (oC) that would accompany a doubling - _ of atmospheric CO2. There is no way a doubling of CO2 and an extra 3.7 W/m2 blockage of OLR to space could lead to such extreme upper tropospheric temperature rises. These large temperature increases occurred because of Hansen's unrealistic upper level water vapor assumptions. In order to obtain the global balance of incoming and outgoing radiation for his assumed high values of upper tropospheric water vapor it was necessary for Hansen to unrealistically raise his modeI’s upper tropospheric temperatures to obtain the amounts of OLR (or oT4) to space that would accomplish net radiation balance. It is amazing that Hansen's high water . vapor increase and massively high upper tropospheric temperature rise assumptions for a doubling of CO2 were not immediately challenged. — Itwas these large amounts of warming resulting from his modeI's gross V over-estimate of water vapor which Hansen presented to a US Senate Committee hearing at the request of then Senator AI Gore during the hot summer of 1988. The media and much of the general public accepted it all. . ` The environmentalists salivated. Hansen had secured his place in the sun. History will reverse such adulation when his warming predictions are inevitable proven to be wrong. · Not only have Hansen's extreme and unrealistically high values of upper tropospheric moisture and temperature changes (for a doubling of CO2) not been challenged, they were instead closely emulated by most of the other . prominent early GCM groups of NOAA—GFDL (Figure 11), NCAR (Figure 12) and the British Met Service (Figure 13). They all followed suit and incorporated unrealistically high amounts of upper tropospheric water vapor and, as a result, obtained unrealistically high values of global upper and _ surface temperature just as Hansen had. The fact that most of the (assumed independent) GCMs produced similar warming results were used as verification of each modeI’s results. But this was untrue. All the modelers were wrong in the same direction and in the same way. 2009 DRAFT V 23 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA Although the more recent GCM runs of Hansen’s GISS model and the Z more recent, GFDL, NCAR and UKMET models have been improved, they are T still fundamentally flawed. I expect the current set of GCM modelers will say I am referring to older model runs that are now obsolete. This argument does not hold however. If the more recent year models are superior to the older ones, then we would be seeing a revision downward of their warming estimates. But their newer models giveimuch the same magnitude of warming as their older ones. · _r as __. . ._ V - All A _ ; ‘_ ;,é;· J .~;‘v _. . .. . V , _ _ .... _ _4;;....,., ....... ........ ‘'‘' i l. .i._._ , ;...,_..,.. ..., y.,.. . ... 1::2§2 ‘'‘‘’ :2:28 ‘ .`V`¤» V _·"H;Y •`u •» ••>¤•» ••>q¤ 1 ¤_n•¤• ¤ H ¤j6`aj•i •· ni¤\•••• n¤ i u·n:i: N ·g H m :‘:£ :::::;;;;· M ~ 1— a · 1 ... .. ,· .... §Z I Z‘ t! :::; . A sv rI|IQ_i*(_ ¢ _ > . V V E Z V _- A . . ‘ _` ‘ · ,1,.. .. .`·. g. _ H 6% . ' _ ` V ```VVV V V , V,·12...-l-;;¤;··x-.·;.·.;r.~;.·..VV . · ·_€i‘. VVV· I V Y V V i q - E NU ;Q;€,2,;;,·_;.};;,;;,2,,.;,_;;Q·,;,.,,;,: .-.i i V “Vvii?$%@E$?§E?£???E??i?5?E?3??§¢fE§·»i;;;;*;i;€;$¤:@§§f‘.»}E‘}€€i;§¢§“Ei?»j%—2; .{Y;¤.} ; . F *5 " M ;§i§IEii$i?§?i?2¥¥i§ I sril 2* , ’ I y 4 I ‘§3 ’i‘· *"sV¥iV?¥£§.‘i*.§¥Y*·.£2;eQ;~i. ·...l ’ i l·.V . l.... 1 ¤· A i gw i;»€E`·*·=iZlZ‘T` *¤`·r‘ »>Z£?‘€i==¤>.`??l?;‘=*i¥¥~ i ._ _ __ i°°”"jEEYEEEXL?$3;*}E??;‘Y.Zé$’*f=5*??*V W won mel mg 0, 30, i 60* mis . Figure 11. Sameas Figure 10 but for the NOAA—GFDL GCM. ‘*;___'_, ""\, R *1f ___ _ =5 . o1_ _ _· __ _ 2. was A . % V V V s, —_~_V__FH'a- f§,€{:. ·. @ i``‘ ° 0 . wm 2·¤*s·l $0zN* acm; 2o*u WS airs $0*5 70*5 $0*5 l-¤¤l¤¤¤• Jun-Jul-Aug YE VV " — 1--V ` __ VV V *9 V - *"`—~.......;i`°w · V *2* AE ~.."‘.` " I; 1¤ A . ___z _,. B "“ ·-·“ii·*·~... 265 E ·— . ........ _ . V ,..... _ .·.~i., '·‘ · SE ;·l E 5 ``i"l “’“' ` `F`` ""° wu ww scm sow www ws ws ws ws ws Akfiil? n.¤1im¤i¤ Dau-Jun-Feb Figure 12. Same as Figure 10 but for the NCAR’s GCM. 24 March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Draft TSD Is Seriously Dated and Updates Made Are Inadequate Jun-Jul-Aug - * ` . ,,_, ~ § mo —···’·a· Mm ;; A EGG A 'IF 3. JG 3, ·§I V S 1 hn l — e,.,” . ...,._ etue _4t._ ...e. .,,.t. -..L.Tl 1.-1- WN all b' u' J) LY NS Dec-Jan-Feb uua E mu _ Elm . _ all `E ri I ’·* H 1};;*; `mll- .r..-;.;wo-.-..’L. ..,,,». :0,-...M .... - ...... 23,...... `_...t.. . ,3. . . __.. Kyi £»'}\*“.·l·2£·¢¢ ,$·.rr»vbr Figure 13. Same as Figure 10 but for the UKMET GCM. 3. IMPOSSIBILITY OF SKILLFUL GCM CLIMATE PREDICTION Skillful initial-value numerical weather forecasts currently cannot be made for more than about two weeks into the future. This is because any imperfect representations of the highly non-linear parameters of the atmosphere—ocean, · system tend to quickly degrade (the so-called butterfly effect) into unrealistic flow states upon integration of longer than a week or two. Skillful short-range prediction is possible because there tends to be conservation in the initial value momentum-pressure fields which can be skillfully extrapolated or_advected for a week or two into the future. But after 1-2 weeks, one must deal with the far more complex variation of the moisture and energy fields. Model results soon decay into chaos. I If skillful GCM forecasts were possible for a longer period of a season to a few years, we would be eager to track their skill. Currently, GCMs do not make official seasonalor annual forecasts. They dare not issue these forecasts because they know they are not skillful and would quickly lose their credibility if they gave real time forecasts that could actually be verified. How can we trust _ GCM climate forecasts 50 and 100 years into the future (that cannot be verified V in our lifetime) when these same models are not able to demonstrate shorter range forecast skill? [End of quotation from Gray paper] . What all of this argues is that there is considerable doubt as to the validity of the IPCC GCM models because they do not correspond with observational data in a very important aspect. Since these models are the principal underpinning for the IPCC conclusions and therefore the Draft TSD it is vital that these doubts and 2009 DRAFT 25 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA uncertainties be carefully explained in the TSD so that readers understand these issues which directly effect the proposed finding of endangerment. 1.8 Scafetta and West: GHG Contribution to Global Warming May Be Much ` Smaller than Alleged by IPCC As noted below in Section 2.4, solar variability (including sunspots) has attracted the ` attention of scientists for many centuries. Until the last couple decades, many scientists appear to have recognized the importance of the changes in the sun as a substantial contributor to changes in the climate. ("Changing Sun, Changing Climate," API. http://www.aip.org/history/climate/solar.htm) With the advent of satellite-based instrumentation beginning in the late 1970s which measured on the sun’s energy output (Total Solar Irradiance, or TSI in watts/square-meter), researchers were now able tract with substantial accuracy and precision the energy reaching the top of the earth’s atmosphere. V The IPCC (2007) report examined all of the satellite data and found that the amplitude of the sun’s TSI varied by only about 0.1% based with no apparent secular trend using an analysis that combined the data from several satellites. The analysis was complicated by a critical gap in the high-quality data that occurred from mid—1989 to 1991.75. The IPCC report based its conclusion of no secular trend in the data by adjusting the data based on a particular TSI proxy model that was believed to provide the best overall fit while bridging the so-called ACRIM—gap by using ‘ lower—quality data from other satellites. This way of constructing the TSI data has been challenged. If the alternative TSI reconstruction is used, it is suggested that the Sun could account for as much as 69 % of the increase in the Earths average temperature (Scafetta & West (2008). A As recently as March 2009, a new paper published in the peer-reviewed journal Geophysical Research Letters concluded that the analysis that the IPCC (2007) based its conclusions on is flawed (Scafetta & Wilson, GRL, 3 March 2009). This suggests that a secular increase in the sun’s TSI may actually be responsible for a substantial part of the global temperature increase V _ attributed to GHGs. This matter deserves additional review by other researchers and solar specialists.6 6 A detailed slide set pdf with extensive references and the 2/26/2009 climate science seminar video by Dr. Nicola Scafetta is available at: http://www.ega.gov/economics/ A 26 March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Draft TSD Is Seriously Dated and Updates Made Are Inadequate The possibility that IPCC (2007) has erred in its attribution of most of the relatively recent gobal warming to GHG increased with the publication of the Scafetta and Wilson (2009). This paper concludes that reconstruction of the solar TSI used by the IPCC appears to have been seriously flawed. If this peer-reviewed analysis is correct, then the sun "could account for as much as 69% percent of the increase in the Earth's average temperature, depending on the TSI reconstruction used." (see Scafetta & West, 2008) _ Until this new paper was published, one might have dismissed the above view by arguing it appears to be based on a erroneous reconstruction of the TSI. 1 However, now the burden of proof seems to have switched to those scientists that continue to support the IPCC (2007) . conclusions on solar variability. [These comments provide as balanced a presentation of these uncertainties as possible despite the extreme acrimony and conflicting views between both proponents of the GHG hypothesis and the skeptics of it. To the extent possible the highest quality scientific infomation will be used, although this has been difficult in the case of the skeptics. Because the views of the proponents have very recently been documented in the United Nations IPCC AR4 Report (2007) report, there will largely only be brief references to this material, which is readily available. This cannot be done for the skeptics’ case, however, because with one possible exception there is no one source of analysis that is generally accepted to fully represent the views of this very diverse group. As a result it will be necessary to spend