The Latest On The Federal War Against Internal Combustion Vehicles

June 08, 2024/ Francis Menton  @ Manhattan Contrarian

I’m old enough to remember a time when there were serious environmental concerns with internal combustion engine vehicles. NOx and SOx emissions caused a thick layer of brown smog in the atmosphere during calm weather spells in summer and winter; and a layer of black soot would cover the snow along the roadside in the winter. But gradually that all got cleaned up. Today the bona fide serious environmental concerns about internal combustion engines are far in the past. But the war to eliminate them — supposedly on environmental grounds — is just ramping up.

The Biden Administration is all in with the plan to get rid of the ICE car. Why? It seems to have something to do with the non-existent “climate crisis.” Meanwhile, Congress has passed no legislation authorizing the executive agencies to force ICE vehicles off the market. Nor is the Administration honest enough to admit that they are engaged in outlawing the vehicles that 90+% of the people drive.

Instead we get massive and thoroughly dishonest regulations effectively forcing the approaching end of the ICE vehicle without ever directly saying so. All with effective dates far enough into the future that the public will not notice that anything is happening in time for the upcoming election.

Two big new regulations on this subject have just gone final. First, there was EPA’s “Multi-Pollutant Emissions Standards for Model Years 2027 and Later Light- Duty and Medium-Duty Vehicles,” issued on April 18. And then yesterday from the NHTSA (part of the Department of Transportation) we get “Corporate Average Fuel Economy Standards for Passenger Cars and Light Trucks for Model Years 2027 and Beyond and Fuel Efficiency Standards for Heavy-Duty Pickup Trucks and Vans for Model Years 2030 and Beyond.” The first is 373 pages in the three-column, single-spaced format of the Federal Register. The second is 1004 pages in standard double-spaced typing.

If you should take the time to read some or all of the 1377 pages of text, don’t expect to find anywhere in all of that an admission that the plan is to suppress and ultimately eliminate the internal combustion car. Instead it’s happy sweet talk about the supposed “health” benefits of reducing greenhouse gas emissions. Here is an example from among many, this from page 27,844 of Volume 89 of the Federal Register:

EPA is establishing both criteria pollutant and GHG standards in this rulemaking given the need for additional reductions in emissions of these air pollutants to protect public health and welfare and based on EPA’s assessment of the suite of available control technologies for those pollutants, some of which are effective in controlling both GHGs and criteria pollutant emissions. Under these performance-based emissions standards, manufacturers have the discretion to choose the mix of technologies that achieve compliance across their fleets. EPA’s modeling provides information about several potential compliance paths manufacturers could use to comply with the standards, based on multiple inputs and assumptions (e.g., in what we have termed the central case, that manufacturers will seek the lowest cost compliance path).

“Manufacturers have the discretion to choose the mix of technologies that achieve compliance . . . .” Right. Everybody knows that the point of this is to force the majority of new car sales to be EVs or plug-in hybrids by some time in the early 2030s. But they’ll never say it straight.

And it’s the same with the new NHTSA Rule. This Rule sets new fleet-average fuel economy standards. NHTSA — aren’t they supposed to be in the business of “Highway Traffic Safety” (that’s the “HTS” part of their name)? Yes, but in the ultimate mission-creep, they are now the people behind the so-called “CAFE” (Corporate Average Fuel Economy) standards. Obviously, the people cannot be expected on their own to make appropriate trade-offs between fuel economy and other transportation needs (like carrying capacity). Thus, NHTSA now determines that beginning in the early 2030s, manufacturers must achieve average fuel economy for their fleets of 50+ miles per gallon.

But, you say, vehicles with internal combustion engines can’t achieve that figure if they are bigger than a thimble. Exactly. So here is a small piece of NHTSA’s justification:

Reducing gasoline consumption has multiple benefits – it improves our nation’s energy security, it saves consumers money, and reduces harmful pollutant emissions that lead to adverse human and environmental health outcomes and climate change. NHTSA estimates that relative to the reference baseline, this final rule will reduce carbon dioxide (CO2) emissions by 659 million metric tons for passenger cars and light trucks, and by 55 million metric tons for HDPUVs through calendar year 2050. Again, these relative reductions are greater if the rule is compared to the alternative baseline, but demonstrating a similar level of absolute carbon dioxide emissions.

You say that you have a need for a vehicle that can actually carry a couple of passengers and maybe a few suitcases? What kind of a traitor are you? Your options are to buy an EV or hire a ricksha.

The agencies know full well that they are forcing a transition to EVs that customers do not want. How fast must the forced transition be? This piece from Atlas EV Hub from March 25 estimates that EPA’s Rule by itself will force EV sales to be up to 69% of new vehicle sales by 2032:

The regulation is set to bring significant changes to the auto industry, potentially putting the United States on the glide path to full electrification. Manufacturers have several options to meet the new standards, and electric vehicles (EVs) will play a pivotal role in ensuring manufacturer compliance with these regulations. Under this final rule, battery electric and plug-in hybrid electric light-duty vehicles could make up 32 percent of all new vehicle sales in model year 2027, increasing to 69 percent by model year 2032.

The NHTSA CAFE Rule would require comparable, or perhaps even higher, percentages of EVs in manufacturer sales to achieve compliance.

Do you believe that the U.S. new vehicle market will switch over to mostly EVs so quickly over the next several years? I don’t believe it for a minute. So what happens when manufacturers produce mostly EVs to comply with these Rules, and then nobody will buy them? This could be very entertaining.

Is Beef Production A Major Contributor To Climate Change?

May 20, 2024 Francis Menton @ Manhattan Contrarian

Undoubtedly, by this time in your life you have read a hundred times, or maybe a thousand, that beef production is a “major contributor” to climate change. It’s one of those narratives that has become a continuous drumbeat in the progressive press. Probably, you have had no reason to question it. Without thinking about it, you likely assume that this narrative is probably true.

But there is good reason to think critically about this one. Among the various scare stories used to take further control of your life, this is one of the more important. With the war against fossil fuels, there is at least the pretense that their use can be reduced or eliminated without major effect on your lifestyle — i.e., just replace the energy from fossil fuels with “cheap” electricity from wind and sun. There is no such pretense with the war on beef. The end game is unabashedly to reduce your standard of living by taking away one of the most important and best parts of your diet.

