**HOLLIDAY ENVIRONMENTAL SERVICES, INC.**

# ENVIRONMENTAL ENGINEERS & REGULATORY CONSULTANTS 

P.O. BOX 2508 BELLAIRE, TEXAS 77402-2508 (713) 668-7640 FAX (713)
668-5184

E-MAIL ghh@att.net

7 September 2008

Environmental Protection Agency

1200 Pennsylvania Ave. N.W.

Washington, D.C. 20460

**RE: Docket 1D No. EPA-HQ-OW-2008-0390 - COMMENTS**

Gentlemen:

These comments respond to the EPA request regarding the revisions to the
Underground Injection Control (UIC) Class VI well rule proposed 25 July
2008 at 73 FR 43492-43541. We agree EPA has the authority under the Safe
Drinking Water Act (SDWA) to propose regulations governing Carbon
Dioxide Sequestration Wells to protect Underground Sources of Drinking
Water, but we believe such wells are: 1) dangerous and 2) unnecessary.
Also, we believe the Safe Drinking Water Act is not suited to provide
necessary safety to the citizenry, because EPA by promulgating Class VI
wells is authorizing construction of a CERCLA eminent hazard substance
storage site and a RCRA hazardous substance (corrosively) storage site.
Each of these concerns and many more are discussed below. We request
these comment be made a part of the record EPA-HQ-OW-2008-0390.

**Summary**

The Environmental Protection Agency at 73 FR 43492-43541 requests
comments regarding the proposal to prepare regulations for an unknown
number of Class VI wells, which are in reality, manmade explosive
devices storing buoyant carbon dioxide sequestered deep in the earth
under supercritical pressure conditions by persons of unknown technical
ability seeking monetary rewards and approved by Agency technically
untrained employees, who are not Professional Engineers and supervised
by a Regional Director who is neither an engineer nor a Professional
Engineer. The Agency proposes using untrained EPA employees who are not
required to demonstrate their CO~2~ sequestration technical knowledge by
completing and passing a written examination. Further, the Agency
proposes to sequester buoyant CO~2~ until the end-of-time by only
requiring 50 years of monitoring (40 CFR 146.93(b)(1)). In addition, EPA
proposes using well completion materials not currently developed and
proven corrosion-resistant under carbonic acid corrosive conditions.

The proposed regulations are a formula for future disaster: 1) Dangerous
to sequester CO~2~, a supercritical fluid stored at high pressure: 2)
The scientific basis for sequestering Carbon Dioxide (CO~2~) as a means
of slowing or eliminating climate change is not scientifically
established. In fact, EPA does not claim anthropogenic CO~2~ is the
cause of climate temperature increase. EPA simply infers sequestration
is necessary. Refer to the Comment Section entitled "Sequestration is
not necessary" and Attachment 2 for details on the lack of supporting
data for this argument.

The sequestration of CO~2~ represents a money-making scheme of a
political pollutant, which will encourage unqualified organizations and
speculators to seek Class VI injection permits. These unqualified
organizations will find unqualified consultants to prepare documents
supporting the permit applications. EPA, in the instant proposed rule,
suggests several financial responsibility schemes to avoid this problem,
but EPA and states do not know how to assure financial responsibility.
Proposed regulations, with this lack of specificity, typically results
in EPA select conditions, which received no comments during the proposal
stage. This gives EPA free rein to select regulation wording not
reviewed by the commenting public, and not alluded to during the
proposal.

One of the most frightening aspects of the proposed rule is EPA imposes
no qualification requirements on EPA review personnel. Thus, a well
written, but false document, can easily be accepted by EPA, when
technically unqualified reviewers are used. If qualified reviewers were
used, the application would be rejected.

A review of the existing technical literature suggests no author has
considered how long sequestration is expected to last. Schlumberger says
in their advertising, sequestration is "permanent" separation of CO~2~
from the near surface waters. Webster Unabridged Dictionary defines
"permanent" as meaning unchanging, a very long time, to last
indefinitely. Indefinitely is for ever without end. This appears to be
an impossible assignment. Governments come and go, people come and to,
and most importantly companies (permittees) come and go. The cost of
carbon dioxide sequestrations monitoring until the end of time is a
monumental expenditure. To circumvent this problem EPA states 50 years
should be long enough, even though EPA offers no technical support for
this assumption, but then they say "not to worry," EPA will allow the
non-technically trained Regional Director to lengthen or shorten the
sequestration reservoir monitoring time based on his vast inexperience.
EPA offers no guidance to assist the untrained, non-engineer Regional
Director in making that determination. EPA discusses what happens, if,
the sequestration operator goes bankrupt or decides "enough is enough"
and cannot or will not continue monitoring the highly pressure CO~2~
containing formulation. But EPA offers no useable answer. EPA suggests
in the instant preamble that, commenters waiting until EPA finds an
answer.

The Federal Government can establish a trust fund? If one observes the
Social Security Trust Fund, we can expect the sequestration fund to be
combined with the General Fund for Government maintenance and then the
money is not available when need! Who will prevent Congress from using
the when times lean. The Safe Drinking Water Act makes no provision for
this alternative!

EPA believes Class VI wells and associated reservoirs will be safe, even
though corrosion resistant materials are not available. Again EPA says
"not to worry" EPA "knows" the Oil and Gas Industry will develop
corrosion resistant pipe and cement. Our investigation shows no pipe,
packer, rubber seal or cement are resistant to carbonic acid attack for
50 years (maximum test length to date is 12 months!). Thus, when the
well or formation fails (leaks), the CO~2~ phase change will result in a
massive increase in volume as the CO~2~ approaches the earth's surface
causing vast destruction. EPA is not authorized by the Safe Drinking
Water Act to consider protection of human life from such a disaster.
Since the disaster may occur where there is no USDW the Statue provides
no protection for the general public in that area. Thus, at some future
time the sequestration system operating at 2215± psia (Moore, et al) can
fail due to corrosion (Meyer, 2007) or the carbon dioxide finds its way
to the earth's surface.

Meyer (2007) reports severe corrosion of stainless steel 404 components
during injection at an enhanced oil recovery (EOR) using carbon dioxide.
Also, Newton and McClay, say "\[p\]redict\[ing\] ··· corrosivity based
on CO~2~ and water cuts have not always proved accurate." The presence
of water insitu to storage reservoirs increases the corrosive nature of
this CO~2~. The injected CO~2~ is buoyant and rises to the bottom of the
top confining zone. The confining zone is penetrated by at least one
injection well and probably more. These wells must have casing, which
will be corroded quickly unless there is a constant injection of
corrosion inhibitor.

A review of the Department of Energy, State of Washington and State of
New Mexico reports and rules shows none of these Agencies are willing to
discuss the types of material appropriate for well completion
components. This is true, also, of the IOGCC (2007) report. On the other
hand, EPA at 73 FR 43510 suggests using stainless steel 316 fittings,
and forgings on the basis of recommendation of Meyer (2007) for surface
connections associated with EOR wells. We ask for clarification from Dr.
Meyer. Dr. Meyer provided reference to two paper demonstrating severe
corrosion of carbon steel (Schemp and Roberson, 1975; Newton and.
McClay, 1977.

