COMMENT BY:
Herman A. (Alex) Pope
Pope's Climate Theory
Houston, Texas
on the
EPA Proposed Rule
Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units

Submitted
Dec 1, 2014

Docket ID:  EPA-HQ-OAR-2013-0602

Agency:  Environmental Protection Agency (EPA)

Due Date: Dec 1, 2014
Recommendation:
The current Social Cost of Carbon (SCC) calculations that the EPA uses for estimated costs and benefits of this proposed rule, as described in footnote (12) of the proposed rule and required by E.O. 12866.  The calculations are based on output from un-validated Models. All actions related to the regulation of CO2 should be delayed until the calculations can be accomplished with actual data or validated models.

Comment:
Polar Ice Cycles and Earth Temperature Regulation

On Earth, Water, in all of its states does regulate the temperature.

The temperature that Polar Sea Ice melts and freezes does not change.  When the oceans are warm and the Polar Sea Ice is thawed, the snowfall is always turned on until cooling occurs. This now takes a few hundred years.  When the oceans are cold and the Polar Sea Ice is frozen, the snowfall is always turned off until warming occurs. This takes a few hundred years.

There was the Roman warm period, a cold period followed, the Medieval warm Period followed, the Little Ice Age followed, this Modern Warm period followed. Next, a cold period will follow. The temperature now goes up and down across this set point. This set point does not change due to changes in the sun or the orbit or tilt of the Earth or CO2.

Look at the temperature history of earth and look at the development of the Polar Ice and the Polar Ice Cycles.

To take us out of the cycles of the past ten thousand years, you must stop the Polar Ice Cycle. The thermostat in your house turns cooling on and keeps it on as long as necessary to lower temperature below the set point. The sun is always on and warms your house until the cooling comes on.

Look at this wonderful temperature record. You can watch the temperature signature change as the ocean circulation and polar ice cycles change. 

A scientist on our climate study team sent this chart with five hundred million years of temperature data.  The scale changes as you go from millions of years ago to the most recent ten thousand years. 

His reference is: Sturgis Hooper, Nov. 4, 2014

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To get temperature to behave like this, you must have a thermostat and cooling that can be turned on and off.  The sun is always on and always provides the warming. The snowfall is turned on when needed and stays on as long as necessary. IR does most of the cooling, but it does not have a thermostat for the fine control.  The bounds of the last ten thousand years cannot be explained without a set point and powerful cooling that can be turned on and off as needed. The changes to the temperature cycle cannot be explained without understanding how the ocean circulation changed and how the Polar Ice Cycles changed.  

I challenge any of you to explain this changing temperature cycle with any other Theory.

For ten thousand years every warming has been reversed, every cooling has been reversed, in the same bounds.  This cannot be done with external forcing with no temperature measurement and feedback.  This can only be done if the system has an internal natural cycle with a thermostat and powerful forcing that is turned on and off as needed.

CO2 is not any kind of pollution: 

CO2 makes green things grow better while using less water.  The food supply for the world has increased and much of the improvement is due to the increased CO2.   Any war against increased CO2, or any war to reduce CO2, is a war against People and all Life on Earth that depends on Green Things that Grow. 

Herman A. (Alex) Pope
Retired Aerospace Engineer
MSC  - Manned Spacecraft Center (1963)
BS Engineering Mechanics VPI/Virginia Tech 1967
NASA - Johnson Space Center (to 2007)
From this thread on wattsupwiththat - Click here