In very simple terms, the reason is because of the permitting system itself. Once the state and EPA have approved a permit for construction and operation of a source, that unit is "grandfathered" from any further regulation unless the physical design and material flow of the source is changed to increase emissions.  

So as Carl Pope says, it then becomes an issue of how to allocate "allowances" to existing sources. Obviously you can't start with zero CO2 emissions you have to start with a number (cap) that can be reduced over time. This turns out to be quite a nightmare because CO2 has never been regulated under the Clean Air Act - unlike our experience with sulfur dioxide, oxides of nitrogen, reactive hydrocarbon (Houston area), and a failed Bush plan for coal power plant mercury.

FYI, it took several decades just to write all the industrial regulations in CFR part 60 relating to emission controls, and today EPA is still trying to adopt the requirements of the 1990 Amendments to the 1970 Act.  That's 37 years of regulation.

So if you're expecting 2-4 years of lead time to make all source sectors comply 100% with some kind of cap and trade system, I'd say you were thinking very wishfully. I am frustrated as well, but do see some promise that perhaps CO2 emissions will not grow all that much ... I do have problems with paper credits and allowances, however.  -sammie

Onward through the fog

The bigger problem may be compliance monitoring -- power plants have continuous emissions monitors, as I'm sure you know, but other industries don't, and I'm not sure if CEMs are practical for other important sources.  For example, some sources will have multiple emission points of different types (as opposed to a single stack at a power plant) -- that would make monitoring more complex.

Could someone out there (Sean?) shed some light on that?  

Use the same principle with other greenhouse sources. Tax or require permits as far upstream as possible. In some cases upstream and downstream are the same - cement plants, many f5 gases and so on.  

So it is an issue because not but a few very large industrial sources have automated CEM technology installed, continuous emission monitoring. Other methods are estimated, mass balance, AP-42 (an EPA "cook-book"), and empirical models (the latter used for mobile sources especially). The range of error with a CEM is one standard deviation but with the other methods it could be plus or minus 15 to 30 percent ... and I freely admit that as an emissions inventory planner and scientist,

So I guess I would have to say that unlike how the states and EPA have worked out measuring the traditional pollutants known as National Ambient Air Quality Standards (NAAQS), anybody who says we really know how much CO2 is being emitted today is full of baloney.  

The only saving grace is that some standardization has happened, so imperfect methods are used in a relative sense. This method is not good for absolute numbers but is OK for defining "rate of progress" as to reducing emissions but not for the purposes of establishing a cap.  /sam

Onward through the fog

The Bush administration will most certainly veto it. Is there any possibility that enough republican congressmen will sign on to make it veto proof?

As far as I know this is not a possibility, but I am open to listen to facts that say I'm wrong.

the pols feel out what they are confortable with, and, finally, commit themselves to something that they later have to defend.  A cautious process, but important because the pols slowly get locked into something specific

it shapes future debate (pols tend to stick to earlier positions unless extraordinary pressure occurs) and it gives visibility regarding where votes need to be changed to make process

until serious votes occur, the pols float free, supporting all vague good things -- even when those things are in tension, as a practical matter

so final passage of a law is not the only measure of significant progress

Fires cost billions of dollars but will soon lead to TRILLIONS of dollars when dealing with this problem in the way everyone here wants to commit to. Nobody figures in the losses to the environment when millions of acres burn at high intensity. Nobody wants to admit they were wrong in how we should manage our ecosystems. Everyone ignores the plumes of toxic gasses spewing directly into our atmosphere. I think it's a plot to completely ignore wildfires and both sides seem very willing to just let it burn, often at unnaturally high intensities.

Welcome to the Bush/Clinton/Gore Memorial Forest Legacy.

Scenic pics at http://Lhfotoware.blogspot.com

Remember, the Clean Air Act was signed by Nixon and the 1990 Amendments were signed George Bush 41. During these negotiations, democrats were able to push the vote, after making some concessions to industry. It could happen.

Will such a bill need to be fixed in the future?  Probably ... but so much work is needed to get done we have to start the paperflow now. Then, we would need a restructuring of the EPA to enable a new way of thinking, regulating, and creating incentives. I would like to add that participation of the states and locals if extremely important as well.  -sammie

Onward through the fog

In case nobody has noticed James Hansen has told us recently that we are past the tipping point for unavoidable positive feedbacks resulting in accelerated global warming. We have cracked the aquarium, dropped the basket, lit the big barbecue, melted the permafrost and the arctic ice cap.