We know the stainless steel components have corrosion problem, Meyer,
2007. Further investigation establishes that only one stainless steel
316 wellhead assembly has ever been made in the U.S. This means EPA
already has approved CO~2~ sequestration wells which are subject to
severe carbonic acid corrosion, making the wells current CERLA eminent
hazards. Meyer (2007) also discusses use of epoxy coated tubing for
enhanced oil recovery. The plastic coated tubing is pulled and inspected
yearly. Yearly inspection of tubing does not appear practical for CO~2~
sequestration wells! Each time the tubing is pulled, the coating at the
threaded joint wears and/or chips, exposing the carbon steel to carbonic
acid corrosion. This corrosive attack will result in rapid
exteriorization of the tubing. The frequent round trips of the tubing
results in exposing the casing to corrosion. With time, the inside of
the casing will be exposed to carbonic acid attack, if a leak in the
tubing or tubing connection occurs.

The packer presents a particularly difficult design problem. A stainless
steel packed body can be manufactured. But, the slip must be hardened
carbon steel so they set in the casing to compress the elastomer seal.
Stainless steel work hardens, but it is not heat treatable. Thus making
stainless steel slips appears highly questionable. Packer elastermers,
e.g. Buna-N and Nitrile rubbers, are available, but never tested over
long time periods, e.g., 50 years, in the presence of carbonic acid.
Schemp, and Roberson, (1975) report "\[T\]ests showed nonmetallic seals
to be susceptible to acid and mechanical damage."

Tubingless completions are possible, but this would expose the casing to
acid attack. Multiple cemented casing strings can be run. However, steel
is known to corrode rapidly in the presence of carbonic acid. Admixed
cements have been "accelerated" tested in the presence of carbonic acid
for a period of 6-12 months, but not for decades (personal communication
with Vaughn Morgan, Halliburton). Thus, un-field tested specialty
cements have been short term laboratory tested, but not over a 50 year
period! Halliburton (<http://www.patentstorm.us/patents/6904971.html>)
makes a acid resistant cement "with improved corrosion resistance.'
Halliburton does not claim the cement to be acid resistant!

What is particularly disturbing is the statement by EPA at 73 FR 43510,
col. 1, "\[t\]oday's proposal does not specify materials that may be
used, rather, proposes providing the owner or operator with the
flexibility to choose, as long as the materials used in GS wells are
corrosion-resistant and meet standards approved for such materials by
API or ASTM International or comparable standards approved by the
\[nontechnically trained\] Director". This statement says in effect, "We
don't know what materials are appropriate for CS well completions. Thus,
EPA places the responsibility on Industry and the untrained,
non-engineer Regional Director to solve the materials dilemma. The EPA's
statement at 73 FR 43510 raises even a greater concern:

> \[t\]oday's proposal would require that the cements and cement
> additives used in GS wells be appropriate to address long-term
> injection of CO2 and assure that the well can maintain integrity
> throughout the proposed life span of the project,

e.g., without EPA specifications materials, expected longevity,
corrosion resistance requirements, etc., EPA places the responsibility
on an industry which government, the public and regulators have never
trusted. By this ruse, EPA sidesteps the responsibility for any CS well
failures.

**The proposed rule must be withdrawn!**

**CS Wells are not necessary**.

Carbon dioxide sequestration will not stop climate change! EPA in the
preamble to the CS proposed rule (73 FR 43496-43502) discusses the
reasons for the need for CO~2~ sequestration. Nowhere in those pages
does EPA state that carbon dioxide emissions cause climate warming or
what the optimum earth temperature is, or how the Agency knows when the
optimum temperature is reached, so sequestration can be discontinued. Is
EPA suggesting sequestration be continued until it causes the next ice
age? A review of the Department of Energy reports demonstrates a similar
lack of CO~2~ cause and effect.

We can find no peer reviewed technical paper, referenced by EPA or
anyone else, not based on computer simulation, showing CO~2~ causes
climate change. EPA relies heavily on Intergovernmental Panel on Climate
Changes (IPCC) reports. Reference to IPCC reports subjects EPA to
serious question regarding the technical validity of the information
presented. The use of the Hockey Stick Figure (Figure 22, IPCC, 1996)
brings into sharp focus the political nature of the IPCC reports.
McIntyre and McKitrick (2003) demonstrated conclusively the Hockey Stick
Figure was based on truncated data, obsolete data, contained calculation
errors and quality control deficiencies. Also, Figures 5.20 and 5.21
(IPCC, 2005) , well details, demonstrate IPCC is technically deficient
because IPCC blithely suggests pulling cemented casing from Class VI at
the completion of injection, IPCC Figure 5.21. Experience demonstrates
cemented casing cannot be pulled. IPCC (2005 at page 231) suggests
milling the casing at the shoe to remove corrodible metal from contact
with the carbonic acid. Milling is possible. Modern mills can "hog out"
10 feet of casing per hour, but the metal chips settle-out in the
Blowout Preventer, preventing proper operation in the event of an
emergence. The ludicrous suggestion of using a milling stone as a means
of connecting to a fixed packer defies all understanding, IPCC Figure
5.20. Astute scientists and engineers are very wary of IPCC reports,
because of the frequent and consistent errors contained in the reports.

Also, EPA, in the proposed sequestration rule, does not provide any
indication of the benefit sequestration will provide other than reduce
CO~2~ concentration in the atmosphere. Even that goal appears
questionable. Our extensive review of the technical literature
demonstrate no peer reviewed reports based on field observations are
available showing a direct relationship global warming caused by
increase in the atmospheric CO~2~. However, Lucas, 2008, states the "We
Can Solve It" ([www.wecansolveit.org](http://www.wecansolveit.org/))
campaign compares "your commitment to solving the climate crisis as
\[being equivalent to solving\] the World War II, Normandy landing, the
civil rights movement and putting a man on the moon" combined.
Unfortunately, [www.wecansolveit.org](http://www.wecansolveit.org/)
offers no supporting data, but it offers new high income opportunities,
which appears to be the major driving force behind temperature change
projects.

If a relationship between CO~2~ and global temperature increase is real
and the quantity of anthropogenic CO~2~ is infinitesimally small
compared with naturally occurring CO~2~ as shown by DOE, Figure 1,
below, CO~2~ sequestration is meaningless. The U.S. Department of Energy
([www.fossil.energy.gov/programs/sequestration/overview.html](http://www.fossil.energy.gov/programs/sequestration/overview.html))
developed the graph, Figure 1, showing CO~2~ entering the atmosphere in
2008 from anthropogenic sources is 6.0 GtC/yr.: Forests and soils
release \>100 GtC/yr: Geologic \>300 GtC/yr and Oceans 1,400 GtC/yr. It
appears sequestering all of the anthropogenic CO~2~ in minuscule when
compared with natural sources. Will sequestering such a small quantity
be effective?