much more space outlining the viewpoint of the skeptics; this is not because of a desire to emphasize their views over that of the IPCC, but rather to adequately represent their diversity of views. The closest thing to an overall summary is probably Singer (2008), but it is hard to accept this comparatively short report as the last word on the subject and it will not be extensively in this paper. On the other hand, an extensive review article on the topic of cosmic rays and climate can be found in Kirkby (2007), which appears to meet very high scientific standards, and will be particularly relied on for these topics. Given the nature of the subject and the disorganization of the literature on the skeptics’ side, however, it has been necessary to‘use some material available only on the internet and even written in a less than academic format. One of the most useful of these is Gregory (2008), who provides a very comprehensive overview of climate change science from at least this skeptic’s viewpoint. It does not, however, provide formal footnotes or references, although there is extensive URL references provided that allows the reader to locate the sources mentioned. To conserve space it 2009 DRAFT 27 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA appears better, however, to cite Gregory where the sources are evident rather than to repeat his analysis of particular topics. An effort has been made, however, to only reference material containing the real names of the authors found on Websites whose Webmasters are referenced or cited. This excludes, for example, allWebsites and material whose authors and Webmasters are . not clearly identified since the authors and the Webmasters of such Websites obviously have so little confidence in their views that they are not willing to clearly identify themselves. Obviously, some of the issues discussed are much more credible than others. In general, those referencing Kirkby appear to be highly credible. Issues raised by Websites may provide very interesting ideas but may also be less credible. 28 I March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! [ Some Major Inconsistencies in the Science of Global Warming that Need to Be Explained 2. Some Major inconsistencies in the Science of Global Warming thatiNeed to be Explained i In addition to the more recent inconsistencies discussed in Section l above, there are a number of others of somewhat longer standing that at least need to be discussed in the draft TSD in our view. They are so serious, however, that we believe that there is a need to change the conclusions of the draft TSD. For well-documented lists of these inconsistencies see Gregory, 2008 and Singer, 2008. Gregory’s list has approximately 30 items, few if any of which are addressed in the draft TSD. Although these lists themselves have not been peer-reviewed many of the references have been. All these inconsistencies are included in these comments by reference. This includes the important missing heating of the upper troposphere in the tropics. V These lists and the references they cite, unless carefully and successfully answered in the draft TSD, largely eliminate the GHG hypothesis as a serious contender for explaining a significant V part of the global warming that has occurred. This leaves the most fundamental issue as to what does cause global temperature fluctuations. It would be very convenient to simply offer a few minor corrections in the draft TSD; unfortunately, the problems are much more deeper since it does not seriously consider other possible causes of global temperature fluctuations besides GHG concentrations. Failure to consider these other makes the draft TSD one—sided and unscientific · in its discussion since it basically pre—supposes the answer and the answer does not explain the A observed fluctuations in global temperatures. Until the causes are clearly understood most any effort (except stratospheric geoengineering) is likely doomed to failure. It is only by taking a new and fundamental look at this question that a meaningful understanding of the endangerment can be reached. Although the hour may be late, it is only by doing so that an accurate endangerment TSD can be prepared. · 2.1 What ls Science? The first question is what science is. Science as used in these comments is the process of generating hypotheses and experimentally determining their validity by comparison with real world data—in other words, the application of the scientific method. We do not believe that science is writing a description of the world or the opinions of world authorities on a particular subject. Science, we believe, is not a statement of belief by scientific organizations. The . question in our view is not what someone believes but how what he or she believes corresponds 2009 DRAFT I 29 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA to real world data. It is important to note that science evolves over time as new discoveries are made and new hypotheses are formulated and discarded. There is no such thing as permanent or settled science. Only continuing research can insure that important relationships are taken into A account. Richard Feynman (1965) expressed this as follows: In general, we look for a new law by the following process. First, we guess it. Then we compute the consequences of the guess to see what would be implied if this law that we guessed is right. Then we compare the result of the computation to nature, with experiment or experience; compare it directly with observation to see if it works. lf it disagrees with experiment it is wrong. lt’s that simple statement that is the key to science. It does not make any difference how beautiful your guess is. It does not make any difference how smart you are, who made the guess, or what his name is-——if it disagrees with experiment (observation) it is wrong." Fundamental to the science of global warming and of climate change is what determines the evident changes in global temperatures over time. Until this is firmly understood any attempt to determine the effects of particular changes in the climate environment such as increases in ambient GHG levels on temperatures or human health and welfare is extremely risky since it runs the risk of being incorrect, with the result that any alleged endangerment may prove to be incorrect along with any actions that may be taken under the Clean Air Act as well. 2.2 What Determines Changes in Global Temperatures? Global temperatures have long fluctuated both in the short and long term. Until we clearly . understand these fluctuations it is not possible to make any meaningful as to the cause of either . global warming or other climate changes. Numerous hypotheses have been offered, but they all cannot be correct since they differ greatly. One clue may be that there appears to be considerable cyclicality in temperatures over time; here’s a brief synopsis of some of what is known in terms of the length of the cycles involved: I Over 150 million year periods: There appears to have been a distinct approximately 150 million year cycle in Earth’s temperatures. One explanation that has been offered is the change l in level of galactic cosmic rays resulting from the Solar System’s movementsrabove and below 30 · March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Some Major Inconsistencies in the Science of Global Warming that Need to Be Explained the galactic plain resulting in higher cosmic ray levels when it is not in the plain (see Figure 2- p 10). Over 100,000 year periods: For the last 3 million years or so the Earth has gone through a succession of ice ages interspersed with relatively brief interglacial periods such as the one we are now in (called the Holocene). In the early part of this period they averaged about 40,000 years each but more recently they have averaged about 100,000 years in length. Global temperatures are believed to have been 5 to 10°C less during ice ages than during interglacial I periods. Various hypotheses have been proposed to explain this but the predominant view appears to be that it is due to changes in the Ea1“th’s orbit which change the intensity of the sun’s I radiation reaching the Earth (the so-called Malenkovitch cycles). One problem with this explanation is that it does not explain the shift from 40,000 years to 100,000 year cycles. What appears evident, however, is that Earth’s climate is unstable on the downside during the interglacial periods and unstable on the upside during ice ages. There appears to be something which has prevented the Earth from getting even colder than it has during ice ages or warming more than it has during interglacial periods. It is far from clear what these somethings are, but this asymmetry appears to have existed for at least 3 million years. Over 1500 year (or so) periods: The Earth has had repeated cooler and warmer periods during the current interglacial (Holocene) period as shown One view of global temperatures during the U Holocene7 is shown in Figure 2-1. 7 David Archibald, "Solar Cycle 24: Implications for the United States," International Conference on Climate Change, New Yorlg, March, 2008, p. 6; available at ‘ http://ncwatch.typepad.com/daIton_minimum_returns/files/Solar_Arch__NY_lV|ar2_08.pdf A 2009 DRAFT 31 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! ( NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA . » - , * a y — I ;. { · i,—- Hotymcerwe 1 Q { A ‘n,’:» ‘.Ma¤_i¤va¤.r_ _’s. ! xg ni·asaV ‘‘‘.— M ; , aaa‘ " ·.‘. i ta’’ F3|iE¤$tB»_-£>]$ii.f¤..u`lT1;r t s.a. .-—sta‘ i . »t»‘‘*; CWD I r n - n- i · 2 » > , . vanas. ig ‘-ii ,’va ;.·H¤met1,j» laa_1.a‘ A gg. Cs_·’ A ‘nv, -i G1? VT, ;- `”a_ { _.si C“ts· `_ii’ I. T »·i • i,.a` ,—_ s~’iC ; _i_i 0 F1; V‘‘i jzf,-Qlplillalgi Pl.'Q[l}ii*.?T' s—_’ Ca i‘A; ‘»»V F as i` ntati it ania t s 1 Aa » ti tiit `C > §" 1YE a tia n A A a ns “ i·”aa ``.. 1 » . » Q L -. ~ ~ - ntas - V, ‘ e _ Vaasn 1 are- A.- n··. 1 sage . 1 . a._· A y ( pp {3 s aV__ . , M ». _ V·»· n,;G A pl- .» v.s·C·_ ;g;_4;_ _; ·,V C_; {I: .,r L; 4a_s _ _ 4. itfa;· t T? »»‘- i iasn ia·`·v- .·a` 2 ‘ ns»A» T 2 ‘2PT » ‘*:i 5 -9.ese¤.—:i?i9"·*?9l?li$f¥r‘?l.T .ec‘ ;# »4,a ’ l£§r**1?$i—? I Q V· a r j a ¥].jk?i »`·’¢ 6 »·»t X Y =i— r naaa A V.‘;a4‘a l F ;F .- ¤ - .-·v fx: _V.;,‘ ., t- in »»’‘ ·1 ‘·· 2 ,.3j 2 z I _-·4 ig? »it; *r< ; ?Z 9*.; 5 san;·, I vsiai t `“.v €?F$fP$.l??’iiéi-'QQP-?'€$*‘%”*ll’i€’2‘?iil@@0}*5 `‘·C ·s’a.a , :¢ a t» aaaa I s as ¥ A- a *nt s:`i s Iii ia—aa »; i as ui ¥¤i·?¥ i i » as 5=¥1 ;a?) ·x ? asta _,‘, »’I V—_ ‘= a 1 »\»sA <'4» »?lw¥.l.;@C?. , M5-*€»?F$»*(·§·?i‘F€i?r !?