EPA Public Comments
over 11,000 public comments
on the EPA's attempt to regulate CO2.
(Probably well over 500,000 when the petitions are included.)
I have obviously not read them all, but there are a few patterns I thought worth noting.
As of 11-24-09, the EPA is still accepting and posting new comments.
the current count is 11,532.
I have particularly enjoyed reading the comments from people who do not
claim an association with any particular group.
For the vast majority, it is clear that they are using some kind of
form letter. The tip off is that 2 or 3 sentences are identical in many of them.
It is also interesting that many of these are either hand written or typed on paper.
(The pdf's are scanned images.)
A great many of them are stamped with "Jun 12 2009", which probably means that that was when
the EPA started handling paper comments.
- I am contacting you to ask you to act swiftly to cap greenhouse gas emissions since delays
will be costly.
I support making polluters pay for their pollution.
- "act swiftly" and "making polluters pay ..." are fairly common
- I am writing you to ask that you regulate greenhouse gas emissions under the
Clean Air Act economy-wide.
- Please direct the EPA to regulate greenhouse gas emissions under the
Clean Air Act economy-wide.
- I have no idea what "economy-wide" means, but I see it quite a lot in letters from Danbury, CT.
The only google hit is
where they say
Tell Administrator Jackson to direct the EPA to regulate greenhouse gas emissions under the Clean Air Act economy-wide.
This group operates out of New York and Connecticut.
- The United States bears a big responsibility since we are major polluters.
- Blame the US for everything. Also claims that CO2 is pollution
- Thank you for leading the EPA to do the right thing
- "do the right thing" is repeated a lot
- carbon pollution
- This is used a lot, it is not in any official documentation I know of.
- because of climate change, [disease of choice] and other vector-borne diseases have
- The truth is that the temperature has not changed enough to change the range
of any diseases. The fact that many letters say something like this
indicates a serious education (or propaganda) problem.
- ... as Big Oil and Big Coal prolong this fight
- I have seen a dozen or more of these, all on the same letter head. The first paragraph
is the same, the second is unique.
An internet search indicated that these originated via
which is run by a cell phone company that "donates" money to the ACLU, Greenpeace, and other progressive groups.
They even provide "free progressive ringtones".
- As a mother of a child with asthma, it would be nice to breath clean air.
- CO2 does not cause asthma, but it could make plants grow better and that would be very bad.
This claim is more common in the hand written letters than in the typed responses.
A comment - there are a few single page letters that have the same titlepage logo
- a blue globe. The first few of these had the same first paragraph and a monochrome globe.
The ones with the blue globe tend to have unique text.
I assume that these come from some type of campaign ... perhaps a form you can fill out on line and send.
These are organizations associated with this letter head.
Online Instant Form Letters
I noticed a few patterns when reading the comments, similar formatting, identical
first paragraphs, and so forth. Eventually, I noticed the following
in some of the title blocks.
Well, a little investigation uncovered the
Sierra Club Global Warming Campaign
with a link to
- a page of various positions that the Sierra Club is supporting.
Unfortunately, the one for this docket is not there,
but the others link to pages where you can enter your name and address.
An initial first paragraph is hard coded and there is a box where you can
type whatever you want.
- Sent by: Sierra Club Membership Services
- Sent by: National Wildlife Federation
That's right, the nicely typed, similar format, identical first paragraph responses really are form
letters after all.
In addition, these organizations have names, address, and emails for future uses
(sometimes you can opt out).
National Wildlife Federation
pages were significantly harder to find.
This looks like the identical software that the Sierra Club uses ...
except that they allow you to edit the entire text.
Observations regarding online form letters
Therefore, some of the canned text may (or may not) appear.
These are a few identifying sentences from the canned text.
- Some sites provide only canned text and user comments are not allowed
- Some sites have a canned first paragraph and users can add additional comments
- Some sites allow the canned text to be edited
are also available. This would explain why petitions contain
typed names, addresses, and comments.
- Sierra Club Membership Services - I support a bold course on Climate Change...
Determining that carbon dioxide and other greenhouse gases endanger
public health and welfare, as EPA has now done, is a bold and necessary
first step towards solving the climate crisis.
- National Wildlife Federation - persons name on title line, the quote is usually the first or second paragraph.
However, users are allowed to edit the whole paragraph.
As a wildlife enthusiast who is concerned about the future of my
community and the natural world, I strongly support your declaration
that global warming pollution is a serious threat to public health and
- credoaction.com, a cell phone company (This is the second sentence of the canned first paragraph.)
Global warming is one of the greatest problems facing our society,
and we cannot afford to drag our feet as Big Oil and Big Coal prolong this fight.