![](media/image1.wmf){width="6.500694444444444in"
height="6.383333333333334in"}

**Figure 1. 2008 Estimated United States CO2 Emissions for 2008**

**CO~2~ Sequestration is Costly as Well as useless**

Xie and Economides (2008) discuss the uncertainties and risks of CO~2~
sequestration in oil and gas reservoirs (see Attachment 1, below). The
authors conclude the cost just to satisfy the United States Kyoto
Protocol requirements will cost more than \$1 Trillion per year. The
paper gives a "realistic situation \[view\] on the potential impacts on
commercial CO~2~ sequestration projects, environment and the global
climate change."

**Sequestration is not Necessary**

Holliday (2008), Attachment 2, shows, based on existing technical
papers, CO~2~ emissions are not causing climate temperature change.
There have been climate changes for at least 900,000 years. Life has
struggled forward under climate temperature increases and decreases
without being annulated.

During these temperature changes, Greenland has gone from a marginal
framing area to a bleak cold frozen area, but life continues taking
advantage of the warmer climate by moving away from the cold areas. The
belief that these climate changes can be mitigated by sequestering
carbon dioxide has no scientific support, since previous climate changes
occurred in the absence of anthropogenic CO~2~.

Climate models, which are being used to suggest CO~2~ is causing
temperature increase are inaccurate at best, because climate predictions
are very complicated and beyond our current technical capabilities.
Relying on computer modeling for the basis for needing the instant rule
proposal is a cruel hoax.

**Lack of Qualified EPA Personnel**

EPA requests comments on many aspects of CO~2.~. For example at 73 FR
43514, col. 2, EPA request help learning to track CO~2~ underground
plumes. I have worked with the UIC rules as a commenter since 1979. At
no time did EPA use an EPA Professional Engineer (P.E.) for developing
the UIC rules. During the initial stages of writing the 1979 draft
rules, EPA used an Ancient English graduate as the Agency lead technical
supervisor. Ancient English is not considered a technical background.

I have not found any of the current EPA UIC Regional employees to be
professional engineers. When I requested the information from EPA, I was
told privacy laws prohibited providing such information. Reviewing and
understanding CO~2~ sequestration projects is a technically exacting
task. Assigning an EPA non-professional engineer to this review task
exposes the U.S. public to severe risk. Placing the final approval in
the hands of a Regional Administrator, who traditionally has not been an
engineer, means the EPA is disregarding public safety. At a minimum, the
reviewing engineer and Regional Administrator must be Professional
Engineers. EPA at 40 CFR Part 112 requires a Professional Engineer
certify a Spill Prevention, Control and Countermeasure (SPCC) Plan,
which typically is intrinsically a safe procedure, but EPA does not rely
on EPA Professional Engineers to review high pressure, corrosive fluid
injection projects, that can be intrinsically unsafe. This demonstrates
the Agency is ill-equipped to approve CO~2~ sequestration projects using
the current organizational practices.

EPA has likened Class VI projects to Class I hazardous waste injection
wells and Class II CO~2~ enhanced recovery wells. It is true Class I
disposal wells sequester hazardous waste, but these wastes are not
buoyant and typically are combined with other waste to make them
non-corrosive. Further, the Agency has been reviewing Class I and II
well plans submitted by experienced oil and gas company engineers. An
anticipated shortage of trained oil and gas industry engineers (Bryant,
2007) and the political nature of CO~2~ sequestration projects
([www.wecansolveit.org](http://www.wecansolveit.org/)) will attract
spectators, who do not intend to see the project through to completion.
Thus, the Agency will be forced to correct many problems caused by poor
review and oversight on the part of the untrained EPA employees

The mixture of hazardous wastes associated with Class I injection wells
do not aggressively attack carbon steel or cement. Also, hazardous waste
will not change phase, as supercritical CO~2~ does when the pressure is
decreased. The change in fluid phase results in formation of a gas,
which is large in volume and better able to find its way to the surface
of the earth through minute cracks. The earth's surface is full of
examples of oil seeps, e.g., the underwater seeks at Santa Barbara,
California, and oil seeps in and around the Pennsylvania oil fields, to
name a few areas where leaks are known to occur.

Thus, the hazardous wastes stored in Class I wells are retained
underground because, the column of waste formed when a leak occurs,
provides a controlling head of weighted fluid. In the case of CO~2~ the
head in the event of a leak becomes less as the over burden pressure
reduces. This is a much more dangerous condition than experienced with
Class I wells. Also, a Class I injection well is associated with
producing wells, which can be protected from corrosion by injecting
corrosion inhibitor into the producing well during the producing phase.

Class II enhanced oil recovery (EOR) wells are not abandoned with a high
residual head of buoyant gas. Typically, the well is produced until the
field becomes un-economical (depleted) to produce. This, unlike the
CO~2~ sequestration wells is not under high supercritical pressure (2200
psig pressure) at the time of abandonment.

**EPA Carefully Selects Citations**

EPA, at 73 FR 43515, col. 2, cites Burton et al. (2007) as supporting
the availability and adequacy of "current monitoring technologies" for
monitoring pressures in GS project (sic)." EPA does not cite the serious
questions raised by Nicot and Hovarka (2008) at the EPA January 16, 2008
CO~2~ meeting in New Orleans, wherein Nicot and Hovarka (2008) presented
a PowerPoint slide show regarding monitoring insitu. Hovarka (2008)
reiterates serious concern raised in 2007 regarding field monitoring
capabilities of currently available tools

Again, at 73 FR 43515, col. 3, EPA selects the Nimiz and Hudson (2005)
report to justify insitu monitoring of CO~2~. EPA did not cite the Nicot
and Hovarka (2007) presentation, which makes a point of expressing
serious concern regarding insitu monitoring using current techniques.

EPA cites Flett, et al. at 73 FR 43519. The reader is directed to the
EPA reference section (73 FR 43533) of the proposed rule preamble and
EPA (2008b). The reader finds a) no citation as to the origin of the
reference at 73 FR 43533 and b) EPA 2008b is a paper regarding
"Vulnerability Evaluation Framework ···", which, in turn, refers the
reader to the instant proposed rule.

EPA consistently, excludes reference which do not support the EPA
preconceived ideas!

**EPA Does Not Have Proper Statutory Authority to Propose CO~2~
Sequestration Rule**

EPA relies on the Safe Drinking Water Act (SDWA) to protect USDWs from
CO~2~ sequestration. The SDWA authorizes EPA to protect drinking water,
not encourage indefinite storage of a corrosive, high press fluid. CO~2~
is known to attack carbon and stainless steel, Meyer (2007). The fact
that Meyer reported stainless steel 404 was badly corroded by "dry"
CO~2~ indicates wet CO~2~ (carbonic acid) is a RCRA corrosive waste,
since it meets the RCRA definition of corrosive. In addition, the fact a
leak of CO~2~ could enter a building basement suffocating the
inhabitants, demonstrates CO~2~ sequestration is not an environmental
problem, but it is a pervasive and dangerous life threatening hazard.
EPA is ill equipped to control potentially unsafe activities under the
guise of protecting drinking water using the Safe Drinking Water Act.

