Jun. 19, 2022
Submission for File No. S7-10-22 The Enhancement and Standardization of Climate-Related Disclosures for Investors AGENCY: Securities and Exchange Commission ACTION: Proposed rule. The following arithmetic and measurements illustrate that this proposed regulation is a waste of money and effort. This illustration uses only high school arithmetic and measured CO2 data from the joint NOAA-Scripps Oceanographic Institute at Mauna Loa, Hawaii. It does not use theory, estimates, statistics, computer models, opinion or belief. This is fact and experimental evidence showing that human-produced CO2 is no danger. The late esteemed physicist Richard Feynman frequently reminded us, “If it disagrees with experiment it is wrong. In that simple statement is the key to science. It does not make any difference how beautiful your guess is. It does not make any difference how smart you are, who made the guess, or what his name is – if it disagrees with experiment it is wrong. That is all there is to it.” (Feynman, 1965) In the 2 years following the June 15, 1991 eruption of the Pinatubo volcano, the natural environment removed more CO2 than the entire increase in CO2 concentration due to all sources, human and natural, during the entire measured daily record of the Global Monitoring Laboratory of NOAA/Scripps Oceanographic Institute (MLO) May 17, 1974 to June 15, 1991. Then, in the 2 years after that, that CO2 was replaced plus an additional increment of CO2. The calculated the mass of net CO2 removed from the atmosphere based on measurements taken by MLO are used herein with the Specific Impulse calculation, a standard physical calculation used daily in life and death decisions. There are no theories, estimates or computer models involved in these calculations. The following calculation is a very conservative demonstration which makes it obvious that human CO2 is not increasing global CO2 concentration. Since humans cannot change the CO2 concentration in air, requiring corporations to monitor CO2 concentration and report it to shareholders is futile and counterproductive. The average slope of the CO2 concentration in the pre-Pinatubo period in MLO data was 1.463 ppm/year. Slope is the rate of change of the CO2 concentration. The rate of change and slope of a CO2 concentration with respect to time elapsed are identical to the commonly known terms velocity and speed. According to MLO, the CO2 concentration in the atmosphere on June 15, 1991 was 358 ppm. 1 ppm CO2 in air = 7.76 GtCO2. Thus 358 ppm * 7.76 GtCO2 = 2778 Gt CO2 in air on June 15, 1991. The mass of CO2 in the atmosphere on June 15, 1991 per MLO was 2778 GtCO2. This is the measured mass of all CO2 in the atmosphere, there is no human residual. (Note this is not GtC, i.e., gigatonnes of carbon. GtC and GtCO2 are not equivalent. This is GtCO2,, i.e., gigatonnes of CO2. MLO measures micromoles CO2 per mole of dry air, which is ppm, not ppmv. Ppm and ppmv are not equivalent.) Slope is calculated with MLO data as follows: MLO began reporting daily CO2 data on May 17, 1974 and on that day reported 333 ppm. Not including May 17, there were 6238 days between May 17, 1974 and June 15, 1991. MLO velocity (i.e. slope) = (358 – 333 ppm)/6238 days = 0.004008 ppm per day On June 15, 1991, the velocity of 2778 Gt CO2 = 1.463 ppm per year * 7.76 GtCO2 per ppm = 11.35 GtCO2 per year. Then 11.35 GtCO2 per year divided by 365 days per year = 0.03 GtCO2 per day. On June 15, 1991 net global average atmospheric CO2 velocity was 0.03 GtCO2 per day. This is the measured daily rate of change of total atmospheric CO2 concentration from all sources on June 15, 1991. On April 22, 1993, GtCO2 velocity was 0.62 ppm per year. Then 0.62 * 7.76 GtCO2 per ppm = 4.81 GtCO2 divided by 365 days = 0.0132 GtCO2 per day. On April 23, 1993 net global average atmospheric CO2 velocity was 0.0132 GtCO2 per day. This is the measured daily rate of change of total atmospheric CO2 concentration from all sources on April 22, 1993. CO2 concentration had decelerated rapidly since June 15, 1991. CO2 velocity continued to decline after April 22, 1993. June 15, 1991 was the start of the major Pinatubo volcanic eruption and April 22, 1993 was the date of maximum deceleration in net global average atmospheric CO2 concentration after Pinatubo, reported in the daily measurement record of MLO. t = 677 days from June 15, 1991 to April 22, 1993 (not including April 22.) Initial velocity u = 0.03 GtCO2 per day Final velocity v = 0.01 