€f.f?$§$3fd.J¢?£_.,¤rl- ; 96% @¤T¤*.i$¢i*¥5¤:W!¥?5€ ‘,V e — ?#995JfT-[ I ij ’,·a Figure 2-1: One View 0f Temperature Variation during the Holocene Source: Gregory (2008) This graph comes from a skeptic (a more careful, more neutral, graph will be presented for a portion of this period later) and may or may not accurately represent temperatures during this approximately 10,000 year period. The important thing is not its accuracy but rather the many temperature variations of roughly one OC on either side of l5°C throughout this long period. ` The last previous very warm period is known as the Medieval Warm Period and extended from about 800 to 1200 AD. The last very cold period was known as the Little Ice Age and extended from roughly 1450 to the early 1800s. This was followed by the current warm period, particularly in the last Quarter of the 20th Century. The total variation appears to have been about I +/- 2°C. The cause for these variations may be variations in solar radiation but is not well established. It is clearly not related to levels of human-caused carbon dioxide since humans had little to do with such emissions during most of this period. It is known that sunspots were either , absent or very few during the depths of the Little Ice Age (the so-called Dalton and the more serious Maunder minimums), however, which suggests that the solar variations may be related. Over about 60 year periods: In the last 120 years or more there has been a clear variation in global temperatures with roughly alternating warming and cooling periods each lasting about 30 , years for a cycle length of about 60 years total. At least in the last 120 or so years, there is a l 32 March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Some Major Inconsistencies in the Science of Global Warming that Need to Be Explained fairly clear pattern of trends either up or down lasting about 30 years (see Figure 2-3). In a 30 { year time-frame the trends, once started, appear to be form remarkably uniform trends. The » reasons for this cycle are not widely agreed on, but any attempt to explain global temperatures needs to explain these observations if it is to be credible. One strong possibility is oscillations in sea surface temperatures since changes in the direction of global temperatures seem to have a _ remarkable coincidence with at least some of these oscillations. Perhaps the most important of l these cycles is the Pacific Decadal Oscillation (PDO), although others such as the Atlantic Multidecadal Oscillation (AMO) have been identified in other major oceanic areas. The PDO is a long-lived El Nino/La Nina-like pattern that is observed in the sea-surface temperatures (SST) of the Northern and Central Pacific Ocean. Positive (/negative) phases of the PDO are typified by ‘ warmer (/cooler) than normal temperatures in the North—eastern and a Tropical Pacific Ocean and cooler (/warmer) than normal temperatures in the region to the south-west of the Aleutian ' Islands (see Figure 2-2). It is important to note that while the El Nino/La Nina oscillation varies on a time scale of 4 — 5 years, the PDO variations are governed by a time scale that is much longer. The immediate point here is that both the PDO and global temperatures have recently l turned negative in recent years. Similarly, both turned positive in the 1970s. The reasons for - this are speculative at best, but the correlation appears to be overwhelming for the —period for which we have much data. One possibility is variations in solar output, but much more I complicated hypotheses havebeen proposed (Wilson, 2008 in a peer-reviewed journal). It is worth noting, however, that human concerns about climate change appear to have followed these PDO variations quite closely with concerns about global cooling and a possible new ice age near the end of the last PDO cooling period in the 1970s and concern about global warming in the 1990s and 2000s. _ 2009 DRAFT 33 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endan erment Anal sis for GHG Emissions under CAA g Y . s "is (G -. 0-8 » ,-¤ ·— #’‘· . , ·f·»» ` ‘·- . ’’i“ I f?$l€?i*.:`=- ` ..=‘ 1 1i‘i· ” ‘’‘‘ ’ vi,‘i =’i · si. "'·‘ ””·` 2 0.4 ‘‘E·· l .·$A. l r V a ¤ ]¤i-_ 1 - ; ...lQsi*'i£i`€£¤e» il rziigih U 2 °A—s- - ~»;_ . §‘.}+5;=:;;‘:q~igS;-.—·<¤is ,·;· ,.·.* éiam ‘ .§§2¤’1—.:-ka5.¥el$¤..‘g:»¢¢’:=.a!¤E·=.r¥§f`-z ..·» if r ·*-‘ i·—‘ » y~;:~=i¤ .—.r< =‘¢ . V·-A—. ‘ .» .0 0 “`‘‘ 1 ' 1 ·»i ;., .:i. * .`.‘ 1 ‘ ‘‘» . §Y `~ ``\‘'”’ 4 ..0 2 »»Q¢§1<.i°‘iI*‘E_ fi?-’; 4v_·r `§Q,'."_T$**?P ·‘ xfj -’*. ·· ‘:r._i¥’·e-`Z§:<·¥—Gigs;2h;§.;,.%¢,;;.;&r;y_;;Z*’ .—.i rr ·.i· R agri? · *‘>?··· ‘ ·-‘V U ‘ . :‘‘` -0 6 Figure 2-2: Pacific Ocean Water Temperatures during a positive and negative PDOs . Source: Wilson (2008), p. 23 0.8 2 ~—¤ 0.6 A . >` I ggg- / ·- poo posmvs "° 0 4 - 4 E s 1 O poo New-wave p l C 0 2 . 1 1 A poo use-Anve me posmvs A . A J l E- 0 . I ¤......t 4 l i P' ‘ 7*;: '· O 2 hu . Ax ‘ I A *5 ‘ · ’* "=· Jr .¤ 2 _ -0.6 p . 1880 1900 1920 1940 1960 1980 2000 Year Figure 2-3: Sixty-year Cycle in Global Temperatures Showing Clear Trends Over 3-5 year periods: There also appear to be a much shorter-term cycle and influences on global temperatures due to El Nino/LaNina oscillations and volcanic eruptions and perhaps other factors. These cycles are clearly evident in both the satellite (see Figure 2-7) and the ground 34 March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Some Major Inconsistencies in the Science of Global Warming that Need to Be Explained data. There may be some argument as to their cause, but the evident similarity to the ENSO cycle is hard to ignore (see again Figure 2-7). p The climate is believed to be chaotic in nature and substantial year-to—year variations can be l expected and have been observed. The surprising thing is actually how well ordered all these cycles actually seem to have been in terms of the available global temperature data. i Against this very complicated set of cycles and other factors that appear to characterize global temperatures, those concerned about global warming in the 1990s and 2000s have put _ forth the hypothesis that the global warming since the 1970s has been due to increases in the global levels of carbon dioxide and other GHGs, and that these levels are a result of human- _ caused emissions of this compound. There is considerable evidence that increased levels of carbon dioxide may lead to higher global temperatures all things being equal. But are these increases the predominant reason'? To explore this topic it is vital to see how well the increases ‘ in CO2 relate to increases in temperature. This is what we will do in the next subsection. 2.2 Evidence for a Predominant Influence of Carbon Dioxide A useful task is to explain these variations since that may provide clues as to what is influencing our current and future climate, and therefore what might be effective in reducing these fluctuations if that should be desired. Figure 2-4 shows global temperatures and CO2 levels T for the period 1880 to 2003. Hypotheses concerning the causation of temperature changes should be rejected if they do not explain at least recent satellite temperature history which undoubtedly represents the best available data, and should be replaced by alternative hypotheses that provide at least the possibility of offering such an explanation. 2009 DRAFT , 35 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA I`: V _ ,. _ . _ . 2 , . . . .. , R- ll ° —·-·*··-—··i»'4i,1·n¤·1¤u·•:1| Mann *m··“*·"*·“··‘*·"·*"*·*·····‘··*‘r*=·*·i*·;***····*·—· , _,_ _ gg: u V . . EQ 0-9 j--··- ·—···—··5-'1’·e•¤rM¤·¤m1i ·—· · _ V Ii, -36*0 as yi----- -- ··——-· Crm! L¤~.·¤-Ir —····-—·····—·~··~··· if agu- e ., . » ._.....-o....i..... ...............-...................-..... . » 3;; 5 D2 ____________ _____ ____ . " i _ ...1. ·_ . _ am _ i -· § mj ;_‘f'_f__';'f " A, · umn! illil .'|•i:.·i,¤l;'l‘ . gm Ei G 4 i I _. n. ` i · S I 2·B¤)¤ ` " T " T · “““ _: ‘ T 4 ““"“”`—"`“`”"`“““"`"""‘“* » arn- 5 _0,_46 . ___ V i 2.6% — I ‘ · ·2.5¤· -Q»_,Q I ’ »»........·........l..¤-............-_.......—............,.........¤o..._.....»..¤-.,.......¤,..o»...i....y ol . . . . r . . V . . _ _ , , 1 ggmi ‘$2%53'£".§'.“aT2”?i§¥¢`¥-?§"€&!".i`;';$E$»‘E Fig. 4. Gl¤:·haz11. tmmgpcrmiuc. {ilcft mule.,) hmm gmcumd mtxuimxs vx. (Till-_, mmc¤1mrim:inn in ppzm in wtrvrm- ' s]jx1v:m¤.{¤·ight si.c.s11c§) ‘l`:r·mu H?JB¤l'3—?2¤3G1.'l·. Aviixilsahluz amt: wm.·w.·C}ZES£·Ei.Ql‘·li¢*ré·?i.¤•.,_;;omu· Muuwnnx num irsnmmunrawnninziuaianneuein l‘J\’$vTlP.E¤'l\| €¤YN|¥\I4.-!*lY‘i¢¤lYiI)'___Ul'0¢,__¤¢·'\¤liT5i_q|'HD\'\`lhlY_l'1|4•.l___§|¥‘vE?i1_,__4}!‘l|||‘1[i¤l__lIL__•'I»f\¤·l\'i¤|I&§__l¤H!I_¤|7d_0¢¤·§N_,\'U3_J.D¢I » TF = ·7 · as‘n ee_» r¤`is ; { * * `»i,, ij ci·,. _; n‘e;Vi· V 'stii 7 ·•s { }> ,, 7V _7 · V 7 r 1 t V ‘ F ¤ . ha 7V LVV-1 VV eaia V i T 1. 1 V . = 1 L -V »V T »‘nn A J · y V. V —iri‘r.‘‘ :i— .L‘i ar T »··, .1; ,ia‘‘,» . ; 1 7 · 7 is: iiiil T nn_ia 77 ~ 7 .7 7T 77 T r r *i-t = . 7 4 ar i 7 . T 1 V‘ { i T ``at “‘»‘ ` ·:»—i' — e‘·‘ T te‘r T T M fa . · I " ' r -T Vi : 211 i T1 · 5 T Wie .- · ·V 4-s b ? J; `¤2’.r· " ea·»li V1 fi r /—e`l’ reii —»e‘ ls ·»·ei—e· f `V·i »..i ,e`e i`\; ii ia_,, `tal-V -V:~e < '_l‘ = l 7 I? ¤: ii T iii? T ` Eiiii éi ` I .iE ‘Tl ` T T T i ` V fi .3* . ‘.· ~ ·i isi; .:¤· L c‘‘‘e ’ , V» in V7 Vw Z 1 ##5.7rri .7 e—p.-e V 77 i . V r ~ 7 7 »s.t .7 4 = 7 ,·V’ V ` i J V rj »*»i ai 7 [ V·»t TV s‘·V· = T: Q *’w ri i’s» V i ¥ T TTVTT 17 TZ E T . » = i ` “?"‘“?"**"°°"°"°°°l°‘°°"i°*"°‘°‘? l T 1 .. i: .7 7. ,rs. 7. 7 . .7 ai s 77 Q ·. Ts 7 7 l . V . A 77 -T . 7.7 ,77 T Figure 2-8: MSU Data with Addition of Center Lines Source: Arrat (2008). Drawing a straight trend line in many ways limits the options examined. Much better is to utilize more of the data by trying to tit a more robust pattern to it. Ambient CO2 levels were increasing throughout this 1978-97 period yet global temperatures remained in a narrow band with little apparent increase. Further, the sharp spike in temperatures in 1998 appears highly unlikely to have been caused by changes in GHG levels since they vary only very slowly rather than exhibiting the sharp spike seen here. The reason for the 1998 spike and its possible after effects in the 1999-2006 period are unknown but would seem very important to learn about before T T assuming that it is related to changes in GHGs.l0 Similarly, the period 1999 to 2006 shows another narrow but higher band of temperatures with no increase during the period. One 10 Amo Arrak has suggested the possibility that the 1998 spike was due to gamma ray burst 971214, but he emphasizes that this is only a possibility. ° 2009 DRAFT G 43 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA possibility is that the elevated temperatures during this period were an after—effect of the sudden surge in 1998. Finally, the period 2007-9 shows a strong downward trend in temperatures which - is surely not relatedto steadily increasing GHG emissions and atmospheric levels. Thus it is very hard to see any effect during the period 1978 to 2009 that can reasonably ascribed to changing CO2 or GHG levels. This is in marked contrast with ground level measurements such ` as the HADCRUT series which shows a marked increase in temperatures through 1998 (but not thereafter). One possible explanation for this apparent inconsistency between the HADCRUT and MSU data is that ground level measurements may inevitably be compromised by the urban . heat island effects which presumably increased rapidly during the period due to rapid urbanization in many parts of the world. 