**EPA Guesses at the required Class VI Monitoring Period**

EPA at 73 FR 43518 -- 43527 discuss how EPA decided to monitor a
sequestration project for 50 years; EPA said 50 years is a long time and
if EPA extends the time longer the cost will be too high! EPA provide no
rational argument for selecting 50 years: EPA says at 73 FR 43 43518,
"EPA is tentatively proposing a post-injection site care (monitoring)
period of 50 years with Director's discretion to change that period to
lengthen or shorten the 50- year period, if appropriate." The best
support EPA offers (73 FR 43520) for the 50 year monitoring period is:

> "To ensure that the post-injection site care monitoring timeframe is
> long enough to determine that there is no threat of endangerment to
> USDWs from injection activities; EPA is proposing a default
> post-injection site care period of 50 years. During this 50-year
> period, the owner or operator would be required to submit periodic
> reports providing monitoring results and updated modeling results as
> appropriate until a demonstration of non-endangerment to USDWs can be
> made."

EPA is willing to rely on a technically untrained Regional Administrator
counseled by uncertified EPA employees, because EPA does not have a clue
how to determine the appropriate monitoring time period! We question the
probability of speculators being in business 50 years after the
injectors stop producing income and become a liability. Since EPA is
charged only with protecting USDWs and not human life, EPA can slough
the real burden onto someone else. In our opinion this is an Arbitrary
and Capricious and a life threatening action on the part of EPA.

**EPA does not include a recommended means of funding sequestration long
term corrective action.**

EPA at 73 FR 43501, tells the reader of the proposed rule to go to
<http://www.epa.gov/safewater/uic/> so as to read the findings of the
various Class VI Workshops. Unfortunately, the presentation are, for the
most part, PowerPoint slideshow without voice over. Thus, the slideshows
are difficult to interrupt and only contain EPA presented materials.
When EPA refers to comments and questions from the attendees, EPA
provides only an interpretation of the questions or comments, thus no
context is provided. This places the commenter regarding the proposed
rule at a severe disadvantage. Reading of the various documents
available on the website demonstrates no issues of post closure
monitoring or long term funding for corrective action were raised, or
discussions recorded. The EPA reference to the website suggests
substantive discussions occurred during the Workshops. The EPA record
demonstrates, little or nothing was accomplished during the meetings.
Again, the commenter is deprived of accurate input from the Workshops.
EPA at 73 FR 43520 EPA states:

> "···SDWA does not have explicit provisions for financial
> responsibility, as included in RCRA, EPA believes that the general
> authorities provided under the SDWA authority to prevent endangerment
> of USDWs include the authority to set standards for financial
> responsibility to prevent endangerment of USDWs from improper
> plugging, remediation, and management of wells after site closure. The
> SDWA authority does not extend to financial responsibility for
> activities unrelated to protection of USDWs (e.g., coverage of risks
> to air, ecosystems, or public health unrelated to USDW endangerment).
> It also does not cover transfer of owner or operator financial
> responsibility to other entities, or creation of a third party
> financial mechanism where EPA is the trustee."

The Agency suggests the Safe Drinking Water Act is not appropriate to
regulate CO~2~ sequestration. Further, EPA believe they can assume the
RCRA type authority for Class VI wells under the SDWA. If challenged in
court, the court most likely will disagree, because the SDWA was written
only for protection of USDW.

When one considers the emphasis on enhanced income available from
climate change presented on
[www.wecandoit.org](http://www.wecandoit.org/), it is difficult to
imagine the speculative companies being willing to fund long term
remedial funds. After the financial income ceases, these companies will
fade away, particularly if the IOGCC (2007) trust fund recommendation is
followed. The trust fund is similar to insurance. The Trust Fund input
per ton of CO~2~ will be considered part of the cost of doing business.

EPA appears to be waiting for counsel from the Environmental Financial
Advisory Board (EFAB) regarding long term financial responsibility for
corrective action. Review of the EPA documents regarding EFAB shows the
"important topic" of Class VI well financial responsibility was not
discussed at the **Workshop on Financial Assurance in EPA Programs, June
17, 2008 - New York, NY**

<http://www.epa.gov/efinpage/publications/FinancialAssuranceWorkshopSummary.pdf>.

At the **EPA, Environmental Financial Advisory Board Meeting 27 March
10-11, 2008,** the minutes record the follow action regarding "this
important topic":

> *"DFO Meiburg* described EFAB's role in paying for activities
> especially in the area of SRFs for water programs. EFAB has expanded
> in the last few years into the transportation sector which is related
> to climate change. For example, the CO2 injection program would
> require financial assurance, if something goes wrong in the clean up.
> EFAB has been working with the Office of Solid Waste and the Office of
> Enforcement over financial assurance related to Resource Conservation
> and Recovery Act (RCRA)."

The sense of urgency expressed by the Agency appears to be lacking in
these Board minutes. If in fact since EFAB is discussing "transportation
sector", the discussion may relate to a different agenda item. In any
event, EFAB does not appear to be actively engaged in long term correct
action funding of Class VI wells.

The entire EPA discussion from 73 FR 43520 to 43522 regarding surety
provisions is not formulated as a rule. The presentation resembles an
Agency thinking "out loud trying to find an answer." We are given no
opportunity to comment on a rational proposal, because the data are
withheld!

**Cost Estimate for Plugging Class VI Wells**

EPA at 73 FR 43522 EPA discusses having funds available to plug Class VI
wells. They question if the owner/operator will have sufficient funds to
plug and abandon the injection well. We have expressed the same concern
previously in these comments. EPA proposes to solve this problem by
having a contractor make the cost estimate. Any cost estimate reflects
the assumption used to develop the estimate. We recall when EPA
instructed their contractor to assume all existing SPCC Plans (67 FR
47140, July 17, 2002) were in compliance with the proposed unpublished
SPCC rule. The resulting cost estimate was unethical, but reflected the
given assumptions and showed the proposed revisions to 40 CFR Part 112
reduce regulatory costs. Is there a chance the same unethical approach
is possible when estimating the plug and abandonment costs for Class VI
by unethical speculators? Will the technically untrained EPA employee
recognize the estimate is not correct or for that matter, how will
untrained EPA employee recognize the estimate is correct?

**ADAPTIVE APPROACH**

EPA, at 73 FR 43522, requests input regarding using electronic means of
involving the public in the rule making process. From our vantage point
of reading the Federal Register daily, the use of the web is highly
satisfactory. However, we find most citizens don't know the Federal
Register exists. Thus, the public does not have any idea what regulation
are being proposed or promulgated. EPA needs to be out-going with their
information, e.g., put notices in the newspapers, sponsor television
Public Notices, etc. Currently, the public is uninformed!

**PRIMACY**

We find many of the state regulator are knowledgeable, but many state
regulators are not formally trained and certainly not Professional
Engineers. CO~2~ sequestration is too dangerous an undertaking to leave
the highly technical review and decision making to non-Professional
Engineers. Any Class VI rule must be based on Primacy only being given
to State and Tribes employing and using specially trained Professional
Engineers for review and approval of CO~2~ sequestration projects.