Oh and this summer untold tonnage's of methane are going to go sailing up from Siberian and Canadian permafrost. Because it's not frozen, you see?

So whether you drive your plug-in Prius or Ford F-250 quad-cab diesel with turbo boost is pretty freaking moot as long as we keep burning coal, burning forests and dumping nitrates on fields.

We don't get "business as usual." That scenario is gone.

We don't get normal grain crops. We don't get freeze-thaw cycles in normal periods, we don't get productive fisheries, we don't get rain, wind or snow when or where we expect them. We get too much or not enough or both in the wrong seasons. We don't get tropical diseases staying safely in the tropics.

Now many of you have working and personal lives completely involved with purely artificial concerns like Second-life (?), Tivo, i-tunes, or completely artificial pharmaceuticals manufactured in completely artificial environments. I used to know somebody who kept plastic flowers in her garden and ate nothing but slimfast and Starbucks mochas. It doesn't cut it. Your comfy life is only possible because growing things, plants that is, manufacture an environment for you to live in that you can survive and thrive in. And the environment that supports those plants is increasingly infected by chaos. The biosphere that supports you is on the death watch.

So it really doesn't matter if you cut emissions in 2012, or 2014 or 2025 if what happens in the meantime is runaway climate change. We really should have gone to some sort of negative emissions profile sometime in the last ten years and should be clawing our way back to 300 ppm CO2 instead of rushing towards 400 ppm as we are now. What part of the phrase "dead oceans" do we not understand?

The point of this rant is this: Suppose somebody announced that he was going to legally kill your kids with a 30-06 rifle at a range of about 100 yards. He's getting paid to do this as part of a reality TV series. You beg and plead and point out the moral outrage of this act and he says "Well legislation is pending that will force me to take the shot from 150 yards and some real whackos are putting a bill out that says only past 175 yards but that will never pass."  You would still be outraged.

At 150 yards there is still enough energy in the system, the bullet, to kill your kids.  At 375 parts-per-million of CO2 there is still more than enough excess energy in the atmospheric system to kill your kids. If not them then maybe your grandkids. Average global CO2 is at least 383 ppm and climbing fast. If we're not carbon-negative we're not addressing the issue.


Put the Carbon Back

But you cannot address it in one fell swoop.

Cannot.

Votes are not there.

But we need to get started.  We need to make it seem "normal" to be concerned about climate, and to aggressively address it.

Then the struggle will continue for decades.

We may not win.

But the only way to start, is to start.

To insist upon what is necessary is to delay.

Blackcut, wildfires are a parta the natural system.  And wildfires (along with prescribed burns) are necessary in oredr to clear undergrowth, help fertilize the natural land, further decomposition, and help plants pollinate and spread.

In the plains and grasslands, many species have evolved with fire in mind.  In some cases, plants won't drop their seeds unless their lower protions are burned.  They've evolved alongside fire to the point that they "know" that fire will clear out underbrush and help fertilize the soil, so their seeds will have a better chance to grow.

To eliminate fire would be to eliminate that natural order.  It would actually wreack havoc on many ecosystems (and has done so already in areas where fire has been supressed).

Bush used the argument of pollution from fire to push for his forest management program...which involved bascially cuttin' down most of the mature growth in an attempt to stop fires.  The problem was fire usually affects undergrowth more than mature growth, and so of course he was just greenwashin' us to get more money for the timber industry.  

Asd you mentioned, there are losses to the environment whjen large areas are burned at high intensity...but the thing is that high intensity fires don't occur that often in the natural system.  Most wildfires in pristine areas are low intensity.  Many of the high-intensity fires that occur these days are the result of a build-up of flammable material that has occured over decades because most low-intensity fires were snuffed out by humans before they could cover much area.  Eventually, so much flammable material is built up that even minor fires will start to burn outta control.

If people had let most low-intensity fires burn themselves out naturally, then high-intensity fires wouldn't be nearly as much of a problem as they are today.

The best way to control fire is with fire...prescribed burns and just let low-intensity fires burn themselves out on their own whenever possible.

People understand that remote scenarios with very high failure costs require adjustments. In California we live in a network of fire, flood, earthquake and god knows what else emergency management networks. Because we take precautions most houses ride out earthquakes just fine. When we ignore the natural system most houses in front of a moving fire-line burn down.

You have to set the goals so that success is the target. A moderated failure just isn't acceptable. A reduced emissions profile by 2050 is just failure by comittee.

