February 16, 2011



            The statement is being made in response to statements submitted to the Subcommittee on Energy and Power, Committee on Energy and Commerce, United States House of Representatives, February 9, 2011 by EPA Administrator Lisa P. Jackson and American Public Health Association representative Lynn Goldman, M.D.


            Administrator Jackson begins by stating that all Americans rely on the Clean Air Act to protect them from harmful air pollution.  I agree. Next, Administrator Jackson says she is relying on the 2007 Supreme Court decision that EPA could consider greenhouse gases an air pollutant.  Administrator Jackson neglected to include that the Supreme Court also said the Administrator could exclude a greenhouse gas if she could present evidence that the gas was not a pollutant or endangerment to mankind.  This gets to the heart of the issue since Administrator Jackson has singled out carbon dioxide as the key substance to regulate on the grounds that, as Administrator Jackson so frequently comments, "CO2 is a pollutant and an endangerment to mankind."  That anyone would say that CO2 is a pollutant is incredible, but particularly when said by Administrator Jackson who is a degreed chemical engineer.  There is not a single case, short of multi-thousands of parts per million (ppm) of this trace gas, that indicates CO2 to be a pollutant.  CO2 is the staff of life.  Earth's food chain begins with plants and as we all learned in elementary school, CO2 is what plants eat.  In fact, as thousands of peer reviewed laboratory and field studies show, the more CO2 plants "eat", the more robustly they grow.  This is not speculation based upon man-made models; this is from real, empirical observations.  I present three examples demonstrating that CO2 is not a pollutant; first, many commercial greenhouse operators grow the fruits and vegetables we buy in the grocery and where they and their staffs work, in an atmosphere of 1,000 ppm CO2.  The workers suffer no ill effects and the plants grow profusely.  Earth's current atmosphere contains only 390 ppm.  Secondly, as testified to the Unites States Senate, Princeton distinguished Professor William Happer has pointed that our very own government allows CO2 levels to build up to 8,000 ppm in our nuclear submarines where our sailors reside for week s at a time.  Thirdly, we breathe in the current 390 ppm of CO2 and breathe out 40,000 ppm (!) with our lungs incurring no toxic or detrimental effects.  For this Administration and especially Administrator Jackson to continue to refer to CO2 as a pollutant is far worse that a slip of the tongue or exaggeration; it is grossly misleading to our country's citizens.


            That man-made CO2 is a primary cause of climate change is just a hypothesis.  The hypothesis has not been proven and even the Intergovernmental Panel on Climate Change (IPCC) admits that when they do not say that they are 100% certain it is true.  While proving that the hypothesis is true for such a complex subject is probably impossible, it is only prudent to examine whether it can be shown to be false.  Webster's dictionary defines hypothesis as a provisional theory accepted for the sake of argument and testing.  Scientists are taught that a hypothesis must withstand its claims being verified or falsified by observing available empirical evidence.  When Albert Einstein, in 1905, proposed the theory of relativity, he encouraged other scientists to try and refute it as demanded by the scientific method.  Therefore, as a geologist and accustomed to looking back at what has happened in the past to understand why the Earth is physically like it is, I decided to use the same forensic approach to review Earth's old climates, her paleoclimates.  Sir Winston Churchill is credited with saying, "The farther backward you look, the farther forward you are likely to see;" certainly applicable here.  Five years ago I began this forensic endeavor thinking I could look back at old temperatures and the often thousands of ppm of atmospheric CO2 and show the tremendous impact such elevated CO2 levels had on Earth's paleoclimates.  I could not find such impacts.  I did find however, after reviewing "all" the scientific studies of others, determine that the hypotheses of significant CO2 induced climate change to be false and here is why:


1.      Per Dr. Phil Jones, director of the Climate Research Unit (CRU) at East Anglia University, which is the prime source of climate data for the IPCC, despite the steep rise in CO2, there has been no statistically significant warming of the Earth for the last 15 years.  Dr. Jones also has publicly admitted that, regarding anthropogenic global warming, the science is not settled.