**Cost Estimate**

EPA at 73 FR 43524 presents the results of an analysis of the cost to
protect USDWs from a Class VI wells. EPA was very specific regarding
what they did not include in the regulatory estimate. EPA based the cost
estimate on a Class I of unknown depth, unknown casing size, unknown
location and type of reservoir. EPA used this unspecified well and
calculated the incremental cost to convert it to a Class VI well. This
approach excludes commenters from verifying the accuracy of the EPA
estimate by these omissions. This is reminiscent of the 2004 SPCC Plan
cost estimate, where commenters were not privileged to the assumptions
EPA provide to its contractor. Unethical instructions, e.g., current
SPCC Plans are in compliance with the unpublished proposed rule or
unstated assumptions prevent testing the accuracy of the cost estimate.
We have no means of knowing if EPA provided unethical instructions to
the contractor for development of the Class VI well costs. Apparently,
EPA told the contractor to use a 25 year after closure monitoring time
period (73 FR 43524). When EPA proposing 50 years at 40 CFR 146.91 (73
FR 43540). Either the Agency changed its mind after giving the go-ahead
to the contractor or the Agency was attempting reduce cost of the rule.

EPA at Table VII-2 (73 FR 43525) says the cost of baseline project plus
Alternate 3 and Alternate 3 increment varies between \$94.6 and \$98.4
million for 22 sequestration projects or \$4.3 million to \$4.5 million
per project. EPA at 73 FR 42504 provides a non-specific definition of
Alterative 3. The definition is words without specificity! We have no
inkling of want Alternative 3 entails.

On 28 August 2007, I discussed these cost figures with the Chairman of
the Society of Petroleum Engineers Sequestration Panel. His response was
"there is no way in Hell we can conduct a sequestration project for that
little money."

EPA notes at 73 FR 43526 "····CO~2~ injection··\[as\]··already
practiced···(i.e. EOR), is expected to expand rapidly···." This
statement can be interpreted to mean CO~2~ EOR will be come under the
Class VI well rule. If this is the case EPA will in effect reduce oil
and gas production significantly during an existing server energy
shortage! Since operating conditions of CO~2~ EOR are different, e.g.,
Supercritical CO~2~ is not left in the reservoir at abandonment, casing
penetrating the cap-rock can be protected from corrosion, etc., the
converting of CO2 EOR wells is not justified or appropriate.

Respectfully submitted

[s/ G, H, Holliday]{.underline}

G. H. Holliday, PhD., P.E., BCEE, Life Fellow ASME

**References**

Bryant, S., 2007. Geologic CO~2~ Storage---Can the Oil and Gas Industry
Help Save the Planet? J Pet. Tech (JPT), p 98-105, September

Burton, E., R. Myhre, L. Myer, and K. Birkinshaw. 2007. Geologic Carbon
Sequestration Strategies for California. Report to the Legislature.
November, 2007. CEC--500--2007--100--SF.

Environmental Enterprise: Carbon Sequestration using Texaco Gasification
Process. Presented at the First National Conference on Carbon
Sequestration, Washington, D.C. May 14-17. 2001

Hovarka, S., 2008. "Recent Progress and Big Ideas on Geologic
Sequestering, US/International Perspective." 11 January.

IPCC, 1996. Second Assessment Report, Summary for Policymakers.

Lucas, F., 2008. Cashing in on Climate Change. Human Events, 64:28;15,
August 14, 2008

McIntyre, S. and R.M. McKitrick, 2003. "Correction of Mann et al. Proxy
Data Base and Northern Hemisphere Average Surface Air Temperature
Series" Energy and Environment, 14:751-771

Meyer, J.P. 2007. "Summary of Carbon Dioxide Enhanced Oil Recovery
(CO2EOR) Injection Well Technology" prepared for American Petroleum
Institute, p 21.

Moore, J.J. M. Nord and K. Brun, 2007. Novel Concepts for Compression of
Large Volumns of Carbon Dioxide, Oil and Gas Journal, June

Newton Jr., L.E., and R.A. McClay, 1977. Corrosion and Operational
Problems, CO2 Project, Sacroc Unit, SPE 6391-MS

Nicot, J.P. and S.D. Hovorka. 2008. Role of Geochemical Monitoring in
Geologic Sequestration. Presented at the CO2 Geologic Sequestration
Technical Workshop on Measurement, Monitoring, and Verification, January
16,. New Orleans, LA.

Schemp, F.W., and G.R Roberson, 1975. Effect of Supercritical Carbon
Dioxide (CO2) on Construction Materials, SPE Journal, 15:3, June. Paper
4667-MS..

Xie, X and M.J. Economides, 2009. "The Impact of Carbon Geological
Sequestration". SPE 120333-P.

**ATTACHMENTS**

**Attachment 1**

ABSTRACT

**The Impact of Carbon Geological Sequestration**

**By**

**Xina Xie and M.J, Economides**

**SPE 120333-P**

Although CO2 geological sequestration is the most popular carbon storage
method promoted and pilot tested, the economic feasibility and technical
risks for commercial scale sequestration projects are rarely mentioned.
More significant, is that, apart from rhetorical pronouncements, the
would-be impact of the operation on climate change is not discussed.
This work studies the technical risks, regulatory issues, and economic
burden of CO2 geological sequestration on the U.S. by using the Kyoto
Protocol emission requirements as the base line. The potential effect of
burying all the extra CO~2~ regulated by Kyoto Protocol on global
temperature change is also evaluated.

The lack of regulatory framework is blamed as one of the obstacles for
slowing or stopping CO~2~ geological sequestration practice. However,
any regulatory issues are intertwined and dominated by the physics of
the injection process itself and its economic viability. This study
analyzes the uncertainty and/or risks caused by CO~2~ geological
sequestration in oil and gas reservoirs, saline aquifers, and coal beds.
The work shows that the potential technical and legal risks and
financial costs for sequestering CO2 underground make it impossible to
promulgate any regulatory framework without causing detrimental effects
on economic development and energy utilization. It is estimated that
CO~2~ sequestration in U.S. will cost over \$1 trillion annually for
CO~2~ geological sequestration by complying with the Kyoto Protocol.
Even if the global temperature increase of 0.7 degrees Celsius over the
past 100 years is solely caused by anthropogenic CO~2~ emissions, the
change on the global temperature by sequestering all the CO~2~ emitted
exceeding the 95% of 1990 level will be negligible. The dynamic climate
and weather patterns on Earth will make it impossible to be verified.

This work gives a realistic situation on the potential impacts of
commercial scale CO~2~ sequestration projects on economics, environment,
and the global climate change. The findings of this study can be used to
evaluate the risks of the CO~2~ geological sequestration projects.

Attachment 2

Climate Change

George H. Holliday, PhD., P.E., BCEE

Holliday Environmental Services, Inc.

SPE

## Abstract

I am neither an atmospheric physicist nor climatologist, but I have
read, studied and thought extensively about climate change on earth.
Based on my reading and study, I am convinced the present climate change
on earth is real and occurs naturally due to changes in solar cycles.