The solutions to providing most of the services people enjoy know at a zero carbon output exist. The one thing that we don't have an alternative is jet airline travel. Comfortable houses, medical care, a varied diet and interesting social lives are all possible using off the shelf hardware.

What we don't have are the memes that direct peoples attention to more comfortable alternatives to existing systems. The fault is in the software.

Put the Carbon Back

When you burn a gallon of gasoline the 16 (guessing here) pounds of CO2 created are there whether it the burn is in Ohio or Tibet. A representation of energy input vs. useful work can be understood and consistent.

When a certain number of dollars are spent on energy costs, say on a solar panel vs. a gallon of gas the dollar value of the energy output in work is a moving target. It is impossible to estimate the future dollar value of the solar panel's power because that value is a political football.

One of the failures of the current financial system is that it relies on mutually agreed fictions to operate. The most harmful fiction is the concept that individuals can acceptably profit while harming the community. Dollar values are not able to adequately express that harm. Carbon accounting can.

Put the Carbon Back

So, that means that we can't have very many "natural" fires and the acres of high-intensity fires has shot up markedly. THIS is definitely NOT natural. Obviously, our forest have gone well beyond the "tipping point" and we're seeing mortality that far exceeds both growth AND harvesting.

Also obvious, Tasermon, is that you're buying into the "party line" and not seeing the big picture. Afer decades of mismanagement from both ends of the spectrum, you can't just "preserve-away" all of our forest problems. The goal should be to have vibrant and resilient forests that harbor endangered species and that are drought, insect and fire resistant. You offer no solution to the spewing of toxic gasses directly into our atmosphere, the losses of endangered species habitat and fires that blaze uncontrollably off the National Forests and on to private lands, killing people and ruining lives. I'd be willing to bet that the Clinton Administration has cut more timber than the Bush Administration. "Healthy Forests" has been a failure, without the funding to make a tiny little dimple in the whole of the problem.

There's one thing that eco's and the Bush Administration agree upon regarding our forests.

Let em burn!!!

Scenic pics at http://Lhfotoware.blogspot.com

For example, the Tahoe Basin has at least one third of all the trees die in the early 90's and very little of that was harvested because of the outcry and emotion over cutting trees there. Today, those trees still remain on the ground waiting for the next inevitable lightning strike, vehicle accident or arsonist to catastrophically burn up "the Jewel of the Sierra". That material will never decompose into soil components, as the dry summers tend to preserve that dead fuel until the next fire. Then will see erosion and a loss of Lake Tahoe's clarity that has never been seen before in our history.

Welcome to the big picture, folks!

Scenic pics at http://Lhfotoware.blogspot.com

That being said, it's not so simple to say "full steam ahead". The windows in the fall to safely accomplish these burns are getting smaller and smaller, as air pollution control organizations are holding tighter reins over the Forest Service. Also, the requirements for keeping the burns "in prescription" are as tight as they have ever been. Burning in the spring isn't a very good idea, either. The fires need the winter rains to make sure that they are out before the next fire season.

Again we go to the Tahoe Basin where, a few years ago, they proposed doing their controlled burns in the summer, to avoid trapping the smoke under an inversion layer, pissing off the local rich folks. When the Los Alamos incident occurred, that squelched the plans for that scenario. I just returned from a weekend in Tahoe and saw firsthand the devastation caused by last summer's Angora Fire, which burned hundreds of home as it roared out of the National Forest and into a housing subdivision. Some people claim they deserved to be burned out, living in such a thick unhealthy forest.

Yes, we live in a sad time where unnatural forests are strictly preserved in all their flammable glory and people will sue to embrace these "natural and beneficial fires" which incinerate ecosystems to bare dirt that will erode and clog streams and rivers.

Welcome to the big picture!

Scenic pics at http://Lhfotoware.blogspot.com

Unlike other pollutants, with CO2 we're talking pretty big numbers that don't change a heck of a lot due to slight process variations.  A gas turbine electric plant for instance can have it's CO2 calculated pretty precisely just by looking at it's consumption of gas... no need really to do any stack monitoring.  Coal might be a bit trickier due to more variation in coal types, but the simplest approach would just be to routinely characterize batches of coal from particular mines and then charge electric plants or other facilities based on the amount of coal consumption using the appropriate carbon factor.  It's not absolutely perfect, but tracking fuel use would come pretty close to the same as measuring actual CO2 emissions.

Sam... what would be the drawback to doing it this way?