2.      When climate proxies, such as ice cores, tree rings, isotopic analysis of ocean, lake and soil samples, stalagmites, corals, and leaf shapes and stomata densities are cross correlated, they give us a good relative measurement of Earth's old temperatures vs. those of the last 150 years.  These studies indicate that, even at much lower levels of CO2  in the past, the USA's temperatures today are not the warmest of the last 100 years (1934 was warmer) the last 1,000 years (the Medieval Warm Period was warmer), the last 10,000 years (the Roman Warm Period, Minoan Warm Period and Holocene Optimum were as warm or warmer according to proxy studies), the last 400,000 years (where of the last five interglacials our current interglacial has had the highest CO2 level yet is the coolest of the five) and to go way back, 430 million years ago, when there was glaciations down to 60 latitude while CO2 levels were about 4,000 ppm; over 10 times as high as today.

3.      Ice core analysis from Antarctica and Greenland show many intervals where CO2 levels lag or follow temperature changes, not vice versa.  A cause does not follow an effect.

4.      The physical heat trapping ability of CO2 declines logarithmically or very rapidly and at today's level cannot "trap" a significant amount of additional heat, consistent with the observations wherein paleotemperatures did not become catastrophically high even at CO2 levels of several thousand ppm.



The above is empirical evidence.  Administrator Jackson said the EPA reviewed thousands of public comments.  Those comments included much of the same data I reference, yet she has refused to even mention this very most basic of scientific tests, the empirical test.  The answer appears obvious; EPA cannot prevail in a discussion of real evidence so must rely on the output of climate modelers whose grants and very futures depend on generating the potential man-made catastrophes that satisfy the position articulated by the funding source.

      What about the public position papers of the leading scientific societies that declares a belief in man-made global warming?  None, to my knowledge, have agreed to take a vote of their membership.  Most societies are run by a small group of leaders, mostly academics, whose universities depend, in part, on government grants.  Why didn't Administrator Jackson mention the recent poll by "Scientific American", a very popular publication with scientists, which found that 77% of the thousands of respondents said they believed that climate was driven by natural causes, 83% said the IPCC was a corrupt organization, and 91% said the doubts about what is causing climate change should be publicly discussed.

      Administrator Jackson said eleven electric power companies thought EPA has proposed a reasonable approach focusing on improving energy efficiency.  I concur with improving energy efficiencies.  Improved efficiency should always be a top priority.  However, the same, regulated companies do not worry about carbon emission regulations because the consumer will ultimately pay whatever the increased costs.

None of us want to see pollutants negatively impact peoples' lives.  I agree . but CO2 is not a pollutant!  Nor has CO2 been a significant cause of climate change. Combining results from thousands of peer reviewed studies, it appears, however, that CO2 has, just since the industrial revolution 150 years ago, been responsible for a dramatic increase in the growth of Earth's plants and forests by over 50% (Mayeux, et al. 1997, Global Climate Change Biology 3,267-278. A further increase in atmospheric CO2 will continue to cause additional growth in Earth's food supply.

Administrator Jackson also says pollution can cause many health related problems.  Here, she did not actually say that CO2 is a pollutant because CO2 is not a health problem.  Very importantly, our additional CO2 has increased food production even more in the 1,000 ppm greenhouse environments.  However, should the EPA and others ultimately succeed in actually lowering Earth's CO2 levels, the aforementioned agricultural studies indicate that going back to the industrial revolution levels of 280 ppm would reduce the world's  food supply by the tremendous gains previously mentioned and probably starve many of the Earth's one billion severely undernourished individuals.  Why was this not mentioned?  I recommend the website for our non-profit at www.plantsneedco2.org and for even more information and substantiation, on the health and mortality impacts of climate change on his excellent website to www.CO2science.org.

Our ultimate hope is that the Administration and Administrator Jackson will do what President Obama promised the nation when he said he wanted decisions based on sound science.  They Administration should reevaluate their astonishingly firm position to ram through regulations to reduce CO2 levels.  Adhering to strict CO2 reduction goals will ultimately be borne by the consumer, will hurt the poor the most, and will drive jobs and even more companies overseas.  Lastly, for the trillions it will cost, there will be miniscule impact on Earth's climate.  Using the IPCC's own numbers and formulas, a severe reduction of 83% of the USA's CO2 emissions by 2050 would only have 0.1 of one degree reduction in global temperatures by that date.  Let's put part of the needless trillions into research needed to ultimately bring currently uneconomic alternative energies into commerciality.  Administrator Jackson must be aware of all of this information.  Why did she not balance her statement by including it?


