I have a particular interest in this because my papers are included. In the response, various comments are referred to by their submission numbers - mine are 10071, 10071.1, 10071.2, 10071.3, 10071.4. Unfortunately, there does not appear that there is a way to search the site for responses to a specific public comment. As a result, it was necessary to open and search each volume. Out of 11 volumes (pdf files), when searching for 10071, I was able to find only the 4 entries below. This is unfortunate since I was hoping to get a comment on my paper (10071.3) which presents an alternate understanding of the function of Greenhouse gases.

Note: I found out about the EPA responses through a link on climateaudit.org (posted on Jan 30, 2010).

Comment (1-62): A number of commenters (0289, 3332.1, 3394.1, 3415.1, 3509.1, 3577.1, 3747.1, 7029, 10345, 10524, 10956, 11358.1, and 11466.1) argue that EPA did not make publically available the data, models, and other relevant information used in the studies upon which the endangerment determination was made. Several commenters (3577.1, 3747.1, and 10071.2) state that nearly half of the studies on which EPA relies for the Proposed Findings are unavailable in the docket due to copyright issues.

Make important references free to the public Point 2 - Price to read the articles I have tried to do a lot of research on Global Warming and the related physics. However, many articles are not available to me because they cost $40 to $70 each to read them. Before the EPA makes a decision, I request that full text copies of all related documents be made freely available to the public. Having to pay $40 or $70 to read the each journal article that the EPA decision is based on is not in the public's interest.

This is a summary of their response.

[From a previous court ruling - the] EPA is not required to obtain and publicize the data underlying all the studies on which they rely. Given that some of these reports relied upon thousands of underlying studies, supplying every underlying study in the Docket would be unreasonable and unnecessary.

Comment (2-15): A commenter (10071.2) submitted a reference to Kawamura et al. (2006) on how air mixes into firn (compacted snow that is becoming glacial ice). The commenter claims that this mixing leads to an averaging of gas concentrations over 1,000 to 5,000 years; therefore, the commenter states, “It is possible, even extremely likely, that peak CO2 values in the past were 2 or 3 times higher than indicated by the filtered values we are shown. Expressed another way, if the same 5,000 year moving average used on the ice core data was applied to the current data, the current ‘highest peak ever’ would, in fact, be about average.” Similarly, a commenter (2818) states that ice core records are unreliable because their resolution is at best 1,000- to 5,000-year averages. Response (2-15): We have reviewed the comment, and the paper by Kawamura, and conclude that there is no evidence in the literature that peak CO2 values in the past were 2 or 3 times higher than indicated by the ice core records. Kawamura et al. (2006) investigate four polar sites in order to better determine relationships between deep air convection in firn and various environmental variables like windiness and pore size of the firn. However, Kawamura et al. make no claims about the timescale of averaging of gas concentrations, and we find that the paper provides no support for the conclusions of the commenter. The resolutions of these ice cores range from decades for the Law Dome in the last couple of thousand years (Jansen et al., 2007), to 570 years for time periods more than 650,000 years ago (Lüthi et al., 2008). Therefore, we disagree with the assertion by the commenters that the resolution of ice core records is at best 1,000 to 5,000 years. IPCC found that “There is no indication in the ice core record that an increase comparable in magnitude and rate to the industrial era has occurred in the past 650 kyr. The data resolution is sufficient to exclude with very high confidence a peak similar to the anthropogenic rise for the past 50 kyr for CO2, for the past 80 kyr for CH4 and for the past 16 kyr for N2O.” Despite the assertions of the commenter, our review of the literature finds no evidence in contradiction to this statement.