Earth has experienced climate change for at least 900,000 years, as
documented by ice core gas analyses and more recently, written
documentation of the Roman Warming and the Little Ice Age. In 1984
analyses of gas in ice cores suggested climate change occurs about every
2,500 years. Additional data shows climate change cycle at 1,500 years
±500 years. These results are ignored or politicized for the general
public. Seldom is the Roman Warming or the Little Ice Age mentioned,
even though Little Ice Age evidence is before us in the form of drastic
change in the temperature of Greenland from marginal farmland to cold
temperatures causing the inhabitants to abandon previously productive
lands. Also, during the Little Ice Age, the Maunder Sunspot Minimum
occurred (1640-1710) during which, the climate temperature was very low
and virtually no sunspots were observed. These scientific truths cast
severe doubts on current suspected climate change proposed corrective
actions, such as CO~2~ sequestration or abandonment of a carbon based
economy. In addition, the references cited in the paper clearly
demonstrate CO~2~ is not causing climate change.

**Introduction**

The earth's climate forever changes in a predicable cyclic manner,
apparently dictated by solar activity, Bond et al. (2001). We know
Romans recorded climate warming between 200 BC and 600, AD, Lamb
(1977a). In Europe, between 600 and 1300 AD, the Medieval Warming
occurred. The Little Ice Age (1300 to 1850 AD) is dramatically
documented by tax records of the abandonment of Greenland by the Norse
population in about 1300 after nearly 300 years of moderate
temperatures, when farming prospered.

**Weather History**

**Ice Core Records**

Dansgaard and Oeschger during 1983cored the ice sheet of Greenland.
Dansgaard, et al. (1984) reported a link between climate cycles and sun
activity. The link shows a moderate cyclic variation in ambient air
temperature with time. The original analyses of ice cores gathered from
coreholes spanning 900,000 years suggested a repeating cycle lasting
about 2,500 years. Based on more research this periodicity was revised
to 1,500 years ±500 years by Bond (1997). The ice core temperature
analyses are based on the ratio of oxygen--18 to oxygen--16 at the time
the snow was laid down. This ratio is not time impacted. Ice core
analyses showed persistent temperature cycles within cycles, Singer and
Avery (2007a). These cycles make weather modeling extremely difficult
and complex, even with modern computers.

**Tree Ring Data**

Tree ring analyses from long living Pakistani trees confirm ambient
temperature warming from AD 800 to 1,000 and cold temperatures from AD
1,500 to 1,700, Esper, et al. (2002). These findings compare favorably
with ice core data.

**Written History**

Lamb (1977b) documented climate change history for the past 1,000 years.
Romans (30-60 AD) reported grape cultivation advancing slowly northward
in Italy. This history shows both grapes and olives growth receded as
the ambient temperature changed (decreased). Lamb (1977c) discusses the
cold temperature history reported in Europe during the 1500's AD. This
history correlates well with the severe change in Greenland temperature
causing the Norsemen to evacuate Greenland.

**Sun's Irradiation**

Perry and Hsu (2000) using a solar-luminosity model based solar-related
isotopes-variations scanned 90,000-year glacial cycle. They observed
excellent correlation using carbon-14 variations and carefully dated
tree rings data as far back as the Medieval Warming (900-1300 AD). They
extrapolated findings to 90,000 years using the correlated model. Soon
(2005) shows how well solar activity correlates with arctic temperature
during the past 130 years and how poorly CO~2~ correlates arctic
temperature, **Figure 1**. The temperature data comes from Polyakow et
al. (2003) using arctic station measurements, while the solar activity
data comes from five databases. Willson (2003) reports the sun's
radiation increased by nearly 0.05 percent from the late 1970s based on
25-year record assembled by NASA. The cited trend is significant,
because the total energy output of the sun is enormous. Willson cannot
support the data before 1978, but he says, if the trend persisted during
all of the 20^th^ century, the increase in solar activity would produce
"a substantial component" of the observed climate temperature increase.

**Climate Warming**

The Earth has warmed since 1850. The highest temperatures were recorded
in the late 1930s, Figure 1. During the late 1930s, the increase in
temperature was rapid, e.g., 2.5ºC in 20 years in the Arctic region. No
one recognized the worldwide temperature increase, except the farmers,
who took advantage of the warming, by expanding their agricultural areas
to the north, just as the Romans did during the Roman Warming. Also, the
population increased, because of the abundance of food.

Good correlation between solar activity and arctic temperature is seen
in Figure 1. Galileo first collected sun spot data in 1609. Therefore,
we have data substantiating Maunder Solar Minimum, the coldest period
(1645-1710) of the Little Ice Age, when sunspots were at low ebb.

Now, there is discussion regarding capturing and sequestering CO~2~ as a
means of mitigating climate temperature increase. Sequestration would be
an expensive mistake if the climate change is the result of solar
activity. In addition, having to compress CO~2~ from atmospheric
pressure to injection pressure is energy intensive. The U.S. will have
great difficulty providing the additional energy, if the 25-year
moratorium on domestic drilling and producing continues. Further,
objection to building nuclear generation plants may prevent providing
the needed power. Lack of power could cause a repeat of the California
rolling blackouts of 2001, but this time on a massive scale. Even wind
turbines may not help, because the wind does not always blow and an
adequate power grid to move the electricity is not available. We are
experiencing this situation now (2008) in Texas, where wind turbine
generated power cannot be introduced into the distribution system
because of lack an adequate grid to serve the wind turbines.

Some concerned citizens raise the specter of sea level rise as a result
of climate increase. Singer and Avery (2007c) state the sea level for
the last 5,000 years has risen at the rate of about seven feet per
century. On the other hand, during the last century, tide gauges show
the sea level has raised about six inches, in spite of the recorded high
temperatures from 1916 to 1940, Figure 1. Accordingly, except in very
low-lying areas, sea level rise does not appear to be a major concern.

**Climate Cooling**

The possibility of climate cooling raises interesting questions, e.g.,
what is the desired climate temperature, when do we know when the
optimum temperature is attained, were the temperatures of the late 1930s
or temperatures of the 1870s the desired levels? Warming produces
abundant crops, increased area of agricultural viable land and moderate
sea level rise. On the other hand climate cooling reduces crop yield,
reduces useable land, and more importantly, climate cooling will
increase need for additional energy for home and building heating. Also,
freezing weather kills far more humans and animals than warm weather.
Interestingly, on 23 March 2008, the Hadley Climate Research Unit in
Britain, the NASA Goddard Institute for Space Studies in New York, the
Christy Group at the University of Alabama, and the Remote Sensing
Systems, Inc. in California reported global temperatures decreased 0.7°C
during 2007, The Australian, 2008. The reported lowered climate
temperature is reflected in decrease solar activity, **Figure 2**.

**Lack of Experimentation**

There are no scientific data, experiments or hypotheses demonstrating
climate change results from greenhouse gases generation. IPCC modeling,
Houghton, et al. (1995), demonstrates exaggerated computer predictions
of climate change from 1978--1998 when compared with field measured
temperatures for the same time period between latitudes 83 N and 83 S,
Robinson (2007b). Shindell and Schmidt (2004), based on observed trends,
predicted global warming would cause the Southern (Hemisphere) Annular
Mode (SAM) to become neutral, thereby markedly reducing polar cooling.
This situation has not occurred, in fact the highest arctic temperature
occurred in the 1930s, Przybylak (2002), Polyakov (2002). Also,
Antarctic temperatures are decreasing and the ice caps are thickening,
Taylor (2006).