So is it true that beef production is a major contributor to climate change? If you give the subject a moment’s critical thought, you will quickly realize that the proposition is wrong. And you will come to that conclusion even if you fully accept that methane gas in the atmosphere is a major contributor to climate change, and that cattle raised to produce beef emit large amounts of methane gas. There is an obvious logical flaw in the reasoning that is used to accuse beef production of being a major contributor to climate change.

But before getting to that, let’s look at one of my lists of the usual fools (and power-hungry government functionaries) repeating the narrative:

• From the UN Environmental Program, August 2021: “Methane emissions are driving climate change. . . . A recent assessment from the United Nations Environment Programme (UNEP) and the Climate and Clean Air Coalition found that cutting farming-related methane emissions would be key in the battle against climate change. . . . Methane has accounted for roughly 30 per cent of global warming since pre-industrial times.”
• From PBS, March 6, 2022: “Livestock production—primarily cows—produce 14.5 percent of global greenhouse gas emissions. The majority of that is in the form of methane, a potent greenhouse gas that is a natural byproduct of how some livestock process food.”
• From the World Resources Institute, March 7, 2022: “How does beef production cause greenhouse gas emissions? . . . Cows and other ruminant animals (like goats and sheep) emit methane, a potent greenhouse gas, as they digest grasses and plants. This process is called “enteric fermentation,” and it’s the origin of cows’ burps. Methane is also emitted from manure.”
• From Scientific American, November 7, 2023: “Cattle play a colossal role in climate change: As the single largest agricultural source of methane, a potent planet-warming gas, the world’s 940 million cows spew nearly 10 percent of all greenhouse gas emissions — much of it through belches and droppings.”

There is an endless supply of similar pieces should you have the time to look for them.

But what are these propagandists leaving out? Here’s the missing piece: the methane emitted by cattle comes from the digestion of the grass that they have eaten. But what happens to the grass if the cattle don’t eat it? The answer is, it dies anyway, and decays in the soil by bacterial action. That decay also produces methane. Is the amount of methane produced in this natural process more or less than the amount produced from digestion by cattle? I can’t think of any reason why it would be much different. It might even be more. The propagandists make the error of counting the methane emissions from beef cattle as “human” emissions, but the methane emission from decay of the same grass in the soil as “natural” emissions.

Kevin Killough at Just the News on May 13 has a report on the latest research. The researchers were Dr. Vaughn Holder of Alltech and Dr. Betsey Boughton of Archbold. Granted, these are agribusiness people, so take that into account if you want. The two studied the question of whether methane emissions from a pasture were greater or less depending on whether beef cattle were present on the pasture or not. The research took place at Buck Island Ranch, a wetland pasture about 150 miles outside Miami, Florida. Key result:

The researchers found that 19%-30% of methane emissions were from the cattle, but the rest was from the wetland soils. If the cows are removed, their research shows, it actually increases the amount of methane the wetland ecosystems give off.

Here is part of the explanation provided to Killough by the researchers:

When cattle graze on land, the plants prioritize root growth over the plant matter above the surface. The deeper the roots, the more plants sequester carbon in the soil through the photosynthesis process. Grazing also removes grasses from a pasture, which reduces the dead plant matter that falls to the soil and decomposes, which also produces greenhouse gasses.

That makes perfect sense. And in fact, wasn’t the part about “plant matter that falls to the soil and decomposes” already completely obvious?

Don’t expect the anti-meat activists to back off any time soon. Their real goal is to make your life worse, as punishment for your sins.

The FTC Takes Its Turn To Feel The Regulator's Exhilaration

April 25, 2024/ Francis Menton @ Manhattan Contrarian

 It’s hard to imagine any job more excruciatingly dull than that of the Washington regulator. You beaver away for months on end generating 300 or 500 page documents justifying the latest the latest agency finaglings, all of which text needs to be cleared with scores of co-participants via endless meetings and by repeated circulation of marked-up drafts that draw hundreds of inconsistent edits from self-important functionaries. Ugh!

But then, into this miasma of infinite boredom, from time to time, there intrudes a frisson of great excitement. This happens when the agency decides to seize control and transform a large swath of the economy by its own edict. New people have arrived with a mission to save the world. Ancient statutes are re-analyzed, and vast new powers magically uncovered. The transformative edict goes out. The sense of exhilaration is overwhelming. Finally the evil corporate interests will be brought to heel. Wow, are we important people here! So what if we weren’t elected and have no legislative powers under the Constitution? This project is way too important to yield to such minor quibbles. And anyway, who’s going to stop us?

During the Biden years, most of this regulatory exhilaration has been reserved for the environmental bureaucracies that have been ordering up the transformation of the energy economy. But other bureaucracies are not about to let themselves get relegated to boring irrelevancy. They have a compelling institutional need to seize the moment.

The latest agency to make its grab for the excitement of the limelight is the FTC (Federal Trade Commission). On Tuesday the FTC announced the issuance of a Final Rule to ban what is known as “non-compete” agreements throughout the economy. According to the FTC’s Rule document (which is 570 pages long), the Rule takes effect in 120 days, which would mean August. The Rule does not just ban non-compete agreements going forward, but also purports to make existing non-compete agreements unenforceable, except for those involving a handful of the most senior executives.

Non-compete agreements have been a fixture of the American corporate world for many decades, undoubtedly well more than a century for at least some of them. They are agreements between employer and employee under which the employee agrees not to work for a competitor of the employer upon departure from employment. They come in near infinite variations of terms and conditions, on such things as how long the non-compete restriction persists, whether it only persists as long as the employer is paying severance, the geographic scope of the restriction, and many other things.

Prior to now, non-compete agreements have been heavily regulated, but only at the state level. The large majority of the states allow non-competes in many to most circumstances, but universally there are severe limits on what is allowed. Although many states have statutes regulating some or many aspects of non-competes, most of the rules have been developed via the common law, that is, via case by case adjudication in courts of the reasonableness of different sorts of non-compete agreements in different circumstances. 

This is one of the areas that I practiced in during my legal career, and I know a lot about it. No two states have identical rules, but there are many common themes that run through the approaches taken by the different states. For example, all states that allow non-competes at all place limits of “reasonableness” on the length of non-competes that will be allowed, with maximum allowable periods ranging from as short as a few months to as long as three years in special circumstances (and even unlimited time periods in the case of non-competes associated with sale of a business). 