Comment (3-42): A commenter (2818) requests that the derivation for radiative forcing be presented (mentioning the HITRAN [High-Resolution Transmission Molecular Absorption] database). Another commenter (10071.2) requests the same data, claiming that infrared radiation only matters for the bottom 800 m of the atmosphere, and therefore the thickness of the full atmosphere should not be used to compute radiative forcing. The commenter suspects that the forcing numbers are chosen to make the models produce the right results, and that CO2 cannot cause global warming. Response (3-42): Radiative forcing for gases is usually calculated within global circulation models using some form of line by line or other radiative code. The IPCC Third Assessment Report includes a discussion of these issues in Chapter 6.3 (Ramaswamy et al., 2001). The citation for the commonly used approximate expression 5.35 ln(C/C0) (the log of the current concentration of CO2 over the pre-industrial concentration) is Myhre et al. (1998), which uses three different approaches to calculate radiative forcing (line by line, narrow band, or broad band). Myhre used the HITRAN database (information on that database can be found at http://www.cfa.harvard.edu/hitran//). Forster et al. also include a discussion on radiative forcing calculations, where they find that “Collins et al. (2006) performed a comparison of five detailed line-byline models and 20 GCM radiation schemes. The spread of line-by-line model results were consistent with the ±10% uncertainty estimate for the LLGHG RFs (long-lived GHG radiative forcings) adopted in Ramaswamy et al. (2001) and a similar ±10% for the 90% confidence interval is adopted here. However, it is also important to note that these relatively small uncertainties are not always achievable when incorporating the LLGHG forcings into GCMs. For example, both Collins et al. (2006) and Forster and Taylor (2006) found that GCM radiation schemes could have inaccuracies of around 20% in their total LLGHG RF (see also Sections 2.3.2 and 10.2).” GISS Model E is also available publicly (http://www.giss.nasa.gov/tools/modelE/), and therefore the commenter can easily acquire the actual radiative code for at least one major model, along with the documentation of how the radiative forcing equations are developed from theoretical principles and laboratory experiments, and tested against satellite measurements of atmospheric radiative fluxes. We find that these radiative equations match the best available science, and are widely available for scrutiny. The statement that infrared radiation only matters in the bottom 800 m of the atmosphere is consistent with the scientific literature. Radiative forcing is commonly report as top of the atmosphere forcing, not at 800 m. CO2 and other GHGs interact with infrared radiation in the full tropospheric column (and indeed, in the stratosphere as well) both in reality and in the model code.

• hitran
• line by line
• line-by-line

The last paragraph in internally inconsistent. They probably meant to include a "not".

The statement that infrared radiation only matters in the bottom 800 m of the atmosphere is [not] consistent with the scientific literature.

The EPA statement that

results were consistent with the ±10% uncertainty estimate ... and a similar ±10% for the 90% confidence interval

On page 39 (pdf 44)

Comment (3-48): A commenter (2818) states that GHGs cool the atmosphere by 100°C, otherwise the Earth would have the same temperature as the maximum temperature on the moon (121°C). Another commenter (10071.2) claims that “You always hear that GHGs warm the surface by 33° C, but most sources forget to mention that they also cool the atmosphere by more than 100° C. If the atmosphere was just nitrogen, with no greenhouse gases, the temperature of atmosphere would be about 121° C (249° F), well above the boiling point of water. It is the greenhouse gases that cool the atmosphere.” Response (3-48): The scientific literature is clear that GHGs have a warming effect on the temperature of the Earth. The existence of an atmosphere and oceans explains why the surface of the Earth does not reach the high temperatures reached by the sun-side of the moon; this is not a function of GHGs. The atmosphere and oceans also serve to keep the night-side of the Earth from reaching the –233°C that the moon reaches. The average temperature of the moon is actually less than the average temperature of the Earth. The average temperature of the Earth is 33°C higher than the theoretical blackbody temperature, and the difference is attributed mainly to GHGs. Venus (see response 3-49) is another example demonstrating that GHGs do not cool the surface. Therefore, we disagree with the assertion of the commenter that GHGs are a cooling influence.

URL: http:// questionable-science.com / Global_Warming / EPA_Comments / EPA_Response.html