2.4 Solar Variability Prior to the advent of the IPCC and interest in the effects of increasing CO2, the predominant view appears to have been that variations in global temperatures over periods less than 100,000 years were primarily due to solar variability since the Sun is Earth’s major source of heat and I light. [reference] A number of researchers have studied this over the years, and they have found some apparent relationships between sunspot cycles and global temperatures. Some (prominently Svensmark) have even developed a hypothesis to explain this apparent relationship. This hypothesis is roughly as follows: ‘ Solar variability has been studied for at least 400 years. The general conclusion prior to 1990 was that the Sun is the major driver but there was little agreement as to the exact mechanism. But starting in 1990, the IPCC instead atttributed warming to GHGs/humans. In 1997, however, . Svensmark suggested a mechanism for indirect solar variability effects. Now many or even most GW skeptics cite solar variability as the major cause and basis for their skepticism. In recent years there has been a furious debate/war on this issue. There has been some new research in recent years, however, some of which will be summarized in the following sections. - - Predominant Views Prior to 1990 •¥• "Earth’s temperature often seems to correlate directly with solar activity: when this activity is high the Earth is warm" 44 I March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Some Major Inconsistencies in the Science of Global Warming that Need to Be Explained •I• "During the famous ‘Little Ice Age’ during the 17th Century, the climate was notably cooler .... This correlated with the Maunder Minimum on the sun, an interval of few sunspots and aurorae" I •$• "In the llth and 12th centuries, a "Medieval Maximum" in solar activity corresponded to the "Medieval Optimum" in climate" •Z• "The 20th century has been marked by generally increasing levels of solar activity"——-Hoyt and Schatten, 1997 Indirect Solar Variability May Be l\/Iajor/Better Explanation than GHGS Although Total Solar Irradiance (TSI) may not vary much, that does not rule out indirect effects of solar variability as the major cause of global climate changes. The impact of changes in solar eruptions, wind, and magnetic Held may explain some or all known global climate changes during the Holocene together with volcanic eruptions. TSI evem varies with sunspot cycles. Other researchers agree that solar variability may be related to temperature variations prior to mid-20th Century. Svensmark (1998) has hypothesized that Sun’s magnetic field varies with sunspots and determines the number of cosmic rays available to stimulate low level clouds on Earth. _ i ii i . ii r ii i``i .`»;° I I · ·`‘— ‘ ’ OI3j‘_Wind i , A/IOd.l·]. HI'ltj);] ' r . Appezrem Link _ , I C _._ ` C ..i.Ve r-Z r.‘.-.r ..-`. i ...t g » —° ‘ ~ 2 iii ll`' < -. i » ‘· - ?* . w e M ; » » c e W , ,__ , gg; _ Figure 2-8 : One Interpretation of Svensmark Hypothesisll ll http://wvvw.sciencebits.com/files/pictures/climate/crcFig2.jpg 2009 DRAFT _ 45 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA 2.4.1 CERN Study In 2007 Jasper Kirkby of the CERN published a review article which reached the following major conclusions: _ . •I• "Over the last few years... diverse reconstructions of past climate change have revealed clear associations with cosmic ray variations recorded in cosmogenic isotope archives, providing persuasive evidence for solar or cosmic ray forcing of the cIimate." •t• “The high correlation of the temperature variations in the A14C record suggests that solar/cosmic ray forcing was a major driver of climate" [over the last 2000 A years]. I , ‘ - •t• "Two different classes of microphysical mechanisms have been proposed to connect cosmic rays with clouds:" •t• Production of cloud condensation nuclei - •I• Global electrical circuit in the atmosphere and, in turn, on ice nucleation and other cloud microphysical processes? V •t• "ConsiderabIe progress on understanding ion—aerosol—cIoud processes has been made in recent years, and the results are suggestive of a physicaIIy—pIausibIe link between cosmic rays, clouds and climate." 46 March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! i Some Major Inconsistencies in the Science of Global Warming that Need to Be Explained . His conclusions were based on a broad review of the evidence for GCR impact on climate using a number of different time periods and lines of evidence. The important points would appear to be the following: •$• Galactic cosmic rays (GCRs) are strongly related to global temperatures V •2• Solar activity modulates GCRs reaching earth, with the modulation related to sunspot cycles 9 3.5 ·~-r-»~~··»—· --·»- ··r· r ~·-» ······ —·v— r——¢~·~r···»¤···¤r~·~ ~r -—~—~ ·——~—»r———»~·-~-—·~r·~··r--`~·~ —»———¤~··¤-—·-·~~»·~·-·—~r~~.~·-r—· —·-r»·+~—¤-·~-r~·——»—-···~—-»—~~r··—r—-···—·»r Ta) , Th r,_ Y ~l\»·l;rrr•»arnsk : ° I i ll`! G _j A `> if 340 F }' U } ·‘ " il _ ,_ V E? ¤\•1l·rny ·* Ré " Q _,"ty` ` ri" y;,.?Lg‘ { {L ` "’ . {Y { *4 ,—.v¤e"L»' "* .F°` Jr? . 1 . . E 2-5 ·- sf if ’°v-t . 5 "l ' hi , ,!' His, r' MOLOWTY A 2 \ V Ejgr I .· fl `” :1 * w ` , _ 8 2.0 i- F · nf _· ~ 1 ‘5 iw -3 . E .. 200 r- —- g . ali, g y W _ l _ , 100 — V g` ` cyqlg Cy'¤I»B V l Cy‘(;[B YKDIIB "’ 0 1. .... Zi",...r-1.-.....:·TY.... ..... -,o...E¥?l.-c. ......... 2. -....,l..r.?`i,- .... . -2....-.5i-.o-._.-2.. .. 2.,ti’?Ll 1 960 1 970 1 980 ’l 990 2000 `1’liI£:1l' Figure 2-9: Solar Modulation of Galactic Cosmic Rays, 1957-2001 . Source: Kirkby (20O8)12 12 Mirny is in Antarctica. (a) based on balloon measurements of the cosmic ray intensity at shower maximum (15-20 km altitude) measured by the Lebedev Physical Institute. Based on CERN 2001-007, 41-62 (2001) and Babarykin etal (1964). 2009 DRAFT 47 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA 1.5 _ aa.) GCJF4 flux Ai»C ` __ >‘°` " 2 .s ,-, 4i”.' ‘i‘:i.`— 2; =As 2 ( ;Ev·;r» i` 1.0 i¤.: .·i:—£**·i; ?TJ’ s·:» v`v»s— $$1 Cf —i`iii ‘-Vi .ss`. — 1.”- ,.s- (_) J = fw. V ; gf xs; - ‘·:4.. Y x·‘:— -~r= 1 . cv G-5 '‘ai‘ ·‘i° · 1; `·;· ‘:‘· 5 " i’*·s »>A [jni ` G gg, 2 I:1) Tamptarlatura ¢¤ _ W GCR (mv.), ,4 ,-"~.._ g .» s ·*·¤»¢’ x' x »’ at i O •.`\1I _. . . . lm , I , , Q" _ .¢ , . E X K `~ Y ` ’ `*~ ... .» ’ E3 { L`. JJ y_ cu -2 —~ I ·—· r · r Q. K J ___ ,u E X 2* V ·2 . , , li l 500 400 300 200 _ 1 O0 0 ° Age- =[l'*»·'1y BP) Figure 2-10: Galactic Cosmic Raysand Climate: Past 500 myr Source; Kirkby (2008) L 1 000 1 200 ’ 1 400 1 600 ·1 800 2DOO {T""""`F‘"""`¤"'“""'!"i'"""'"I""`"""`{"""‘“¥"“"`“"“"l”"""i'1""_"‘T""`—T`—"_`"`i"% '*· aj Northern hz-zuvunsphearc temperature __j A cgi OA ;-*_ 5$W~;gL3'g§_;€g?_ MM-J:..E5;!!.‘§L:.!sEE.P,..4·?.t$»:£»&».~»·~» ( `9_`7 Zé" énStru:"nc=nia| was fz: L —··· ee S Q G ,,» ..`. , ,.:1 .: . l<,·. ., :9 "T § ‘: 4l`i` ’T ., ·»e~ ~·:~··¥iJT;LI.L1..;j_ ’t’T — ( l ( 2 § % E § vO'd ffff "%2%A' >`·:i%}‘·3’4,%¤ * ~·%`iiir_f? we Q" $5 1: '¤l 3 in _ ~. . ‘2!i & ‘ ( @(,4;:* `. `· ` _ _,.r’" ` k '· V F __? " ` , E ;.l2?;l;.: ;’i*§.J§?a§l;S. my : i»l- ‘ "P 8 E _0_B i 7. €Z;§r@¢;~r1§&11"aG t.;·<:>mz.Mc¢m¢e; {Miss} ' Q v.··;:·rld·.·»:lc!¤ b¤rmh·§:s!¤wé "’%;w,;))¤»*$` ‘¤—£;¤*"J ( @5 A R1) Galacllrz cosnnic rayls 1{BBG {G rmamamdu § -1D i···— +'>T__"llN_j·*#ij {;·!·sv e_;·;§;3.ia;;-p igrme xjafiggz) \` W `QO tg` V l-c ’ ei 'imj . Wn ` yr;-, g O ·<___·_-;__,$~· _q&_ ___7__: ____ ___ ______‘__ _____ _ .._ if is 1 M 3*5.. s o ( f 2 S ¤' ,, g HE _; . l .-.: lg .20 3; iw —, _ ` ' E , + g g ·M , · `lr ‘ . 0 _ _. _ ‘ ‘‘‘`‘ . 5 3Q ifiliwe {S<>uu·x F¤‘c>~r:;»} J"/sv é g ‘§ (5 E, {H1 s¤::z1.ha·§ .5) ·-— W 20 3 40 ; * : Figure 2-11: Galactic Cosmic Rays & Temperatures: Last 1100 yrs Source: Kirkby (2008) . 48 March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Some Major Inconsistencies in the Science 0f Global Warming that Need to Be Explained "““1"“_r“"f“*1““‘]“*F"_T*’1“““l "l`4`1“”l"l"“T` ‘° ] “V"_1_‘1““ ‘ 320 - , . -. CO2 we ln` ,' ""-`X X,-"._/‘_ ·*"·. f 290 (ppm) a- I ` I; \‘I ‘l!\‘Il = : -10 "' ‘·“" lm-..,· -8.0 ‘ s . G9 1 *· 0 1 _|('¤ i ` ~ 5180 GCR! ’ » · (%¤) I I I l _ _' J p I 'Y.5 (%¤) ” V 1¤ 1 M 1 `°°’ · -7.0 p 2O . ~ : 500 1000 1 500 1 2000 Year (AD) Figure 2-12: Temperature Reconstruction for the Central Alps over Last Two Millennia, Obtained from 0-18 Composition of Speleothem from Spannagel ‘ Cave, Austria Source: Kirkby (2008) based on I\/Iangini et al. (2005). 2.5 Urban Heat Island Effects and Other Problems of Surface Temperature Measurements 4 There appears that there is another major influence on global temperatures——but significantly only for surface temperature measurements. This is the effect of rapidly expanding urbanization worldwide and a number of other factors that appear to be corrupting surface measurements. Because most surface measurements are made in urban areas there is a high risk that the urban heat island effect will influence the measurements made. This UHI effect is well known and well documented. Strong support for this effect can be found in the extreme divergence between surface and satellite temperature measurements. This is shown in Figure 2-13 below: _ 2009 DRAFT 49 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA - ’’‘’ *n‘·‘‘·’ ‘=‘i’’·e‘ t ‘ ‘·‘‘‘ ‘‘‘‘ ‘ `’‘’·n `’·’‘`*‘’ ·L“' Data sources: http://vortex.nsst<>.uah.adu/dala/msuIl2lUuahncd<:.ll httpdlhadobamet0lHce.c0nvh¤dcmt3ldIagnosllcs/glohallnh+shlmonlt1Iy »V,,L,E ».,,>;r a `—.; . .... a .>,‘ » sj vt-. ,:.;. _.:i; t»,»·; » . 