Shorter allowed periods are the rule for lower-level employees, while longer allowed periods often apply to higher-level employees, particularly when there is compensation that is specifically tied to the non-compete. Some states follow the “blue pencil” rule, where a court that finds a non-compete unreasonable will modify it to be reasonable; while other states follow the rule that any non-compete found unreasonable will be stricken entirely, thus incentivizing employers not to overreach.

A handful of states by statute have disallowed non-competes in all or almost all circumstances. California has had such a rule since 1872 (in other words, it’s not just part of the current progressive craziness). Other states that mostly ban all non-competes include Minnesota, North Dakota, Nebraska and Oklahoma.

So here we have a detailed body of state law, developed over a period of a century and more, with careful consideration by thousands of state legislators and judges of rules appropriate to infinitely varied factual circumstances. And now today, the FTC has decided to step in with its big foot and just outlaw all of it at the federal level.

So what has changed suddenly to make this a matter of urgent federal interest? Perhaps there might be a new statute enacted by Congress?

Not at all. The FTC claims to find its authority for the new Rule in Section 5 of the FTC Act. That statute was enacted in 1914, the time when the agency was created during the administration of Woodrow Wilson. Indeed the creation of the FTC was a signature achievement of Wilson in his effort to “modernize” the federal government to enable replacement of the constitutional balance-of-powers order with rule by “expert” bureaucracies. The wording of the statute has not changed in the intervening 110 years. Here is the relevant text of Section 5:

Unfair methods of competition in or affecting commerce, and unfair or deceptive acts or practices in or affecting commerce, are hereby declared unlawful.

Has anything happened in the last 110 years to make non-competes any more “unfair” than they were back in 1914? Of course not. Indeed, up until now Section 5 has been thought to relate to the FTC’s mission as an enforcer of anti-trust law, rather than granting it infinite authority to micro-manage anything that might be “unfair” in the entire economy. But the current Democratic FTC commissioners, and particularly the Chair (Lina Khan), do not like non-competes and think that they can get away with this gigantic power grab. They claim to rely on some “new research” that, they say, shows that non-competes harm employees throughout the economy, even those not subject to them. Sure. Really, what they want is that regulator’s exhilaration. And they are not going to be denied.

The FTC’s action is on absurdly shaky legal ground. Yesterday — one day after the FTC’s announcement of its Final Rule — business groups including the Chamber of Commerce and the Business Roundtable had already filed lawsuits to have the Rule overturned. I find it hard to believe that the Supreme Court will allow this kind of naked power grab by a regulatory agency, purportedly under a 110 year old statute that doesn’t mention anything about the entire area of law suddenly being pre-empted. 

But while we wait a few years for the case to reach that forum, there are tens of thousands of businesses that have negotiated and paid for non-competes that are suddenly illegal, at least for now; and the FTC will have the sadistic fun of watching those businesses squirm. It can be so much fun to be a regulator. When the Rule gets overturned a few years from now, no FTC commissioner or other employee involved in this gambit will face any consequences.

Meanwhile, not to be outdone, the environmental regulators are out showing the pipsqueak FTC who the real big fish are in this pond. Just today, EPA finalized a rule requiring coal power plants to cut emissions by 90% by 2039 or else close. That could only conceivably be done with carbon capture technology that does not exist today in any form that can be deployed economically. And yesterday, the White House announced a national goal to cut emissions from freight shipping down to zero by 2050. Electrify all trucks, freight trains, and ocean shipping — nothing to it! It’s complete fantasy, but oh what exhilaration you can feel as a regulator announcing such edicts.

Comments From Supporters Of EPA's New Power Plant Rule

August 14, 2023 Francis Menton @ Manhattan Contrarian  

My last post highlighted two lengthy comments submitted to EPA by groups of states critical of the agency’s recently-proposed “Power Plant Rule.” (EPA’s official title: “New Source Performance Standards for GHG Emissions from New and Reconstructed EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean Energy Rule.” ). The Rule seeks to eliminate, or nearly so, all greenhouse gas emissions from electric power plants, by some time in the 2030s. The comments that I highlighted delve into substantial technical detail, giving serious reasons why EPA’s proposed transformation of the country’s electricity generation system is unlikely to work and poses severe risks to the people’s electricity supply.

What about on the other side? Are there any comments on the proposed Rule that are supportive of the Rule, and that even contend that its restrictions on use of fossil fuels to generate electricity should be made more stringent, and/or advanced in time? The answer is that there are many such comments.

But how do these supportive comments deal with the problems identified in the critical comments? What do they say about risks to the reliability of electricity supply, or about the potential for greatly increased costs? The answer, as far as I can determine, is that they can’t be bothered addressing such issues.

I’ll freely admit that I haven’t attempted to read all the comments, of which there are now some 618. Rather, I have sought out a few from groups that appeared likely to be supportive of the Rule. So here are three such comments: one from something calling itself the U.S. Healthcare Climate Council; a second from the American College of Obstetricians and Gynecologists; and a third from a consortium of healthcare groups in Wisconsin described as “American Academy of Pediatrics - Wisconsin Chapter, Cream City Medical Society, Healthy Climate Wisconsin, et al.”

The “U.S. Healthcare Climate Council” may sound like some sort of official body, but as far as I can determine it is just a lobbying group based outside of D.C. that uses the cover of “healthcare” to push for elimination of fossil fuels. (Here is their website if you want to investigate further.). Here is their position on the proposed Rule:

We strongly support the EPA using their authority in sections 111(b) and (d) of the Clean Air Act to set these new pollution standards that would require fossil fuel power plants to reduce their GHG emissions for the first time and recommend that the standards be as strong as possible to protect human health and prevent the worst climate change impacts from occurring.

(Bold is in the original.). So what are the “climate change impacts on human health” they are talking about? There’s this:

A strong limit on power plant carbon pollution would also protect those patients who are most vulnerable, including children, older adults, those with health conditions, and people with lower incomes and communities of color who feel the health harms of climate change soonest and most intensely.

How exactly does that work? They don’t say. Hey, everybody know it. Read on and you come to this:

The proposed rules would result in up to $85 billion in net climate and health benefits, while preventing 1,300 premature deaths and over 300,000 cases of asthma attacks by 2030.