- care2.com, it isn't clear, but they claim to be an independent activist group (with lots of ads)
I applaud your proposed finding that greenhouse gas ...
- democracyinaction.org - You can completely replace the canned text. Email subject - "I Support Action to Curb Global Warming and Protect Human Health"
Global warming is one of the greatest challenges humanity has ever faced.
- Form letter from an unknown source - interesting (and unusual) because it argues against regulating CO2
The impact of classifying carbon dioxide as a pollutant ...
A new regulation on this scale should be openly debated by
Congress and not passed in the back rooms of an executive agency.
- Environmental Defense Action Fund - Apparently this is from Kofi Annan, not the UN. It is also
apparently not true.
The UN recently reported that 300,000 people die every year worldwide
from global warming impacts.
I understand why large national activist groups
(like the Sierra Club and the National Wildlife Federation)
provide form letters.
But cell phone companies and independent activists seem a little weird.
- Comment submitted by W. K. Halligan - (named mistyped as Hafligan)
- Very well written, covers most of the anti-regulation points
- Comment submitted by Christopher B. Reilly, Vice President, York County Board of Commissioners
- Well written. Invokes the fear of lawyers.
... if the EPA were to find that greenhouse gases affect public health, it would give trial lawyers a pretext to
begin litigation ...
- Comment submitted by T. Ferguson
- Some letters are gold. I liked this because it was submitted via a pro-regulation formmail site. He just added
the following paragraph above the normal crap.
The letter below is a bunch of crap. Global warming and cooling
are caused by sun cycles. Stop worrying about CO2 and worry
about LEAD MERCURY, and CADMIUM. Worry about clean water. Global
warming is a scam to create a new commodity and a new market to
trade it in. Enron came up with Cap and Trade. Don't fall for
- Comment submitted by R. Clemenzi
- I figured I might as well link to my own comments :)
It was 7 weeks from the time I submitted them electronically until the day they were posted.
Because my main email page also has the blue globe, it is obvious that it is something
that the EPA is adding. Apparently, it just means that the page was received electronically (email).
- Comment submitted by R. Graham
- Very well written. Discusses problem with computer models.
Discusses the issues with the "Hockey Stick" graph.
- Comment submitted by David Boleneus, Licensed Geologist, InfoMine USA Inc.
- Discusses ice cores from the perspective of a geologist
- Comment submitted by J. Ford
- CO2 is plant food. Supports Anthony Watts.
- Comment submitted by D. R. McIntyre
- Well written. Provides references for his claims. The most interesting (to me) was that ticks tend
to be a bigger problem in cool, wet years than in hot, dry years because in hot, dry years
there are more ants which eat the ticks. As a result,
Global Warming should decrease the spread of tick borne disease though the
extremists claim the opposite.
- Comment submitted by Rick Reiter, Reiter & Associates
- Another litigation warning. There are 29 municipality owned utilities in Colorado that would probably be sued
if this regulation is passed. The letter claims that everyone in those communities would be harmed
simply because of the cost of defending the lawsuits.
- Comment submitted by Howard C. Hayden, Professor Emeritus of Physics, University of Connecticut
- This comment was written October 27, 2009 and entered into the system November 17, 2009 ...
well after the June 23 comment end date.
At any rate, this is very well written. It says that the fact that there is more than
one model is definitive proof that the science is not done. 21 models producing very different
results is not consensus.
The science in some of these letters is so bad a study should be
done to see if the schools are really this bad or if
something else is going on.
(Like intentional disinformation)
- This was added to
the National Wildlife Federation form letter
- Effects of global warming - asthma, severe allergies, swine flu,
more mosquitoes will cause more cases of AIDS and swine flu (neither is spread by mosquitoes),
- Mass Comment Campaign sponsored by Ligon Middle School (14)
- There are 14 letters from some Raleigh, North Carolina middle school students.
(Only one of the 14 letters is online.)
In the past, when comments came from kids under 18, the letters were not published.
At any rate, the names and addresses should have been redacted.
When discussing CO2, these letters say
In addtion to ruining the planet, health problems are increasing in my generation.
Asthma rates are higher, and new forms of airborne bacteria-caused diseases
are appearing, like the antibiotic-resistant strains of tuberculosis.
It is a shame that bad science (like this) is being taught to these kids.
I keep seeing public comments that don't seem appropriate.
I assume that these are form letters from some clueless activist site.
- Anonymous public comment
- There are quite a few of these. However, a lot of them actually have names associated with them.
While there is no signature block, a name does appear in the email heading.
I know that this is a nit, but ...