1 ’ g ‘a=—Cn 2 . . . Q 1 ’ i 1 4 ; i ‘ 2 ——r»wc¤¤r¤m·¤¤¤¤s - 1 r - ’ ‘ ; - ·j . T E 2 » ; . a ``t ‘ - 9, i» i_ _ j a—,ni -s—A · V -4 €i “_*as ‘ [ ef T ` ’*a» ” ‘iC " , #.9 ·? ‘eai V · V . . . . ‘ V , xw ‘* . r ¥z?<££19r2a . — » : V ._ #s · · · H . +;=.· ~ * s<.·_aa@ ,.· r gz} .V`ii Jajtm _ C‘.= r j _ ,_it,l;§“tjjvii§_ gjgiiig ij. _Y · gi ‘¤=A [4~. ; ,; 4 ,~A u _e·- jr; a·_·_ js-—¤ ri§§*§ _ !»l»i. ,li°¢‘·iii ,,_. ii i ,. ., , , , . * 1 · *` it 2 E `*·· Q` " ‘ i‘‘ · * ai1"’ t“ i¤" rf . >t xi v " t i`· 2 V L Q ’ * 2 .- · ‘ #*5*4* f 1 l ‘i j in . t . l tit ‘ i 2 i » & i 2 it — ‘ r a A ·.a s a 3 · I r = 1 ; 2 . r <€*;&·§§=¢r»£ <`» . · it t { $$9- j <· t - .=.E “ - ` ‘ i · * 5 2 ¥ . , M gift? " 5 .**» ’·fi~$¢· »: ~. r »’ I ‘`=’* ‘.»· ew ~;°i · ~ ` ‘ —·nC r E ‘‘·“i ; ave. i.;~ 5:: ,r.· ‘ . - V .2**9 g . ig .‘»» , •-;·— t; 4‘.* ’ita 1. `.i» - * »Ciee,· w T. a’s. . i,,,‘ JI: ·D·~ Y . y, 1 .- Gsae 2 _ , | . I : - `‘°, i " _ ,_.. , 1 ,a’’' ,,4· I — ‘ . j ; 1 — . ‘ 3 3 3 , E ; i . . ; . . _ , J . » ¤° é Figure 2-13: Satellite (UAH MSU LT) and land-based (HADCRUT3) · Temperature Anomolies Compared · _ Note that the difference between the satellite and the ground data steadily increased during the 1978-97 period, at the same time that worldwide urbanization also increased. It is possible, of course, that the two approaches are measuring different things, so the comparison may be suspect for this reason, but the draft TSD needs to explain why there was no increase in lower troposphere temperatures during this long period. Without any, the case for GHG-caused temperature increases during this critical period is greatly _ weakened. ln addition to the problems of urbanization and the UHI, surface measurements also suffer from a number of other problems including major station dropout, missing data, bad siting, instruments with known warm biases being introduced without adjustment, difnculties in obtaining data from oceans and other areas with ·few monitors, and sometimes even black—box and man-made adjustments designed to maximize [reported] warming." Given these many problems it would appear to be much better to trust the satellite rather than the surface measurements even when carried out by neutral groups 50 March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Some Major Inconsistencies in the Science of Global Warming that Need to Be Explained with the best ot` intentions. There are two satellite databases which appear to be in close agreement, unlike the surface measurement databases. 2009 DRAFT V 51 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! 1 NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA One of the most obvious places to look to try to understand these variations during ` the Holocene including the two recent periods is to look at variations in the Sun, the source of Earth’s heat and light. There are two possible types of solar variation. The first and most visible is direct variation, usually measured by Total Solar Irradiance (TS1). . This is the variation of the sun’s total radiation output. The second type of solar variance is often referred to as indirect since it involves the impact of solar variation on other aspects of Earth’s climate system, which in turn affect global temperatures, among other things. The discussion here will start with direct effects and then proceed to indirect. Direct Solar Variability Most measurements show only small variations, usually about 0.1 percent, but it is not known how it may have varied before accurate measurements have become available. One important aspect of these variations is that they vary with the sunspot cycle, with the highest TSI roughly coinciding with the maximum number of sunspots. V Perhaps the best known aspect of solar variations and the place to start is sunspot cycles, shown in Fig. 2-13 over the last 400 years. The first thing to note is the amazing correspondence between the average number of sunspots and the global temperatures depicted in Fig. 2-?. 4001 Years of Sun1sp ot Observations . M, ximum img h EE · it . . 1 ‘ E 1 ¢ . * * . 3 » 1 i tl F5 · 1 r 50502 if ’ , I ; E A I = y id s. . Maunder y i . » . 1 · 1 9 1% .; ··_. 1 · z' ii ‘l_ 1- `#§ _; i t .1 , » ·p- · -e *1 ` ll ·. + _ " Ei] 3 V U A g _ 1 J, . _ _ . ·s.;r » - r l ` i 1 lll! 1 1 m __,. Q », , ,,, _,; , ,.. .... 1 _ _ .... .. .... .,1-. .... .... ; .... 1600 1650 1700 1750 1300 1850 1900 1950 2000 52 . A March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Some Major Inconsistencies in the Science of Global Warming that Need to Be Explained Figure 2-14: Relation of Sunspots (or Lack Thereof) to Little Ice-Age Periods i Phil Chapman has made the following observation concerning the new sunspot cycle 24:13 The new cycle, No.24, was supposed to start soon after that, with a gradual build-up in sunspot numbers. It didn't happen. The first sunspot appeared in January this year and lasted only two days. A tiny spot appeared last Monday but vanished within 24 hours. Another little spot appeared this Monday. Pray that there will be many more, and soon. The reason this matters is that there is a close correlation between variations in the sunspot cycle and Earth's climate. The previous time a cycle was delayed like this was in the Dalton Minimum, an especially cold period that lasted several decades from 1790. Northern winters became ferocious: in particular, the rout of Napoleon's Grand Army during the retreat from Moscow in 1812 was at least partly due to the lack of sunspots. That the rapid temperature decline in 2007 coincided with the failure of cycle No.24 to begin on schedule is not proof of a causal connection but it is cause for concem. 13 Phil Chapman, "Sorry to Ruin the Fun, but an Ice Age Cometh," The Australian, April 23, 2008. 2009 DRAFT 53 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! 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I-. · Is f-1. ··. ·1. - Q (I') ’ _ V 1 U1 Ch @1 1 1 1 1 lglll‘€ — . O 2ll‘ l‘l‘2l l3IlC€ SlIlC€ F' 2 15· S l I d' ' 161114 54 4 March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Some Major Inconsistencies in the Science of Global Warming that Need to Be Explained 1366-6 -; pnod/5} an:12 i‘·' E [J li p·l¤ll\ . JR 1366.4 ( rlulrlv /\ “ *` l N _ 1366.2 lh"|b|.I’,f`¤,\ K {JJ] l l 1366 . I A i` HI km lj ll 1365,12 X I) '\ I} ll 1365 6 n lla" )/ Mk", / S Nh O L""`."'A"} \\`·._\J_.r \L‘r " kit L|00dF0rTrce;$_tJrg 1365.21975 1938 1985 1999 1995 2888 2885 2918 Figure 2-15: Solar Irradiance since 1979*5 · A 14 From http://www.]unkscience.com/Greenhouse/irradiancegif 15 http://www.woodf0rtrees.org/plot/pmod/mean:12 From PMOD; SORCE solar irradiance instrument does not show the additional decline .— 2009 DRAFT 55 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA [2.4.2 Brief History of Research on Causes of Global Climate Changesm [2.4.4 Copeland and Watts In 2008 Copeland and Watts "published" a paper on Watts’ blog. The two-part paper presented “Evidence of a Significant Solar Imprint in Annual Globally Averaged Temperature Trends." By using the first differences of smoothed HadCRUTv3 data with Hodrick-Prescott filtering and a lambda = 7, they produced the graph shown in Figure 5-‘?. This graph is quite ‘ remarkable in that the peaks in the annual rate of change appear to correspond very closely to solar cycle peaks and as indicated by the indicated solar cycle number. · Fig 2-?: Sunspot Cycles Derived Entirely from Global Temperature Data - one . . . l . . . . . . . . Ulm 11 Q 13 ..5 17 W 21 y 23Jl _ o.os 2 U, i fi _. if ` ~o.¤z , ~ ‘ ’\ _' V _ is zu ' \l V .. i - ht/ig ( =i· fri`, I » [ E om;. ly , V it .V ly l l \ l E *0 D;] 0 *2 i T4 Q V C bl 1 V l l lr i i. —D.D3 V V -0.04 I I _ 4 ` -¤.¤s r i JDJJ6 A I BD LBSD 1.9U*D 192G* 19-40 1960 1 BU ZEIUCI First dlfEea-oznces dn smuuthcd uawcnurva, H¤d‘Hck—P·r»esc¤tt mlserlng with lasnbdaw?. Peaks In the annual! atgggrifhange cunwzspnnd ruughly to solar cycle peaks as Indllizabed by the acconmanymg snlar cyde Source: Copeland and Watts (2008), Part ll. — This or similar analyses have been done by a number of researchers with similar or less revealing results. There is a possibility, of course, that the cycles shown here are picking up some other non-solar cycle in the climate system of unknown origin. There are several reasons, however, to believe that this is highly unlikely. The first of these is the extremely close correspondence 16 John’s paper and book A 56 March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Some Major Inconsistencies in the Science of Global Warming that Need to Be Explained between the cycles shown in the analysis and known sunspot cycles. The second is that the analysis appears to pick up the effects of the different characteristics of the two 11-year Schwabe sunspot cycles that make up each 22-year Hale cycle. This conclusion is based on the fact that odd numbered cycles shown in Figure 5-? are consistently and noticeably stronger than the even numbered ones. This appears to be consistent with a known feature of the Hale sunspot cycle in which this 22 year cycle is composed of alternating 11 year phases. These are referred to as parallel andiantiparallel phases, with transitions occurring near solar peaks. Mavromichalaki, et. al. (1997), and Orgutsov, et al. (2003) contend that during solar cycles with positive polarity, the Galactic Cosmic Ray (GCR) flux is doubled. This implicates GCR flux in modulating global temperature trends. The _ difference in peak amplitudes appears to support the kind of influence on terrestrial climate postulated by Svensmark (1998). The evidence of bidecadal oscillations appears to be inconsistent with the conclusions of the IPCC concerning role of GHGs since they believe that solar variations play little role in global climate. · The analysis also appears to show a longer periodicity on the order of 60 to 70 years, i 1 corresponding closely to three bidecadal oscillations. lf so, we have just come out of the peak of the longer cycle, and can expect global average temperature trends to moderate or even fall, with ‘ _ increased likelihood of a cooling phase similar to that experienced during the mid-20th century ` or even during the "Little Ice Age." This could even lead to a new ice age in the worst case if GHG levels are not a significant factor. It may be important to note that the current downtrend line has broken upward pattern of lows in period from about 1945, just as happened in about 1940. . Copeland and Watts (2008) reached the following conclusions: •t• "The periodicity revealed in the data, along with the strong correlation of solar cycles to HadCRUT surface data, suggests that the rapid increase in globally averaged