The statement of Dr. Lynn Goldman is fraught with outright inaccuracies.  Instead of relying upon all of the peer reviewed literature pertinent to writing the position paper of the American Public Health Association, they appear to have missed great numbers of easily available peer reviewed studies from around the world that refute their various positions.  For instance, just from one excellent summary alone, "Climate Change Reconsidered" (CCR), 2009, published by the Heartland Institute, anyone can find references and summary statements included that directly contradict Dr. Goldman.  Dr. Goldman's statements to the Subcommittee were concerning greenhouse gases and she particularly singled out that CO2 is the major component of greenhouse gases, so I will also focus on CO2.  Below you will find some of Dr. Goldman's statements followed by a summary of peer reviewed studies, where available, from around the world.  The comments and references are listed in the order they appear in Dr. Goldman's statement.  I will paraphrase some comments to shorten this submittal and get straight to the point.

1)      Dr. Goldman:  EPA estimates that the first 20 years of the Clean Air Act prevented 200,000 premature deaths, 672,000 cases of bronchitis, 843,000 asthma attacks and 189,000 cardiovascular hospitalizations and that the six most common air pollutants decreased by 41%.  Dr. Goldman did not say whether CO2 was one of the six pollutants mentioned although many untrained readers could easily presume so since regulating CO2 is the paramount subject of the Chairman's bill.  Dr. Goldman, does the APHA have studies that show CO2 played a part in any of the aforementioned health or mortality issues?  I remind the Subcommittee and Dr. Goldman that we are breathing in only around 390 ppm of CO2 but our lungs hold 40,000 ppm at the time we exhale.  Isn't it blatantly clear that CO2 is not toxic to our bodies at concentrations many multiples higher than Earth's atmosphere contain today?  To the contrary, additional CO2 has and is continuing to stimulate increased crop yield, our nutrients, and through photosynthesis, put the oxygen in the air that we breathe.

2)      Dr. Goldman says the Supreme Court directed EPA to act on the science to protect the public health from the impacts of greenhouse gases which contribute to climate change.  Fair enough, but the Supreme Court did not say the EPA had to consider CO2 a pollutant if the EPA could simply provide information as to why CO2 is not a pollutant and an endangerment to man-kind.  Consider these facts; without greenhouse gases, Earth's surface temperature would be far below zero degrees Celsius and life as we know it would not exist.  I know of no scientist on either side of this issue that would disagree.  If there was no CO2 greenhouse effect, Earth would be about three degrees Celsius colder.  The Little Ice Age with its rampant death and starvation was colder by only about one-half that amount.  If there was no atmospheric CO2, there would be no life on Earth's continents.  Should the 180 ppm CO2 level of the last glacial stage have fallen only 30 ppm to 150 ppm, photosynthesis would have declined dramatically and many of Earth's plants would have withered and died. I have summarized why CO2 has been shown to not be a significant cause of climate change in discussing Administrator Jackson's statement.  Is the EPA incapable of summarizing the obvious facts and not relying on inadequate models, as their reasons for excluding CO2 from regulation under the Clean Air Act?

3)      Dr. Goldman: "The United States is the leader in contributing to greenhouse gas globally and carbon dioxide is the major component of greenhouse gases."  Absolutely doubly false as concerns CO2.  China surpassed the USA almost three years ago in CO2 emissions and China has not agreed to be bound to firm levels of CO2 emissions as proposed in any of the previous treaties.  That CO2 is the major greenhouse gas demonstrates how totally unknowledgeable Dr. Goldman and the APHA are regarding greenhouse gases and their impact on Earth's climate.  Water vapor is by far the leading greenhouse gas, accounting for 95% of the gases by volume and up to 90% of the greenhouse effect. Shame on the APHA for reading environmental extremist blogs from which to draw their conclusions.

4)      Dr. Goldman recommends the government implement environmental policies that will significantly reduce greenhouse gases.  Dr. Goldman recommends we actually reduce CO2, not just reduce the level of CO2 emissions.  As the CO2 level drops, food production will drop.  The ecosystems and habitats in our fields and forests will become less robust as indicated by the thousands of studies by the agricultural community, agricultural universities and commercial greenhouse operators.  Ask the latter what would happen if they reduced the 1,000 ppm levels in their greenhouses back to the 390 ppm in our current atmosphere.  Dr. Goldman, where are you finding peer reviewed studies that support this recommendation by you and the APHA?