**Weather Predictions**

**The Intergovernmental Panel on Climate Change (IPCC)**

The Intergovernmental Panel on Climate Change (IPCC) was formed in 1988
as a body of climate scientists interested in furthering knowledge of
weather behavior. These scientists published peer reviewed technical
weather assessments. For example, the 1996 IPCC "Second Assessment"
provided a graph showing "The Last 1,000 Years of Earth Temperatures
from Tree Rings, Ice Cores and Thermometers" (Figure 22, IPCC Climate
Change, 1996), **Figure 3**. This graph clearly shows the Medieval
Warming (900 -- 1300 AD) and the Little Ice Age (1300 -- 1850 AD).

The 2001 assessment prepared by the IPCC Executive Committee, a group of
policymakers, rather than scientists, Horner (2007a), displayed a
totally new rendition of Figure 3; the 1996 technical data and plot.
Instead of an accurate assessment of historical temperature trends, the
new graph, **Figure 4**, eliminated the last 1000 years of temperature
variations and historical records, Mann (1998). The 2001 version of the
historical data, Figure 4 portrayed the past 1,000 year of temperatures
as an almost straight line having an obvious, consistent and abrupt
upward curve starting at the end of the Little Ice Age, e.g., the
so-called "hockey stick" graph (Figure 2.20, IPCC Climate Change, 2001),
Mann, (1998). The hockey stick graph ignores the Medieval Warming Period
and the Little Ice Age.

**2001 IPCC Data Review**

McIntyre and McKitrick (2003) reviewing the Mann data observed critical
data correlation errors, e.g., unjustified truncation of data, use of
obsolete data, calculation errors and quality control deficiencies in
the data and statistics. McIntyre and McKitrick using a corrected set of
Mann data showed the "Hockey Stick" interpretation is wrong. Erroneous
graphical data sponsored by IPCC Executive Committee and computer
simulations by Houghton, et al. (1995) resulted in frightening the
uninitiated public to near hysteria.

The IPCC (2001) included the Hockey Stick graph in their Executive
Committee Assessments. Further, IPCC advocated the Kyoto Protocol even
in the face of Ice Core data demonstrating long trending temperature
cycles. In contrast, Robinson (2007a), reports obtaining signatures of
18,000 (now report to be 31,000) American university degreed physical
science graduates opposethe Kyoto Protocol, which recommends limits on
greenhouse emissions. Interestingly, after the McIntyre and McKitrick
interpretation, IPCC report (2007) includes no mention of the Hockey
Stick graph.

A Global Warming Industry developed as a result of misinterpretation and
misreporting of climate change by IPCC, This industry finds government
financial assistance is readily available, if the research proposal, in
some fashion, suggests the research findings could be a solution to the
perceived Global Warming problem. Michaels (2006) reports "in the United
States the taxpayer outlay for so-called global change science is now in
excess of \$4 billion annually."

Based on the scientific findings of persistent and repeated climate
change cycles, the temperature records show the Little Ice Age stopped
in 1850. After that date, the climate temperature consistently
increased, except for an anomalous high in 1940. Frohlich and Lean,
(2002) show this temperature increase is due to solar irradiation. Also,
the analysis shows no significant increase of CO~2~ concentration
occurred with increased temperature, Figure 1. Carbon dioxide is a
lagging indicator of warming, Singer and Avery (2007b). The observed
CO~2~ increase is due to the ocean warming, which releases more CO~2~.
There is no question we have observed climate temperature increasing.
This temperature change is likely to be small. Robinson et al. (2007b)
estimate the increase will be about 4ºC.

**2007 IPCC Report**

The 2007 Intergovernmental Panel on Climate Change (IPCC) Climate Change
report
(<http://www.ipcc.ch/pdf/assessment-report/ar4/syr/ar4_syr_spm.pdf>)
generated considerable criticism from climate scientists, who claim the
report provides grossly inaccurate information as reported by the U.S.
Senate Committee on Environment and Public Works
(<http://epw.senate.gov/public/index.cfm?FuseAction=Minority.Blogs&ContentRecord_id=f80a6386-802a-23ad-40c8-3c63dc2d02cb>).
The Senate Committee said "Over 400 prominent scientists from more than
two dozen countries recently voiced significant objections to major
aspects of the so-called \"consensus\" on man-made global warming. These
scientists, many of whom are current and former participants in the UN
IPCC (Intergovernmental Panel on Climate Change), criticized the climate
claims made by the UN IPCC···".

This should raise concern regarding the validity of the newer IPCC
reports.

**Greenhouse Gases**

The greenhouse gas theory suggests emissions of greenhouse gases,
especially CO~2~, from human activities are causing heating of the Earth
beyond the levels of past climate variation, and creating serious danger
for the planet's ecosystems, IPCC (2007a). The theory has obvious flaws.

1.  CO~2~ changes do not account for the past climate variations,
    including the Roman Warming (200 BC -- 900 AD), Medieval warming and
    the Little Ice Age (1300 -- 1850), Figures 1 and 3. If CO~2~ were
    the cause of climate change, what would cause the presence or
    absence of CO~2~ to result in these past documented temperature
    variation over time?

2.  The Greenhouse Theory does not explain the recent temperature
    changes. Most of the observer climate warming occurred prior to
    1940, Figure 1 (top)**,** before there was much anthropogenic CO~2~
    in the atmosphere. In fact, the CO~2~ lags the temperature rise,
    Figure 1 (top); no increase in CO~2~ in the 1930s, when climate
    increase was observed. After 1940, climate temperature decreased
    until 1960, in spite of an increase in CO~2~ emissions. On the other
    hand, solar activity tracks Arctic temperature well, Figure 1
    (bottom). Bond (2001) states, "···over the last 12,000 years
    virtually every centennial time-scale increase in drift ice
    documented in our North Atlantic records was tied to a solar
    minimum." The regularity and correlation of temperature increases
    and drift ice occurrences with solar activity demonstrate the
    interaction of these observations.

3.  The increase in CO~2~ concentration has not produced the increases
    in atmospheric temperature predicted by the computer models over a
    20-year-period. The Earth's surface temperature has warmed more
    rapidly than the temperature of the lower atmosphere up to 30,000
    feet. The Greenhouse theory states the "lower atmosphere" will warm
    first. This disparity places the Greenhouse Theory in serious
    question.

4.  CO~2~ is a lagging indicator by about 600-800 years, of climate
    warming for the last 240,000 years, e.g., warming produces CO~2~
    rather than CO~2~ producing warming, Singer and Avery (2007a).

5.  The Greenhouse Theory predicts CO~2~--driven warming of the Earth's
    surface will start, and be strongest at the polar the regions. This
    is not happening. Horner (2007b), Taylor (2006). Polyakov (2002)
    supports lack of pole warming by showing no pole temperature
    increase and perhaps, a slight temperature decrease in the arctic
    since 1937.

One of the reasons the greenhouse gas theory is flawed is computer
programs do not consider other greenhouse gases. For example, water
vapor is a strong greenhouse gas, e.g., the atmosphere contains nearly 2
percent water (compared to 0.037% for CO~2~). Water vapor is responsible
for about two-thirds of the natural greenhouse effect. Modeling water
vapor in climate-change models is very difficult and currently is
rudimentary. In fact, the Environmental Protection Agency did not
include water vapor in the 1990-2006 Inventory of U.S. Greenhouse Gas
Emissions and Sinks, EPA (2008). EPA stated water vapor was too
difficult to inventory.