temperatures in the second half of 20th century was not unusual, but part of a ~66 year climate cycle that has a long history of influencing terrestrial climate." •t• "While the longer cycle itself may be strongly influenced by long term oceanic ‘ oscillations, it is ultimately related to bidecadal oscillations that have an origin in impact of solar activity on terrestrial climate." ] · 2009 DRAFT 57 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA 2.4.5 Summary of Evidence for CO2 and Sun/Cosmic Ray Warming Hypotheses Besides the most apparent comparisons between global temperatures and CO2 levels, the CO2 only and sun/cosmic ray hypotheses imply a number of predictions involving observable evidence. An interesting comparison of the predictions of the CO2 and the sun/cosmic ray hypotheses with available data: _ TTTTMTMM ”T""Mm”"i r>r€ii€H5IC" 'W”””`W”"—T""'T H§Q§Y{2§§` V Prediction - CO; Sun/Cosmic Offering W ~ Issue Hypothesis Ray Actual Data C Best . . p j Hypothesis y p p Explanation " iAntarctic and Temperatures in 1 Temperaturesi Temperatures move in g Sun/Cosmic e Arctic the Arctic and I will initially { opposite directions _ Q Ray I Temperatures Antarctic will p move in C - rise opposite I . symmetrically g directions _ _ g p . p _ ‘ Troposphere Fastest warming The I Surface warming similar or Sun/Cosmic i Temperature will be in the j troposphere 0 greater than tropospheric I Ray i troposphere over S warming will warming ` ‘ A N the tropics » be uniform y Timing of CO2 CO2 increases Temperature V CO2 concentrations C Sun/Cosmic . A and Temperature then temperature increases increase about 800·years I Ray , Changes at End increases then CO2 after temperature increases » i of Ice Age increases g V . _ Temperature NA NA _ Cosmic ray flux and Sun Sun/Cosmic ` I correlate with activity correlates with C Ray ‘ i the driver over temperature, CO2 does not _ last 400 years I 1 1 t n I Temperatures Very hot due to Very cold 0 Very cold ice age Sun/Cosmic a during CO2 levels > IOXI due to high Ray D j Ordovician present I cosmic ray : p period iflux p Q I _ 4 I p p pa , Other Planets· No change I Other planets {Warming has been detected Sun/Cosmic 3 Climate p C will warm Ion several other planets Ray §HJF6`é'T”G'Fé§(;yj@§jT”—”*`"”“T~”"”"—T_—""”*`"”`””'"”""“T"‘”T Gregory (2008) provides a much more detailed description of each of these issues and his basis for reaching the conclusions that he has. In contrast, the IPCC reports conclude that since the CSI variation is small therefore solar variability makes at most a very minor contribution to global temperature changes and can be safely ignored in most of their actual models and conclusions. This does not address the possibility, however, as hypothesized by Svensen, that 58 ° i March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! SomeMaj0r Inconsistencies in the Science of Global Warming that Need to Be Explained there may be indirect pathways by which solar variability can have substantial effects on the Earth. To the extent that Gregory has accurately captured the comparison, the sun/cosmic ray hypothesis appears to offer a much better explanation of all these comparisons. Gregory (2008) also compares the temperature increases predicted by the IPCC computer models during the 20th Century with the actual temperature increases and says that the predicted was 1.6 to 3.74oC while the observed was about 0.6oC. He comments that “a model that fails to history match is useless for predicting the future." ?? 2.4.6 Landscheidt (2003) Paper Landscheidt (2003) predicts a low comparable to the Maunder Minimum, the last major cold period of the Little Ice Age, in 2030 (one Hale cycle from now) based on solar dynamics. He says that the cycle "minima around 2030 and 2201 will go along with periods of cold climate comparable to the nadir of the Little Ice Age. As to the minimum around 2030, there are additional indications that global cooling is to be expected instead of global warming. The Pacific Decadal Oscillation (PDO) will show negative values up to at least 2016 (Landscheidt, 2001), and La Ninas will be more frequent and stronger than El Ninos through 2018 (Landscheidt, 2000)." It is interesting to note that this is the case during periods of negative c PDOs, so Landscheidt’s predictions are parallel to those implied by the PDO hypothesis. I 2.4.7 Other Recent Research ‘ _ [Move to Section 1 and substitute JD’s new section] In an article in Physics Today, Scafetta and West (2008) estimate that the Sun could account for as much as 69% of the increase in Earth's average temperature, depending on the TSI reconstruction used. Furthermore, if the Sun does cool off, as some solar forecasts predict will happen over the next few decades, that cooling could stabilize Earth's climate and avoid the catastrophic consequences predicted in the IPCC report." - I 2.4.8 Are Sunspot Cycles Telling Us Anything? 2.4.9.1 Sunspot Cycle 23 ls Now Over 12 Years Old Sunspot cycle 23 reached its 12th birthday in May, 2008. Cycle 22 was only 9.5 years long. There have only been three small and short-lived Cycle 24 spots to date. It is widely believed 2009 DRAFT 59 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA that the longer cycle 23 lasts and the later and weaker Cycle 24 is, the colder global temperatures will be. _ 2.4.10 Penn and Livingston . In 2006, two astrophysicists, Penn and Livingston of the National Solar Observatory‘?? published a paper reporting on their measurements of the computed magnetic field from the Zeeman splitting of the Fe 1 1564.8 nm line, shown for umbral spectra observed from 1998 through 2005. While there is a large variation between different sunspots, nonparametric tests confirm that the data show a highly significant trend. Mean values for each calendar year are shown as data points in Figure VV, and the error bars show the standard error of the mean. The best-fit linear function (fit to the original 906 data points) reveals a decrease in the average magnetic field strength of 52 G/yr. Magnetic field and intensity changes observed over time in I the sunspot umbrae from different spots behave in the same way as the magnetic field and intensity changes observed spatially across single sunspots. If these trends continue the authors say that sunspots may vanish by 2015. Given the strong association between sunspots and global temperatures, this suggests the possibility that we may be entering a period of global cooling. This possibility needs to be discussed in the Draft TSD. ;w;ioi;:· 1 ’ n vi E! _ _ I 5 » Z£»BlZJE¤ r • ‘“ J _:T~4Q‘-ww ` . l E" GDB i"*·~~—»._.__,__ —— HJ ` ¤ ; wl" · —..__,_ J:] _ >—~“*‘···--_,__ " r_.r:» “ ·=—....______M cm :2‘»¤1· ¤1`2•~·f;¤ ‘ r g "“g3—--...___, tr., ·~· V _ -"""*¤-·,.,`_W_%-,~ U UD A ZECIUU ETiC!·¤Zl L-`Ei{3·¤I]1·£$ EDGE Ti‘m·¤=;; [°*r"ie»e.¤ rj V A Figure 2-?: Decay in Sun’s Magnetic Field since 1999 60 March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Some Major Inc0nsistencies_ in the Science of Global Warming that Need to Be Explained Source: Penn and Livingston (2006) 2.5 Solar Variability May Determine Major Climate Oscillations [Currently available research shows that the closest association between global temperatures and other variables is with the Pacific Decadal Oscillation (PDO) rather than with CO2. [refs] In fact, the correlation is about 0.83 and every major change in the PDO appears to be mirrored in the global temperatures in the period since 1880. ] ` S » Solar variations=>PDO=>other oscillations=>temps?? _ One possibility is that solar variability and changes in the PDO are not independent and that [ one influences the other or both respond to a third influence not yet identified. Ian Wilson is one of the leading advocates of this view. I Global temperatures appear to be influenced by the PDO, which may in turn determine the other oceanic oscillations •t• PDO may be primarily determined by indirect solar variations I •t• So indirect solar variations may determine climatic oscillations •I• And climatic oscillations may not be independent events 2.6 Conclusions with Regard to the Best Explanation for Global Temperature Fluctuations ` The reason for this extensive review of some of the availablescience is to use it to derive some implications for economic analysis of climate change control Several general conclusions stand out as a result of this analysis: Despite the complexity of the climate system the following conclusions appear to be well ‘ supported by the available data: V A. What appears to be by far the best single explanation for global temperature fluctuations is variations in the PDO/ENSO. ENSO appears to operate in a 3-5 year cycle. PDO/AMO appear to operate in about a 60 year cycle. B. There appears to be a strong association between solar sunspots/irradiance and global temperature fluctuations. It is unclear exactly how this operates, but it may be through indirect solar variability such as the effect on cloud formation. 2009 DRAFT 61 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA C. Changes in GHG concentrations appear to have so little effect that it is difficult to find any effect in the satellite temperature record, which started in 1978. U D. The surface measurements (HADCRUT) are more ambiguous than the satellite measurements in that the increasing temperatures shown since the mid-1970s could either be due to the rapid growth of urbanization and the heat island effect or by the increase in GHG levels. However, since no such increase is shown in the satellite record it appears more likely that urbanization and the UHI effect are the most likely cause. If so, the increases may have little to do with GHGs` and everything to do with the rapid urbanization during the period. Given the discrepancy between surface temperature records in the 1940-75 and 1998-2008 and the increases in GHG levels during these periods it appears even more unlikely that GHGsihave much effect on measured surface temperatures either. These points need to be very carefully and fully discussed in the draft TSD. E. Hence it is not reasonable to conclude that there is any endangerment from changes in GHG levels based on the satellite record, since almost all the fluctuations appear to be due to natural causes and not human-caused pollution as defined by the Clean Air Act. I The surface record is more equivocal but needs to be carefully discussed and fully nuanced. . F. There is a strong possibility that there are some other natural causes of global temperature fluctuations that we do not yet fully understand and which may account for the 1998 temperature peak which appears on both the satellite and surface temperature records. This possibility needs to be fully explained and discussed in the Draft TSD. Resolving the remaining uncertainties would appear to be of great importance before significant expenditures are made on the assumption that the GHG only hypothesis is correct. ` The important factors affecting global temperatures may include any of the three hypothesized in this section or all of them or others not discussed here. We do not currently have sufficient evidence to determine which, if any, are of importance and how important each might be. The currently favored GHG only hypothesis does not explain a number of aspects of the available data so is appears unlikely to be the sole explanation. There is an urgent need to update and improve on the IPCC reports by taking an independent perspective 62 ' March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Some Major Inconsistencies in the Science of Global Warming that Need to Be Explained and including new information not included in their reports concerning all the factors summarized above. 