And what is the source? The link goes to EPA’s own “fact sheet” on the proposed Rule! As far as I can determine, the numbers are completely made up by government advocates, and certainly the “U.S. Healthcare Climate Council” has not checked them in any way. Since when does CO2 cause asthma? Hey, EPA says it, so it must be true.

And how about the issue of whether the emissions reduction goals are achievable on the stated timescale? These guys don’t deal with that, but that doesn’t stop them from advocating for shorter deadlines and more stringent requirements in every respect: 

“Increase the number of gas plants covered by the rule. . . . Move up compliance timelines so that power plants must reduce their emissions this decade. . . .”

As to the American College of Obstetricians and Gynecologists, you might wonder what expertise they have in anything related to climate change or how electricity is generated. The answer is that they have none, but that doesn’t keep them from showing their virtue here. Here’s their statement of why they are commenting:

As climate change continues to adversely affect the well-being of women, people seeking obstetric and gynecologic care, families, and communities, ACOG supports greater recognition of and investment into addressing the effects of the environment on public health. Specifically, ACOG in its position statement [c]alls on our national and international leaders to act to curb greenhouse gas emissions and limit further climate destabilization. . . . Greenhouse gas emissions accelerate climate change, which poses a serious threat to American’s health and well-being. . . .

Do they have any proof of this made-up nonsense?

In 2030 alone, nationwide the proposed standards would prevent: approximately 1,300 premature deaths; . . . more than 300,000 cases of asthma attacks. . . .

It’s the exact same bullshit projections cribbed from EPA’s own “fact sheet” and parroted back to them with no independent thought or research. And in conclusion:

Rapid emissions reductions are therefore required to limit damage to global ecosystems which provide essential services necessary for human wellbeing and societal stability.

I like the “therefore” in that sentence. No support for the proposition was provided in anything that preceded it.

And finally for today we have the comment from a large coalition of environmental and health groups from Wisconsin, which include Evergreen Action, Healthy Climate Wisconsin, Green Neighbor Challenge, the Wisconsin Chapter of the American Academy of Pediatrics, and many more. The gist:

[O]ur organizations urge the EPA to set the strongest possible safeguards on carbon pollution by early next year. While the agency’s current proposal is a good start, we ask the EPA to strengthen it in three ways: 1) require power plants to reduce their emissions more quickly, 2) apply the pollution safeguards to a wider number of gas plants, and 3) ensure communities have input on how the pollution safeguards are implemented at power plants.

And get ready for the health impacts of climate change:

Carbon pollution from the fossil-fuel industry drives climate change and leads to poor air quality and increasingly negative health outcomes, including respiratory disease, heart disease, and insect-borne infectious diseases.1 According to the National Institute of Environmental Health Sciences, poor air quality as a result of climate change can harm respiratory and cardiovascular systems. These health impacts include hypertension, coronary artery disease, heart attack, and stroke.2

And where does any of that come from? Footnote 1 goes to yet another EPA self-serving advocacy piece, “Climate and Human Health.” Footnote 2 goes to a similar piece from NIH.

Now, I don’t wish anybody a premature death, but this advocacy has completely lost its way. EPA has somehow ginned up a number of 1300 premature deaths per year that it thinks it can prevent by shutting down an electricity generation system that works and replacing it with something that has not been demonstrated to work or even been subject to a feasibility study. Last year there were 3,274,000 deaths in the U.S., so 1300 would be 0.04%, and they would appear to be counted by EPA even if the death is premature by only one day. How EPA knows that an imperceptible change in temperature could cause these deaths is an excellent question.

Meanwhile, what about the benefits of a reliable electricity supply? Is it really possible that we so completely take that for granted, like it’s just a fact of life? If we suddenly start having blackouts that last for weeks or months, how many people are then going to die prematurely? Hundreds of thousands per year, that’s how many.

 

Comments On The Insanity Of EPA's New Power Plant Rule

August 11, 2023 Francis Menton @ Manhattan Contrarian 

On May 23, EPA put out its long-expected proposed Rule designed to eliminate, or nearly so, all so-called “greenhouse gas” emissions from the electricity-generation sector of the economy.  The proposal came with the very long title: “New Source Performance Standards for GHG Emissions from New and Reconstructed EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean Energy Rule.”  The full document is 672 pages long.   

Various not-very-far-off deadlines are set, ranging from as early as 2030 for some changes to coal plants, to at the latest 2038 for the last changes to natural gas plants.  But how exactly is this emissions elimination thing to be accomplished?  Today a substantial majority of U.S. electricity (about 60%) comes from one or the other of those fuels; and it is inherent in the burning of hydrocarbons that you get CO2 as a product.  In all those 672 pages, EPA has only two ideas for how to eliminate the carbon emissions from combustion power plants: carbon capture and storage (CCS), and “green” hydrogen.  Either you must implement one of those two ideas to meet EPA’s standards by the deadline, or you must close your power plant.  But here’s the problem: both of those ideas are, frankly, absurd.   

The deadline for commenting on the proposed Rule was August 8, although comments have continued to pile in after that date.  Many hundreds of them have been received.  If you have nothing else to do for the next month or two, you can review the comments at this link. 

I have by no means made the effort to read all the comments, but I have gone looking for some of the more significant ones.  Two that I can highly recommend are this one by a group of 21 red state AGs led by West Virginia, and this one by an overlapping group of 18 red state AGs led by Ohio.  Both of those comments do an excellent job of dismantling the concept that either CCS or “green” hydrogen could ever work as a significant part of our electricity generation system.  Of the two, the West Virginia comment is the much longer (54 pages) and goes into far more technical detail.  But the Ohio comment, at 21 pages, has its share of good zingers as well.

The Ohio and West Virginia comments label the idea of CCS at the high rate demanded by EPA (90%) as either “infeasible” or not “viable,” and include recitations of the history of failed attempts to implement this frankly useless technology.  From the Ohio comment (page 4):

A study of 263 carbon-capture-and-sequestration projects undertaken between 1995 and 2018 found that the majority failed and 78% of the largest projects were cancelled or put on hold.  After the study was published in May 2021, the only other coal plant with a carbon-capture-and-sequestration attachment in the world, Petra Nova, shuttered after facing 367 outages in its three years of operation.