**Discussion**

# IPCC Executive Committee abrogated its contract to provide useful, forward-looking climate information. Instead, the IPCC Executive Committee ignored peer-reviewed climate science and, in some cases, knowingly and willingly refused to correct erroneous data previously published, e.g., Hockey Stick Graph. The greenhouse gas misconception fostered by the IPCC Executive Committee led to the Kyoto Treaty. This treaty is now languishing because, most participating nations cannot, without causing havoc to their country's economy, achieve the greenhouse gases reductions proposed by the treaty. In July 2008, the major industrialized countries abandoned the Kyoto treaty by agreeing to half the greenhouse gas emission by 2050, [**http://www.foxnews.com/story/0,2933,377622,00.html**](http://www.foxnews.com/story/0,2933,377622,00.html).

The concept of reducing greenhouse gases to mitigate climate change is
hopeless task, if temperature change is the result of solar radiation,
as the scientific community shows. We observe energy wasting by
well-meaning persons and companies trying to sequester CO~2~ by
underground injection, OSPAR,
<http://www.ospar.org/eng/html/welcome.html>. Gas compression is energy
intensive. CO~2~ is a minor greenhouse gas compared with water vapor or
methane. Elimination of CO~2~ will not prevent climate temperature
increases. Svante Arrhenius (1895) showed a reduction in CO~2~ down to
about 60 percent of the concentration of atmospheric CO~2~ existing at
the time of his calculations, would have been necessary to cause the
Little Ice Age. Ice core gas analyses show such a drastic reduction in
CO~2~ did not occur. Thus, we can conclude, CO~2~ is not a major actor
in climate change. On the other hand, good correlation exists between
solar activity and climate change on earth, Figure 1.

The current climate-warming scare has fostered an entire industry
seeking financial grants for weather related research. Also, there is
developing a need by industry to show the public their commitment to
mitigate climate temperature increase by reducing greenhouse gases.
There is or was a move towards emissions trading. Kyoto Annex I Parties
can trade emission, at a price, to satisfy the protocol. Unfortunately,
if a problem exists, emission trading simply allows the emissions to
enter the atmosphere, rather than a reduced emissions quantity. This may
no longer be a problem since, for the most part, the EU is unable to
achieve the Kyoto prescribed reductions and the Kyoto protocol will most
likely dissolve in 2012 and the 2008 proposal to reduce CO~2~ by 50
using unspecified methods will be substituted for Kyoto. Proposals to
reduce greenhouse gases will result in increased cost of doing business,
which will be passed onto the consumer without affecting climate change.

The carbon tax is another remedy being proposed to reduce CO~2~
emissions. Such collected taxes likely will be spent on ill-conceived
projects. Congress spent billions of dollars on Synfuel Projects during
the 1970's, but provided no economic viable synthetic fuel.

Even when politics is not involved, there is little agreement between
opposing groups. In this regard, your attention is directed to Appendix
A of the 1 October 2006 New Zealand Climate Science Coalition at
[http://nzclimatescience.net2.php?option=com-content&do-pdf=1&id=20]().
The report is a response from the Coalition to Dr. Wratt (listed author
of IPCC Assessment Reports), who took issue with the Coalition's
statement "the science \[of climate change\] is not settled" regarding
the issue of anthropogenic activities. Further, The Oregon Institute for
Science and Medicine (2008) announced 31,000 physical science university
degreed professionals, including 9,000 PhDs signed a petition stating
climate change is not the result of anthropogenic greenhouse gasses.
This demonstrates the magnitude of the disagreement.

There are no experimental data supporting CO~2~ causes climate change.
On the contrary, Jones et al. (1986) developed an 11 year running
average of terrestrial Northern Hemisphere temperature as deviations
from the 1951-1970 mean temperature for the period 1750-2000 AD. These
data are compared by Baliunas and Soon (1995) with solar magnetic cycle
length in years. The resulting match of climate change vs. solar cycle
length is almost perfect, Robinson, (2007a, Figure 4), Figure 1.

**Conclusions**

1.  The earth's climate temperature is increasing.

2.  The temperature change is a natural, cyclic occurrence driven by
    solar activity,

3.  There are no experimental hypotheses and supporting data
    demonstrating greenhouse gases causes climate change. On the
    contrary ice core and tree ring data show climate change is a
    long-term cyclic occurrence.

4.  Controlling anthropogenic greenhouse gases, including CO~2~, will
    **not** stop climate change, if the climate change is due to solar
    activity.

5.  The most convincing hypothesis and supporting data demonstrate the
    earth's cyclic temperature change results from solar activity

**Recommendations**

1.  Encourage governments to establish laws based on science.

2.  Discourage governments and research groups appropriating and
    spending tax monies on inappropriate anthropogenic climate change
    experiments.

**References.**

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Baliunas, S.L., and W.H. Soon (1995). Are variations in the length of
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Bond, G., 1997. "A Pervasive Millennial Scale in North Atlantic
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Bond, G., et al., 2001. "Persistent Solar influence on North Atlantic
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Research letters* 31: L18209.

Singer, S. F., and D. T. Avery, 2007a. "Unstoppable Global Warming every
1,500 years." Rowman & Littlefield Publishing, Inc. 11

Singer, S. F., and D. T. Avery, 2007b. "Unstoppable Global Warming every
1,500 years." Rowman & Littlefield Publishing, Inc. 23

Singer, S. F., and D. T. Avery, 2007c. "Unstoppable Global Warming every
1,500 years. Updated and Expanded" Rowman & Littlefield Publishing, Inc.
8

Soon, W. (2005). Geophysical Research Letters **32**, 2005.

Taylor, George H., 2006. "Antarctic Temperature and Sea Ice Trends Over
the Last Century --An Assessment of Antarctic Climate Trends."
<http://icecap.us/images/uploads/antarctica_white_paper_final.pdf>

The Australian, 2008.
<http://www.theaustralian.news.com.au/story/0,25197,23612876-11949,00.html>

Willison, Richard C., 2003. "NASA Study Finds Increasing Solar Trend
That Can Change Climate." Goddard Space Center "Top Story," press
release 20 March.

![](media/image2.wmf){width="3.192361111111111in" height="5.4in"}

![](media/image3.png){width="3.0069444444444446in"
height="1.6083333333333334in"}

> **Figure 2. Solar Cycle Prediction**

<http://solarscience.msfc.nasa.gov/predict.shtml>

> **Figure 1**. Carbon Dioxide and Solar Activity Arctic Temperatures. .
>
> Horner (2007b) p146. Courtesy of Dr. Willie Soon

![](media/image4.wmf){width="3.125in" height="1.7333333333333334in"}

> **Figure 3. Climate history for the last 1,000 years.**

![](media/image5.wmf){width="3.3833333333333333in"
height="2.285416666666667in"}

> **Figure 4. The 2001 IPCC Report "Hockey Stick"**