2009 DRAFT 63 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA 3. Contrast between Continuing Improvements in US Health and Welfare and their Alleged Endangerment Described in the draft TSD One of the most glaring problems of all with the EPA’s Endangerment TSD is the nearly complete disregard of observed trends in a wide array of measures which by and large show that ` despite decades of increasing anthropogenic greenhouse gas emissions the U.S. population does not seem to have been adversely affected by any vulnerabilities, risks, and impacts that may have arisen (to the extent that any at all have actually occurred as the result of any human-induced - climate changes). For instance, despite the overall rise in U.S. and global average temperatures for the past 30 . years, U.S. crop yields have increased (Figure 3-l), the population’s sensitivity to extreme heat has decreased (Figure 3-2), and our general air quality has improved (Figure 3-3). Further, there has been no long-term increase in weather-related property damage once changes in inflation, population size, and population wealth are accounted for (an essential step in any temporal comparison). All of these trends are in the opposite sense from those described in the EPA’s l Endangerment TSD. ‘ i E: 56 · 160 " ss ‘ ‘ ‘ . g V Tenwperature I 3 + ` H9 I, EE 54 ~ .. { » < 3, . E ry · · a. _ ,2,, ~ lg ‘ sgi `l"iy;.\{·‘a» lr¤·*··l I 1 _ mo zi ge pt pgs g-4 . ESE1 ( ’ ao'? Q Corn Yle-idk * gt, 5; as prgmpimmn -_ so EW is t r .. d i l J e li " lll ( # 2 s d A *3 § § as " . c 3 zu ·· E _ . Wheat Yield _ y E QI] -¤·—·•—{-1-1-1-1-w-•-;-1-r-v-—;—w¤—r¤—g—#v+•—g-r•—•~—rr1—v#—p¤¤—v-r—y—+w—v-+-;—v+w—»—pw~ ·— U ieee was was 1225 1935 is-as 1955 wss we V was S was anus Year Figure 3-1: Yields of Major Cash Crops such as Corn and Wheat Data sources: NCDC, USDA 64 l March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Some Major Inconsistencies in the Science of Global Warming that Need to Be Explained Average Annual Heat-Related Mortality U, 50 % 40 it `F 3 G 5 20 Q e g 10 F ‘ tb co "b z{b‘;\ NCS?) ,’\éb A9 Q?} QU . i eg Figure 3-2. Average Annual Heat-Related Mortality Per Standardized Million People in the U.S. (Source: Davis et al., 2003). A Ozone Air Quality; 1980 -—·· 2007 (Based OH Annual 4th Nmdmtlm 8·~l··l0ui‘ Awrage) biaimal 'Rend based on 289 Sites nu i i ‘ i A A '=` A " ‘ ‘ ‘ . 1 ” t »-» `_LJ~i‘¢»-¥£;__; W `*lQ*Y· f>'|j,'_; "` V Q..`~L.._,' : g at F p iiiiiiriiiliiiliiiiizaaaaaaa umceoeueucneuucuuceuuuuuucca ascaaanaaaseeeaaeeoauueooucn 012s·4¤»?·ne=¤1as·i=s0va—eoi2s4¤te? A @80 to 20D? 7 21% decrease in National Average Figure 3-3. Trends in ozone air quality 2009 DRAFT 65 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA Source: "http://www.epa.gov/airtrends/ozone.ht1nl Perhaps, most significant of all, the average lifespan of Americans has increased (Figure 2-5). BU 1 75 · 1 E T0 . E B5 l B* § E0 E. 55 'LLI ig 5u_ 45 l *1U_ ', asti 1890 1900 19,10 1920 1930 1940 19501950 19}*0 19801990 2000 2010 Year Fi ure 3-5: Life Ex ectanc at Birth in the U.S. g _ P Y Sourcef http://www.cdc.gov/nchs/data/hus/hus07.pdf#027 What better measures of human health and welfare are there? ln fact, there is no better way 1 to obtain a good picture of how human health and welfare may trend in the future under increases in greenhouse gas emissions than to assess how we have fared in the past during a period of increasing greenhouse gas emissions. True, hurricanes will strike again in the future and cause a great deal of damage and suffering. But that will largely occur because our climate is one which includes hurricanes. The same is true for tornadoes, droughts, floods, heat-waves, cold i 1 outbreaks, strong thunderstorms, heavy rains, hail, lightning, snowstorms, blizzards, freezing rain, etc. Those are all aspects of our climate. Climate change may alter the strength, path, or frequency of -these events—lessening some and increasing others. But to the large part, our nation’s climate in the future will be made up of ‘ the same characteristics as it is today. 66 March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Some Major Inconsistencies in the Science of Global Warming that Need to Be Explained Obviously, there is substantial variation in the viewpoints of proponents and skeptics on what value to use for this crucial factor. One additional viewpoint is offered by Miskolczi (2007), who suggests a value of about ~0.24°C,l7 which is less than even the skeptics shown in the figure have proposed. The remainder of Section 3 will outline a number of inconsistencies between the expectations of the GHG hypothesis and available data which if correct suggest that CSF is either very small or even zero. A 3.1 An inconsistency: Enhanced Greenhouse Effect May Be Overestimated by IPCC . ` A major cause for concern with regard to the Enhanced Greenhouse Effect espoused by the IPCC is that a crucial implied assumption may not be valid based on real world data. The IPCC models imply that global relative humidity is a constant as a result of various assumptions about evaporation and participation. This appears not to be the case, however, as shown in the following graph. Stockwell (2008) provides a discussion of the pros and cons for EGE and concludes that it is doubtful. Ref: http://landshape.org/enm/greenhouse—thermodynamics-and- » gcms/ Gregory and XXX say that the IPCC models all assume that global relative humidity is a constant.18 I note that this assumption would appear to imply their result since increases in temperature increase the amount of water vapor that the atmosphere can hold. This in turn 17 l\/liskolczi offers a very similar value (~O.25oC) in an earlier paper (Miskolczi et al., 1990) with some explanation as to its derivation. This paper attributes the 0.25oC "to the exact solution of the semi- transparent radiation transfer problem in gravitationally bounded atmosphere. The instrument of the above ascertainments is (Miskolczi et al., 1990). The simulations, he says, were made on the Earth’s Radiation Budget Experiment (ERBE 2004) Monthly Scanner Data Product of NASA Langley Research Center, and the TIROS Initial Guess Retrieval (TIGR) Global Radiosonde Archive (1983). 18 Yes, I agree. I don’t mean to suggest someone types in relative humidity = constant into the computer code. I said in my write—up "Relative humidity = constant (or various parameters to achieve the same effect.) ls this O.K? ‘ They model evaporation and precipitation to achieve an almost constant relative humidity. This is based on short term observations of temperature changes. During these observations CO2 concentrations are approximately constant, so these observations only hold tmc over periods when CO2 does not change much. lt is invalid to extrapolate these observations to long term periods with increasing CO2. Comment by Ken Gregory — june 2l, 2008 @ 4:04 am ’ 2009 DRAFT ‘ 67 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA results in an increased GHG warming effect, and so on and on, just as the IPCC concluded. Gregory puts it this way: There is no physics in support of this assumption, and no way to calculate its value from first principles. This assumption means that if temperatures increase for any reason, the amount of water vapour in the atmosphere increases. But water vapor is the most important greenhouse gas, so the · GHE becomes stronger and temperatures increase more. The current theory does not determine this - it is only an assumption. If this assumption is only slightly wrong, it completely changes the expected response of increasing CO2 because water vapour is such a dominant greenhouse gas. So if this arbitrary assumption does not hold, then there is no positive feedback effect. If _ accurate, the chart appears to support the anti-GW case: _ · One recent alternative to the IPCC’s approach is a new theory proposed by Miskolczi (2007). Whether is correct or not is not yet known, but it does offer the advantage that it may explain several observed atmospheric observations better than the models relied on by the IPCC. Last V week someone named Ken Gregory posted an understandable interpretation of it (http://wvvw.friendsofscience.org/assets/documents/The_Saturated_Greenhouse_Effect.htm) which argues that the IPCC approach violates energy conservation laws. He argues that the . new theory shows that the application of these laws requires that the atmosphere maintain a "saturated" greenhouse effect controlled by water vapor content (ie, any "excess" of GHGs gets "rained out"). As a result any increase in other GHGs (like CO2) results in a decrease in water vapor, the main GHG. Gregory calculates that the CSF would be, and spells real trouble for the warmist viewpoint. Gregoryconcludes that "a/most all of the global warmingof the last century must have been due to changes of the Sun or albedo." The following chart shows that global relative humidity has indeed been falling for 60 years, particularly at the higher (blue) altitudes I which he believes are the most relevant. ’ [In 2007 Miskolczi published a new theory which argues that the IPCC approach violates _ energy conservation laws. Global relative humidity is controlled by the laws of physics, not 68 ‘ March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Some M3' · · · ence of Global Warm' I 1ng that Need to Be Explained |PCC’s arbltrar · A Y assumptnon that it is a co · · nstant, which as NOT th e case over last 60 I y68l’S. V K Global Relative Humidity 300 - 700 mb · · .»» ·» ·. —= tv N · it Q * ,;.9 xg; ze? Q § · - ‘ * € · `··~ ;_ e‘· " 1 - `:‘ T <$M ‘ t% e `” * · ;? 