With the closure of Petra Nova, there remains in the entire world exactly one operating commercial CCS facility at a coal power station, the SaskPower Boundary Dam Unit 3 in Saskatchewan, Canada.  That one is supposed to achieve the 90% capture rate that EPA demands, but with constant operating issues it has fallen way, way short:

[T]his [SaskPower] facility is the world’s only operating commercial carbon capture facility at a coal-fired power plant.   And it has never achieved its maximum capacity.  It also battled significant technical issues throughout 2021—to the point that the plant idled the equipment for weeks at a time.  As a result, the plant achieved less than 37% carbon capture that year despite having an official target of 90% . . . . 

The West Virginia comment provides lots more technical detail on the failures of CCS. Why can’t a CCS system just easily suck up all the CO2 out of a power plant’s emissions stream? Because the effort to suck up the emissions takes energy from the output of the plant, and the higher the percentage of carbon emissions you seek to capture, the more of the energy output of the plant you consume. (I have previously described CCS efforts as a “war against the second law of thermodynamics.”). In the limiting case, you can use up all the power output of the plant on the CCS system and still not capture 100% of the CO2. From the West Virginia comment, page 24-25:

Take efficiency to start. CCS units run on power, too. An owner can get that power from the plant itself. But this approach makes the plant less efficient by increasing its “parasitic load”—and CCS more than triples combustion turbines’ normal parasitic load. . . . This is the cause the Wyoming study analyzed that showed installing CCS technology would devastate plants’ heat rates and lower net plant efficiency by 36%.

And that percentage relates to a system that captures well less than 100% of the plant’s carbon emissions. And these are only the start of the technical issues to be faced. For example, once you have captured all this CO2, where do you put it? Do you build an entire new national network of pipelines (at a cost of hundreds of billions of dollars) to transport it to some underground caverns somewhere? And then, are there environmental issues with the chemicals used to snag the CO2 out of the power plant’s emissions stream? From the West Virginia comment, page 27:

The Proposed Rule would force utilities to adopt and communities to accept all aspects of CCS technology without fully understanding the ramifications. For example, the environmental and health effects of CANSOLV—the leading amine-based and EPA-recommended CCS solvent, 88 Fed. Reg. at 33,291—appear unknown; leading CANSOLV studies over the past decade don’t discuss its impact.

And then, if you have to increase the power output of the plant by 50% or so to power the CCS facility, doesn’t that then increase the emissions of nitrous oxides and particulates by a comparable amount? From the West Virginia comment, page 27:

Nearly a decade ago, the European Union’s European Environmental Agency released a study finding that CCS would increase “direct emissions of NOx and PM” by nearly a half and a third, respectively, because of additional fuel burned, and increase “direct NH3 emissions” “significantly” because of “the assumed degradation of the amine-based solvent.”

It goes on and on from there. And then there’s the idea of “co-firing” the power plants with “green” hydrogen, produced by using wind or solar power or something else magical to electrolyze water. EPA’s proposed Rule would impose such a requirement on existing natural gas plants to take them up to 96% hydrogen by 2038. A few insights from the West Virginia comment, page 35:

Most combustion turbines on the market today cannot handle anything more than a 5-10% blend [of hydrogen]; 20% is generally accepted as the absolute technological ceiling. . . . Even in the best scenarios, a hydrogen volume fraction of 20% is usually the most technology currently can do.

And how about the problem (and cost) of producing the amounts of hydrogen that would be required. From the West Virginia comment, page 37:

America currently produces just .5% of the clean hydrogen we need under the Proposed Rule. The industry would have to close a 99.5% supply gap in just 15 years. EPA has offered no evidence showing that this gap will close.

There is much, much more on issues like transporting and handling the hydrogen, cost of production, and so forth.

The conclusion is obvious and impossible to escape: These proposed methods to allow combustion power plants to continue to exist are not real and can never work. EPA intends to force the closure of all such electricity generation facilities. Will we have an electricity system that can still function at that point? They neither know nor care. After all, we have a planet to save here.

Somehow, in the weighing of the costs and benefits here, the bureaucrats appear to have completely lost track of the enormous benefits that reliable access to electricity has brought to the people. They will destroy that without giving the subject a second thought.

CFACT to American Cancer Society: Reject EPA’s politicized emissions standards

By Craig Rucker August 8th, 2023

Mr. Brian A. Marlow, CFA

Chairman, Board of Directors

American Cancer Society

3380 Chastain Meadows Pkwy NW, Suite 200

Kennesaw, GA 30144

Re: ACS and EPA misuse CPS II to claim deaths from PM2.5

Dear Mr. Marlow,

With headquarters in Washington, DC, the Committee For A Constructive Tomorrow (CFACT) is a 501(c)(3) national and international environmental and educational organization dedicated to protecting both wildlife and ecological values and the health, nutrition, energy needs and living standards of people, families and communities. CFACT is also committed to evidence-based decisions, policies and programs that are guided by the best possible scientific data and analyses.

We are deeply concerned about the American Cancer Society’s support for the current Environmental Protection Agency (EPA) plan to further tighten the PM2.5 National Ambient Air Quality Standard (NAAQS) for particulate matter, which has been based largely on findings from the Society’s 1982 Cancer Prevention Study (CPS II).

CFACT respectfully requests that ACS scientists Dr. Karen Knudsen, Dr. Alpa Patel, and Mr. Ryan Diver meet with environmental epidemiologist Dr. James E. Enstrom as soon as possible to discuss his CPS II findings, along with further concerns that we summarize below.

We understand that ACS scientists have rejected Dr. Enstrom’s repeated requests to meet with him regarding his peer-reviewed evidence of serious errors by ACS scientists in their analyses of CPS II data that attempt to link air pollution to mortality. The Society’s CPS II analysis found a positive relationship between mortality and PM2.5 emissions – and EPA utilized this relationship to help justify its initial NAAQS for PM2.5 in 1997.

Subsequently, the Obama EPA based parts of its Clean Power Plan on significant errors and misstatements about air quality, especially PM2.5 emissions. The Biden Administration and EPA are doing likewise, often citing CPS II and similar analyses to justify even tighter PM2.5 standards, as part of their ongoing efforts to close the nation’s coal-fired power plants, and even eliminate natural gas use.