5)      Dr. Goldman recommends that we deploy wind, solar and geothermal.  Wind and solar are not yet ready for prime time.  They are far more costly and unreliable than fossil fuels.  To burden our country needlessly by forcing the deployment of these non-commercial energies while the rest of the world uses the cheapest energies, would be unilateral economic suicide, hurt the poor the most, see jobs and industries follow the cheapest energies overseas, and negate our leadership in standard of living, healthcare and environmental stewardship.  "Rich" countries lead the world in environmental practices.  While the motives of the APHA may be genuine, the practical impacts of some of the recommendations are clearly negative.

6)      Dr. Goldman says "Climate change is one of the greatest threats to human health.  Scientists have stated in the strongest possible terms that human activities are to blame. The IPCC has unequivocally concluded that greenhouse gas (singular) is causing global warming." Unequivocal means certain and even the IPCC have not come to such a conclusion. Dr. Goldman continues:  "This increase in Earth's temperature is causing more regional extreme weather events, increases and decreases in temperature and rainfall, may create (more) floods, heat waves, drought, poor air quality that lead to poor health outcomes such as heat strokes, injury, malnutrition, respiratory illnesses, asthma and infectious diseases."  Dr. Goldman, there are 66 peer reviewed studies that show that longevity increases and/or diseases diminish in a warmer world.  There are fewer deaths from heart attacks, strokes and respiratory diseases (CCR, 2009, pages 664 to 676).  Also, 106 peer reviewed studies worldwide indicate 20th century droughts are no more frequent or severe than in the previous millennia and 47 more peer reviewed studies from North America, Europe and Asia indicate no increased frequency or severity of floods last century (CCR, 2009, pages 281 to 309).  The statistical histogram put together by the Center for Ocean-Atmospheric Prediction Studies at Florida State University shows that global cyclone (hurricane) energy has trended down for 17 years and is currently at a 30 year low despite the 24/7 ongoing rise in atmospheric CO2.  Another histogram of the number of strong to violent tornados in the USA shows a clear downward trend for the past 35 years.  Dr. Goldman, where are your peer reviewed studies, based on actual data and not simply on someone's opinion, that refute these peer reviewed studies?  Were you swayed by the claims in the Lancet and echoed by Secretary Sebelius of Health and Human Services immediately before the Copenhagen Conference that millions of deaths could be saved by lowering CO2 emissions?  Those statements are in direct contradiction to 25 peer reviewed studies from the United States, Russia, Japan, Norway, Korea, England, Australia, Brazil, Greece and Asia that showed a much higher death rate from heart attacks, strokes, and respiratory diseases following a drop in temperature versus following a heat event. (CCR, 2009, pages 664 to 667)  Do you have evidence, as many people claim, that shows that people who move from New York City to Miami actually die earlier than their actuarial peers left behind?  The average January temperature in New York City is 33º Fahrenheit and 77º in July.  The January temperature in Miami is 68º or 45º Fahrenheit warmer and the July average in Miami is 83º or 6º warmer than New York City.  Why has the United States population voluntarily migrated to the southern states if, as you suggest, warmer temperatures are so bad for the health of our citizens?  The length of the growing seasons also lengthens dramatically as you move south or in years when the temperatures rise in the north.  Are people stupid, healths wise, that voluntarily choose climates that average many degrees warmer?  Dr. Paul Reiter of the Pasteur Institute for Infectious Diseases has testified that there is no evidence that mosquito borne malaria has increased as Earth has warmed.  Dr. Goldman, if they exist, please furnish our lawmakers with peer reviewed studies that refute the above studies.

7)      Dr. Goldman: "Chairman Upton's bill would prohibit EPA from taking further actions to implement the Renewable Fuels Program which promotes the domestic production of advanced bio-fuels."  I say "great" if it will allow our lawmakers to decide which bio-fuels make sense.  The mandated use of ethanol is clearly a disaster in that it has greatly increased the price of corn, hurting the poor and undernourished the most, taken more standard fuel energy to make a gallon of ethanol than the energy created, and its utilizes more wild lands which could lead to the extinction of more species. One gallon of ethanol contains only 70% as much energy as regular gasoline so every bit you add lowers the miles per gallon of your car.  Even Al Gore has publicly admitted his mistake in advocating the use of ethanol.  Despite this, our Administration and obviously the APHA, is still recommending more bio-fuel production of ethanol.

In summary, the peer reviewed science plus empirical observations and common sense speak for themselves.  To ignore this is the true endangerment to mankind.

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