7 1 -’ ii ” " 0 ” Z., 49 ·•-·* l“A` ·· U - ' E ··- -.~ . ‘· ; r·;,» » V- E aawa » M 0 f ` %F§‘—€% »‘; ;_,g \;-.L;,. ‘ ;§ £'4 . r ·£» E ,,45 T .,°i Y •l2IJ t xl ‘ “ , QL .» .· qu »»·<.» {itil: _·:45`.· if -»E§_{,% i§@£»?'?‘~¤`{"·i#·3i¤¢t?L*?;_?§*%¢v¢»,»a»~¤,.. 3 43 A ·-· —· ·· ·#i E 41 A ~ wma gr a * Mae. t . `E a t .? *` ;·;;_.;,,.'.v if ~ eq ?“ . U: ; ’?"‘ ·_ gx @2% *·~ ; »t;.;.;~ t? V,,,» ,‘»` " **53:, ·&§ ·—“» · !: t ri;. ~• .,g t, 1 * 1 , 7* -* * ,_ 2 ~ ,,— " ;_ , v,,_,¤»r§£§g·>· 1,, · _; R · , ·· ·- ·, 39 i *’* =*·—·Ri$$:¤S, ctx.? :,.-9; Lk tg \- - .·‘ . i UE, jj 4 i v'; _;- ’ 1 . ~ ', V ` t’;g"·l§1t~ ">Yg;~·4:§ ,.-.4 tt- W e · · el». . ’ er ‘°Ym’”“" ’ ‘ 0 W"` B'? $ $0, Y if ' ‘ § " x fg *·’ g‘¢g?J— ‘ " .. *1;; ’§;3¤' r"?;;ga.#v; x _ _ _; "E ‘°'i" ~‘*“ ¢' #l¥‘l»¤%"l ' §§_ i§z, ¤ 'Z `· l i . ?'“(M $`§` .· j ` ~»; ;*§_ ·· { t · ,. _ , wm. ‘ ,_ mr ·` ~¢¤ Jig; Q§y 435; ; gt§ lr WE .©ra¢‘xa$¢tz~r§?E%? » · ~a*sv»;r· t . $ V · ¤?e,a~—».V ~~ ·~» -~ :¢‘%»t t. ·e · = · » " ‘ " OO {N .. aa at é "T LO LO LO (D (N (O C) W OO {xi ` · O`? O) O) O-;. Ot, (O l"'* l"‘·—· OO 0;) (D D W · I 300 mb —-400 mb ·———-·-50g ... V mb 600 mb — mg S0urce· Gm · · 0 I · 20Yy (2008), cntmg NOAA at · - . b1n/T1mesemes/t1mese1·1es1. l Ov/c I ......_.....;..._;...tL ‘ · “· · l Box 81 of 4AR Ch il The radiative effec · ‘ t of . ' l absorption by water vapour is roughly proportional t h · C9“€€¤YFHtlon, so it is the fractional change in water A O t Q logarithm Of its _ va O ‘ that governs its strength as a feedback mech ` ill, Concentratlom not the absolute Chang€’ . A anism. a culati ‘ V8.pOLIT l”€mEiII'lS at all 8ppI'OXlm&I€ly COI'lSt3I"It fI'é1CtlOl”i f ` Ons Wlth GCMS Suggest that Water relative humidit R O its Saturated Value (CIOSE to un h y H)) under global-scale warming (see Sect' 8 C a"9€d uniform warming, the largest fractional change in water lon -6d3'])- Under Such a response, for _ V3 OUI' an . . the feedback, 0 9€St Contribution to COl'T`ll'l'°I€l'lt From http·//land r _Jun€ 2g' 2008 @ Mm . shape.org/enm/ ree - 9 nhouse-thermodynamics-and-water-vapor/ ` ‘ 2009 DRAFT , — 69 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA Precipitation provides greenhouse equilibrium mechanism for climate in accordance with physical laws. Further, the increase in ambient CO2 results in decrease in water vapor, the main GHG. The Result is that CSF would be ~O.24°C, which is less than even the skeptics claim. Implications of New Theory "The long wave upward radiation from the surface is limited to 1.5 times the short wave downward radiation from the Sun. This limits the temperature to very close to the current temperature. Therefore, almost all ofthe global warmingof the last century must have been due to changes of ` the Sun or albedo." —Ken Gregory, June, 2008 3.2 A Second inconsistency: Do Changes in CO2 Cause Changes in I Temperature? The IPCC (2007) argues that it is changes in ambient CO2 levels that have and will largely determine temperature changes. A number of skeptics dispute this. One of their arguments is that changes in temperature have preceded changes in CO2 by hundreds of years rather than the other way around over the last quarter million years (see Gregory, 2008, citing Caillon et al., 2003; and Singer, 2008, citing Fischer, 1999). They argue that this is incompatible with changes . in CO2 levels having any effect on temperature. According to Gregory (2008), "Logic demands that cause must precede effect. Increases in air temperature drive increases in atmospheric CO2 l concentration, and not vice versa." So at least these skeptics would presumably argue CSF = 0 ` since in their view changes in ambient CO2 do not increase temperatures. 3.3 A Third inconsistency: IPCC Climate Models Inconsistent with Observed Temperatures Figure 2-? shows how climate models and reality diverge._The red, purple, and orange lines are model forecasts of global temperatures under different emission scenarios. The yellow line shows how much warming we are supposedly "committed to" even if CO2 concentrations don’t change according to the IPCC. The blue and green lines are actual temperatures as measured by ground-based (HadCrut) and satellite (UAH LT) monitoring systems. 70 March 16, . \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Some Major Inconsistcncies in the Science of Global Warming that Need to Be Explained What’s really rather remarkable, is that since 2000, the rates at which CO2 emissions and concentrations are increasing have accelerated. According to Canadell et al. (2008), fossil fuel and cement emissions increased by 3.3 percent per year during 2000-2006, compared to 1.3 _ percent per year in the 1990s. Similarly, atmospheric CO2 concentrations increased by 1.93 parts per million per year during 2000-2006, compared to 1.58 ppm in the 1990s. And yet, despite accelerating emission rates and concentrations, there's been no net warming in the 21st century, and more accurately, a decline. — 2009 DRAFT 71 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Conclusions 4. Detailed Comments 4.1 · Executive Summary Page ES—7, lines 25-30: The cited temperature changes are misleading at best. There is a profound difference between surface and satellite measurements which is not discussed. . Satellite data shows no significant change between 1978 and 2008 and thus does not support the view that there was an increased rate of warming in the last 30 years. Infact, It says that there has been no appreciable change. As discussed in Section 2.5 above there are strong reasons to believe that the satellite data is more accurate so any statement along these lines needs to carefully explain the differences between the measu-rement approaches and explain why one is superior to the other. It ls also misleading to quote changes since 1900 since it is highly unlikely that GHG changes were appreciable before 1940. 4.2 Part ll ‘ A UAH MONTHLY MEANS OF LOWER TROPOSPHERE LT5.2 Global Temperature Anomaly 1970-2008 ` 2 l . , · * 1 I · l l 1,9 ..__._ .._. ..,.. ._,.... .._. .._.. -1 ._... .,... .... ,.__..... .._.. - ........ l ..._ .._. ...... -. ......_. -..--..--1 ...... -.-. .- ...,. .... ...,... -. .... _- ...... l--.- -..- ........, ..... ...1 ..... -.- ......, . .... Q. - - --.-’ ..... . ....... 1.--.. .... --- -.-. ..-.1-..-- -- ii .... 1 . .. . .. ..... . . .- -1 ..... .. I ....... - .... I . - .... - .... · 0. ...- ..... -1- _... - I -..._... ._._ .._. ..... 1 ...-...- l ...... ...... ..... 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W-,}. .... -.--.- -... - ., -..,‘ -- -..--- - 1- ,,1 . ._ ..-. . . _ - ..... .... --1 .... . ..,... - -,.- .-- - . -. - ...... i-- -.-- --- -1--- --- l I I I 1 I 0 ..,-.- ---.-. - . i-.-.. - .. ..-.--.l..-.-....1.--...... -.§.-.... . ` --..-.... -..-;lr,....'.. . vt .w...‘ -.-Y".- .-.... . ........ ..-..¥.-... Y- -..... V ...-lm"`. 7... _1,_, .__..___ .- _._. - .._... l--_ -- - _... - -:-. - ,-- - .-1 _._. - . -..-1--- ` `"ll l` ilfl 4 ”l”i2i iw T lili `lllli 1 '"llil TIT `H §”HlT1§&·€` .0.3 -·—-W-- -—~—<» -~ ·——»—!——— —·——»-—-·- 1 ~—»~—'—~ -~»l·'»-·»·~ ME--r—— [ ---r-— —»—»— »-—— l- ·--·· ~·—~— ~ ~~»» »——- ————| -- j—~— --—~— -. -.--1 ..... ...-. . .... -- ...... --.- - ........ ---.-1---}.- ...-.. ...... - ........ .-- --- .... -.-. `°i"lIll1llll'll*ll1llI1 Il -0-50 12 24 36 48 80 72 84 96 108 120 132 144 156 168 180 192 204 216 228 240 252 264 276 288 300 312 324 336 348 360 1979 ********** 2008 •Z• IPCC left out a major variable that actually is a major factor •I• CO2 is not as significant a factor In determining global temperatures as the IPCC hypothesized •t• Regional ocean oscillations are random events that IPCC also did not analyze but play a significant role In climate change _ 2009 DRAFT 73 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA An effort will be made in Section 5 to determine which of these explanations appear likely. . Section 6.1.2 will summarize the conclusions. ` 4.2.2 New Paper Predicts 10 Year GW "Postponement" i The authors of a new paper (Keenlyside, 2008) in Nature, who were also authors of the 2007 IPCC report, which they helped author, did not take account of effects of major known regional climate oscillations in the Atlantic Ocean. Since these are/may now be tuming towards a "cooler" mode, they believe that a GW "postponement" appears likely. These oscillations may _ be related to solar cycles, but were not analyzed by the IPCC. Not discussed in Nature was a similar and probably more significant change in a similar multi-decadal oscillation in the Pacific I (PDO) which has just moved into a cooling mode according to NASA. So the hypothesized "postponement” could be much longer than the authorsindicate.] 4.3 Part lll 4.4 Part IV 74 I _ March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! l Conclusions 5. Conclusions [to bc written] 2009 DRAFT 75 l \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA 76 · March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! References References Arrak, Arno, 2009, "Sattelite Data Show that there Was No Global Warming Before 1997," available from l http://icecap.us/images/uploads/ThereWasNoGlobalWarmingBefore1997.pdf Baker, Marcia B., and Gerard H. Roe, "The Shape of Things to Come: Why is Climate Change So Predictable‘?" 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Zagoni, Miklos, 2008, "Developments in Greenhouse Theory," available at http://hps.elte.hu/zagoni/Proofs of the Miskolczi theoryhtm 2009 DRAFT 79 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments on Draft TED for Endangerment Analysis for GHG Emissions under CAA 80 March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! References ‘ About the Comments · This report has been prepared by the National Center for Environmental Economics (NCEE) in the EPA Office of` Policy, Economics, and Innovation, which is a part of the Office of` the Administrator. It was authored by Alan Carlin and John Davidson of NCEE and in part builds on three previous reports (Carlin, 2007), Carlin (2007a), and Carlin (2008). 2009 DRAFT 81 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! NCEE Comments 0n Draft TED for Endangerment Analysis for GHG Emissions under CAA 4 This page intentionally left blank 82 March 16, \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\! Endnotes End notes 0 2009 DRAFT V ` 83 \!\! UNCORRECTED OCR SCAN OF DOC062509-004.pdf - VERIFY AGAINST ORIGINAL BEFORE USE \!\!