Those errors are exemplified by testimony to congressional committees by former EPA Administrator Gina McCarthy and other EPA witnesses. Ms. McCarthy asserted that there is no threshold below which there is no risk, no level “at which premature mortality effects do not occur.” That is simply false.

In reality, cigarettes quickly send hundreds of times more tiny PM2.5 particles into a smoker’s lungs than what the EPA says is lethal if they come from coal-fired power plants. Cigarettes certainly pose cancer and other risks, but millions are not dying from inhaling PM2.5 particles.

Equally damaging to EPA (and ACS) assertions, Agency-funded experiments on human test subjects administered PM2.5 particles to dozens of people – including elderly, asthmatic and diabetic subjects, people with heart disease and children who EPA says are most at risk from PM2.5 particles. Those experiments exposed these test subjects to thirty or even sixty times more PM2.5 particles per volume than what the EPA claims are dangerous or lethal – and did so for up to two hours. And yet, contrary to EPA and Ms. McCarthy’s claims, no one died or even got sick from those exposures.

This underscores how false and misleading EPA claims have consistently been about the “serious risks” from coal-based electricity and other sources of PM2.5 particles. And yet the agency has repeatedly used such claims to justify tightening its NAAQS restrictions.

In summary, there is strong evidence that the PM2.5 standards cannot be justified on scientific, economic, or human health grounds; that EPA’s current PM2.5 regulations have had adverse economic, energy reliability and health impacts on American families, industries, and businesses; and that EPA’s asserted benefits from PM2.5 restrictions are illusory or heavily offset by such adverse consequences.

And yet, ACS scientists have failed to discuss or address the strong evidence contained in Dr. Enstrom’s February 16, 2003 letter to ACS scientists: “ACS & EPA Misuse CPS II to Claim PM2.5 Deaths”.  Dr. Enstrom clearly described this evidence in his July 8, 2023 Talk “Corruption of Science by the American Cancer Society” at the Doctors for Disaster Preparedness Meeting in Tucson, Arizona, which CFACT experts attended.

This is an urgent matter, because EPA is once again using seriously flawed epidemiologic findings in its latest efforts to further lower the already too-low PM2.5 NAAQS. Evidence by Dr. Enstrom and studies by other experts demonstrate that there is no factual or scientific justification for this.

If the ACS scientists cannot meet with Dr. Enstrom, then we request that you speak with me or CO2 Coalition Executive Director Gregory Wrightstone about the importance of honest, reproducible science to our nation’s affordable, reliable energy; the jobs, economic wellbeing and overall health of America’s workers and families; and indeed the continued credibility of ACS epidemiologic research.

Mr. Wrightstone has already written to the Society. His March 31, 2023 CO2 Coalition Letter to ACS can be found here:  CFACT supports his analysis and hopes the ACS recognizes the importance of the issues we both raise.

Thank you very much for considering this request.

Sincerely yours,

Craig Rucker

President

50 is the New 70 degrees Fahrenheit

April 9, 2023  By Mark C. Ross  

Gee, record snowfall practically everywhere.  Many have been enduring well-below-normal spring temperatures.  When is that atmospheric heat-trapping going to kick in?  If I had mastered Photoshop, I'd have put together a picture of Al Gore driving a snow plow...with palm trees in the background.  But reality is disturbing enough.

Many reporters covering the ongoing devastation being wrought by tornadoes bend over backwards to tie the phenomenon to global warming.  It so happens that this is tornado season — when cold Arctic air masses collide with warm, moist air masses coming up from the Gulf of Mexico.  The death and destruction on the ground is happening because of where the twisters touch down, which is a largely chaotic process.

H.L. Mencken is credited for saying, "Nobody ever went broke by underestimating the intelligence of the American public."  Until I looked this up, I thought it was P.T. Barnum.  Careful research, don't you know................To Read More..... 

Opportunity in the face of tyranny April 11, 2023 We're living in a new America. The fraudulent indictment of former president Donald Trump underscores the truth that the swamp no longer hides its hostile motives or pretends to favor the rule of law and the Constitution over tyranny.  Since Joe Biden entered the Oval Office, the socialist far-left Democrats have openly attacked American values and societal norms. Under the guise of saving the planet, a false religion was created that would use the vitality of impressionable youth to divide the nation — sons against their fathers and brother against brother.

From the corrupt editorial pages of their dishonest newsprint bibles, the Democrat left preached the fallacy that man is the destroyer of the planet, which is to be worshiped as some deity.  And that radical energy measures that produce pain, poverty, and death to third-world populations, not to mention the economic collapse of the United States, are the repentant price for past climate offenses.

Young Americans were taught that there was no sacrifice too great to be paid by the unwashed.  Still, they were not told that such economic and physical calamities were not to be encountered by the Democrat priests and priestesses of the false climate theology...............

Joe Biden's King Canute Environmentalism - Are we watching a replay of King Canute commanding the waves to recede? That thought occurred to me while reading about the Biden administration's latest step in advancing the president's 2021 goal of having half of all new autos be electric by 2030. The analogy isn't exact -- current thinking is that Canute knew his courtiers were wrong when they said he could stop the incoming tide. And the king was apparently in his 30s, with no sign of cognitive impairment, at that moment by the seashore. But consider it anyway. The analogy was prompted by the Environmental Protection Agency's order last week regulating tailpipe carbon dioxide emissions of model year 2027 to 2032 cars, SUVs and pickup trucks. It was clearly intended to force automakers to produce electric vehicles so that they'd account for two-thirds of sales in 2032 -- roughly 10 times the 6% share they accounted for in 2022.................

 

America's Coming Energy Crisis

April 15, 2023 By John Kudla

President Joe Biden and the apocalyptic climate cult within the Democrat party believe that climate change is the greatest threat to the country.  That's right, the greatest threat is not nuclear war, not unlimited unlawful immigration, not inflation, or out-of-control spending.  Instead, it's the slow warming of the atmosphere, which they believe is caused solely by burning fossil fuels.

In 2021, Biden signed an executive order that decreed that all federal contracts for goods and services to be carbon-neutral by 2050.  Some states and businesses are following Biden's lead.  California and six other states intend to ban the sale of gasoline-powered vehicles by 2035.  California also wants to ban the sale of gas-powered water heaters and furnaces by 2030.  Now the Environmental Protection Agency has piled on.  The agency is proposing vehicle pollution limits for 2032 that are so strict that they will force roughly two thirds of new vehicles sold to be electric................To Read More....

NYC Hates Its Middle Class Homeowners

October 28, 2022/ Jane Menton @ Manhattan Contrarian

Four years ago, just before our son was born, my husband and I bought our first home: a two bedroom, one bathroom apartment in Queens. 

Queens has a lot to recommend it; it is often known as the City’s “middle class” borough, with almost no slums, and an equivalent lack of notable wealth. It is not a small area: more than 100 square miles, with a population over 2.25 million. The homeownership rate is about 45%, which is high for New York City. In addition, it is the most ethnically diverse county in the U.S., and a place where immigrants from all over the world have sought the American dream. Unfortunately, our politicians are working hard to put an end to that. 

About a year ago I joined the board of my building, a nondescript co-op which has about 160 apartments. Within my first month of joining a senior board member, one who has been on the board for many years and is about 20 years my senior, sent us all the following email: 

“I just wanted to bring this topic to your attention… The Climate Mobilization Act of 2019 will have a big impact on our building. Our emissions must be cut by 60% in the next 10 years or so. If we fail, the fines are in the range of $150k a year. We will be required to make hundreds of thousands of dollars in investments to upgrade our systems.” 

For reference, this act, the Climate Mobilization Act, is a New York City statute also known by the name Local Law 97 (LL97).

Since I am the daughter of the MC, I was already familiar in a general way with this New York City law, and with the similar law at the state level known as the Climate Leadership and Community Protection Act, also passed in 2019. But our senior board member’s email brought home the particular financial consequences that our building – and hundreds of others like it – would shortly be facing.

My colleague’s email was accompanied by the following chart, created by this website, called the NYC LL97 Carbon Emissions Calculator. This site has been endorsed by the City for buildings to use to calculate how much they are supposed to reduce their carbon emissions and how much they will owe in fines if they fail to install “zero-emissions” heating systems by the set deadlines. Here is the chart that my colleague came up with for our building:

Editor's Note: I can't properly reproduce the image of the chart, so please go to the original article. RK 

According to the chart, about 75% of our carbon emissions result from our natural gas heat, represented in green in the circles in the lower right portion of the chart.  The City’s statute mandates a series of lowering thresholds for building emission per square foot of space. By 2035, supposedly we must reduce our emissions by 60%, or face fines well in excess of $100,000 per year. In order to reduce our emissions by 60% we would have no option but to convert our building away from its current gas heat system – which is quite reliable, only a few years old, and in fine working condition – to an electric heating system.  

In addition to the lowering emissions mandates, the City statute also prohibits new natural gas hookups in new buildings under 7 stories starting in 2024, and buildings over 7 stories starting in 2027.   

Policy makers busily writing these edicts have yet to figure out how NYC’s electric grid could support such a transition. Spoiler alert: it cannot.  They push ahead even as California begins to realize the folly of requiring everyone to buy an electric car. Supposedly New York is going to triple the load on the electrical grid by forcing the electrification of all buildings and automobiles, while also closing reliable fossil fuel power plants and trying to replace them with wind and solar facilities that only work part time. Meanwhile, they have made no effort to demonstrate how this could possibly work. See prior Manhattan Contrarian discussion, for example here. Beyond being a financial burden on New York’s middle class, there are serious quality of life concerns to consider.

Assuming that they decide to or are forced to go along with this, how much will it cost the unfortunate co-op owners? We haven’t yet had an estimate done for our building, but here are a few words from Warren Schreiber, board president of another Queens co-op, the Bay Terrace Gardens Co-op Section 1, and co-president of the Presidents Co-op & Condo Council (PCCC):

“Converting to (electric) heat pumps will cost [the co-op] $2.5 to $3 million, which does not include finance charges. This expense will result in a 25-30% monthly maintenance increase. Shareholders who have lived here for 20, 30, 40 and 50 years will have to leave Bay Terrace Gardens to find more affordable housing.”

A 25-30% maintenance increase is significant. In my building, we just had a relatively minor maintenance assessment due to rising gas prices. The total was $45,000, spread over 160 apartments, to be paid over the course of three months. We announced this at the annual shareholder meeting in September. During the meeting, our accountant also briefed everyone on the other things that were likely to affect our building finances, including: rising cost of labor, rising property taxes, and inflation.

“This meeting is a call to action to vote Republican” I texted my friend on the board. 

She replied: “Yep.”

After the meeting, a shareholder came up to me to complain about the assessment. 

“If you are going to have a maintenance assessment, you really need to give tenants more warning. It's too expensive. It’s an increase of $88 a month for me.” 

In our building, $100 a month is not money most residents won’t miss. Knowing that, I seized the opportunity to warn this resident about the Climate Mobilization Act and the much higher costs NYC plans to impose on us. 

“But that’s crazy! They can’t do that — it would ruin the city! You know, this is the Republicans’ fault and the Democrats are too cowardly to stand up to them.” 

How anyone could believe that when our city is under exclusive control by the Democratic Party, and the “Green New Deal” has been entirely championed and sponsored by Democrats, is beyond me. But that’s the NYC mindset for you. Even as the costs of policies championed by Democrats begin to hit home, there is acute denial over who’s to blame.

I am trying to take productive action. I wrote the following to my fellow board members: 

“My primary concern in all this is that it seems clear the city wants to push us to convert to electric heat. The cost to retrofit such a system to our building would be astronomical, not to mention that the cost per resident for electric heat would be a significant personal expense. Further, if hundreds of NYC buildings were to suddenly depend on electric heat, I have no faith in the city grid to rise to that level of demand. The cascading negative consequences of imposing this on NYC co-op owners are immense. I’m seeing a housing market crash and financial ruin for middle class citizens (as evidence, see: Europe). What can we realistically do to push back?”

I haven’t heard back from them yet. I’ll let you know if I do.

In the meantime, there are several co-ops in the city who understand what’s at stake. They have mounted a legal challenge against the law. I hope to join them.

FRANCIS MENTON adds: 

The costs of installing and running an electric heat system are actually the smaller part of the problem. The much bigger issue is that the City has embarked on forcing all buildings (and separately, all automobiles) to convert to electricity without any sort of realistic plan of how to provide the necessary electricity. 

My recommendation to Jane and her Board is that they get together with several other co-ops in Queens and call a meeting with their State and City representatives where they say: “We can’t responsibly convert our buildings to electric heat until you can demonstrate a workable system to provide the electricity without blackouts. Otherwise we risk having our owners freeze to death in the winter. And if you persist in this, we will tell our shareholders that this is on you, and advise them that they must vote you out of office to avoid disaster.” 

And meanwhile, the last thing Jane’s building should do is actually invest anything toward converting to electric heat. This whole mania will be long forgotten before these supposed fines kick in for them some time after 2030.

 

Biden EPA Chief Vows to Ignore Supreme Court on EPA Regulation of Coal Plants

By Steve Milloy From JunkScience

What an actual threat to our democracy looks like. EPA has no statutory authority to regulate greenhouse gas emissions from coal plants.  Although the Supreme Court is taking up the question on Feb. 28, the Biden regime doesn’t care what the Court holds. It plans to aggressively regulate emissions from coal plants anyway. As reported by Politico’s “Morning Energy” report today:

 

Pollution Is Many Things; Cause of Death Isn't One of Them

By Julianna LeMieux

A new economic claim from the American Lung Association of California regarding Zero Emission Vehicles and their potential health benefits has us all living in an episode of The Oprah Winfrey Show.

But, their statement goes way beyond,"You get a car, you get a car, you get a car!"  Their analysis postulates that a big push in the usage of Zero Emission Vehicles (ZEVs) will allow Americans to save billions of dollars in health costs each year, along with thousands of lives. Unfortunately, that's a promise not even Oprah could make happen.

A Zero Emission Vehicle is a vehicle that directly produces no harmful emissions - some don't even have a tailpipe. There are currently two categories of zero emission vehicles: 1) battery powered electric cars that recharge when plugged in and 2) hydrogen fuel cell models that are powered by a chemical reaction. This latter category is not only very rare, but, it is hotly contested whether these ZEVs are better for the environment than the cars that we drive now. They have to convert a hydrocarbon fuel (natural gas or gasoline) into hydrogen - which uses substantial energy and emits greenhouse gases.......To Read More......

EPA Goes Ape Over Power Plant Emissions

Everything we are told should bear some resemblance to what we see going on in reality.  I wish to thank Alan for allowing me to re-publish his work.  Alan blogs daily at Warning Signs, a site worth visiting daily.  RK

By Alan Caruba

Not a day goes by without our being told that something is going to kill us. Much of what kills people is genetic; little time bombs in our DNA that determine the state of our health.

Anyone who reads the daily obituaries knows that Americans are living longer than any previous generation. Most of the population is dying of nothing more sinister than old age.

The diseases that kill Americans have been quantified and known for decades. At the top of the list is heart disease, followed by a variety of different kinds of cancers. Third in line are strokes. Chronic lower respiratory diseases such as asthma are next, but nothing more than accidents kill as many people.

The remaining factors include diabetes, Alzheimer’s, pneumonia, nephritis (kidney diseases), and septicemia, a disease of the blood.

What do Americans really die from? Genetic dispositions to illness. Accidents. Poor diets. And bad lifestyle choices that include smoking, drinking, and taking illegal drugs.

With the exception of asthma that affects about seven percent of the population none of this has anything to do with air quality. Indeed, the causes of asthma remain somewhat shrouded in mystery even if the symptoms do not.

None of this empirical knowledge and data has the slightest effect, however, on the Environmental Protection Agency (EPA) and the American Lung Association that profits greatly from any claims about air quality. Both are inclined to making wild claims.

In early July, the EPA announced proposed cuts in “pollution from power plants in 31 states and D.C.” This is not about air quality. It is part of the long-term attack on all sources of power in America, but most particularly the coal-fired plants that provide just over fifty percent of all the electricity on which Americans depend for everything!

Depriving Americans of electricity would trigger a tsunami of deaths in the form of heat stroke in the summer months or freezing in the cold of winter. That, however, is the actual objective of the EPA and the many environmental organizations that wage ceaseless propaganda campaigns and endless law suits whose sole purpose is to deprive Americans of this vital source of power.

The EPA claims that infinitesimal particulates from power plant emissions, specifically sulfur dioxide (SO2) and nitrogen oxides (NOx) “harms the health of people “living downwind” of power plants. They propose reducing such emissions by 71 percent over 2005 levels of SO2 and fifty-two percent of NOx.

This is in line with the crazed and fraudulent claim that carbon dioxide (CO2) is causing global warming and thus requires the huge tax on energy sources, the Cap-and-Trade Act making its way through Congress.

The claims are the typical exaggerations of all proposed government regulations. The EPA claims that their latest action would yield “more than $120 billion in annual health benefits in 2014, including avoiding an estimated 14,000 to 36,000 premature deaths, 23,000 nonfatal heart attacks, 21,000 cases of acute bronchitis, 240,000 aggravated asthma, and 1.9 million days when people miss school or work due to ozone-and-particle pollution-related symptoms.”

There’s a very impolite word to describe these kinds of statistics.

They are the same kind of statistics the Obama administration has been conjuring while it blew through a trillion dollar “stimulus” program with no real effect on the economy. These are the same kind of vacuous statistics behind the promise of new jobs, the takeover of healthcare, one-sixth of the nation’s economy, the takeover of the auto industry, et cetera!

Everyone wants clean air. The effort to achieve it began over three decades ago and it has been a success at the same time the U.S. gross domestic product increased 156 percent, vehicle miles traveled increased 143 percent, energy consumption increased 45 percent, and the population increased 36 percent.

Cracking down on coal-fired plants is a political act. It has no relation whatever to any need to reduce particulates for the general population.

When the American Lung Association talks of preventing “tens of thousands of premature deaths each year” it is engaged in the worst kind of exaggeration and fear-mongering.

Because Americans are rightly concerned with issues involving jobs, mortgages, auto payments, and all the real threats to their well-being, the EPA knows it can sneak through draconian regulations that, in normal times, would be and should be stopped in their tracks.

The EPA and environmental organizations are the enemy of economic recovery. They are the true cancer on the body politic.

Comments will not be accepted that are rude, crude, stupid or smarmy. Nor will I allow ad hominem attacks or comments from anyone who is "Anonymous”.

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