GtCO2 per day Acceleration a = (v-u)/t a = (0.01 – 0.03)/677 days a = -2.95 * 10-5 GtCO2 per day per day The net force F on a mass equals the mass times the acceleration of the mass. (Newton’s 2nd law of motion. F = ma) As shown above, the net mass of CO2 in the atmosphere on June 15, 1991 per MLO was 2778 GtCO2. F = 2778 GtCO2 * – 2.95 * 10-5GtCO2 per day per day = – 0.082 Newtons F = the breaking power or force the environment exerted on the net CO2 mass in the air in response to the surface cooling that followed the Pinatubo eruption. The negative sign indicates the vector direction of the force. In other words, CO2 was being removed from the atmosphere. Impulse J = Force * time or J = Ft J = – 0.082 Newtons * 677 days = – 55.5 The impulse calculation tells us whether a car has enough braking force to stop before hitting the wall, or enough force to take the rocket into orbit before it runs out of fuel, or enough force to accelerate the loaded 747 to liftoff velocity before reaching the end of the runway, or enough force to overcome addition of human CO2 to air. The above calculation for Jn is for the total mass of net global CO2 in the atmosphere. Next, we want to compare that natural Jn to the Jh for the human-produced CO2 component. But, unfortunately we only have estimates based on theoretical assumptions and dubious sources for the human CO2 component. Therefore, instead of using these theories and estimates, we will now calculate an amount of CO2 that is clearly larger than the human CO2 component, that is, a not-to-exceed amount of human-CO2 is created. For avoidance of doubt, this not-to-exceed amount is more conservative than in Bromley and Tamarkin (2022). MLO began reporting daily CO2 data on May 17, 1974. On that day, MLO reported 333.38 ppm. On June 15, 1991, MLO reported 358 ppm. 358 minus 333 = 25 ppm increase in total CO2. This increase includes all CO2 in the atmosphere from all sources, human and natural. There is no residual human fraction. 25 ppm * 7.76 GtCO2 per ppm = 194 GtCO2 increase in CO2 For this comparison, attribute that entire increase in MLO CO2 since the daily record began to humans. This amount was measured by MLO and we know this amount exceeds the actual human CO2 component. The average velocity for the pre-Pinatubo period in the MLO data set is 1.463 ppm per year. Converting that amount to GtCO2 we have 1.463 * 7.76 GtCO2 per ppm = 11.35 GtCO2 per year. For this comparison, assume this entire amount is due to humans. 11.35 GtCO2 per year divided by 365 days per year = 0.031 Gt “human” CO2 added per day. Assume that human emissions did not slow following Pinatubo, even though total CO2 was decelerating precipitously. Thus: “human” CO2 mass m = 0.031 Gt “human” CO2 per day * 677 days = 21.05 Gt “human” CO2 added post Pinatubo. Adding: 194 GtCO2 “human” increase + 21.05 GtCO2 “human” added post Pinatubo = 215 GtCO2. “Human” emissions cannot exceed 215 GtCO2. Then m the mass of not-to-exceed (“human”) = 215 GtCO2 On June 15, 1991, the velocity u of 215 GtCO2 = 1.463 ppm per year * 7.76 GtCO2 per ppm = 11.35 / 365 = 0.031 GtCO2 per day. On April 22, 1993, 677 days later, final velocity v of “human” CO2 was the same 0.031 per day. But, to be more conservative in this comparison, let v = 0.041 GtCO2 per day. In other words, for this comparison, we are letting “human” CO2 grow faster than total CO2 was growing prior to the eruption even though on April 22, 1993 total CO2 was declining sharply. Thus, post-Pinatubo acceleration a of ”human” CO2 = (v – u)/t =0.01/677 = 1.48 * 10-5 GtCO2 per day per day F = ma (Newton’s 2nd law of motion. F = ma) F = 215 GtCO2 * (1.48 X 10-5 GtCO2 per day per day) = 0.0032 “Human” CO2 specific impulse Jh = 0.0032 Newtons * 677 days = 2.17 Jh = 2.17 is the specific impulse for our not-to-exceed “human” CO2 emissions. Comparison: § 2.17 for not-to-exceed “human” CO2 emissions § -55.5 for natural CO2 removal from atmosphere § – 25.6 / 1 is the ratio. The minus sign indicates the vector direction CO2 absorption. Removal of CO2 is over 25 times addition of CO2 by “humans” even when “humans” is conservatively calculated to include all sources of CO2 in the MLO daily measurement record prior to the Pinatubo eruption. In this conservative calculation, based entirely on measurements (not theory, not models, and not estimates), Earth’s environment demonstrated the capacity to absorb more than 25 times the not-to-exceed amount of human CO2 emissions at that time. The units drop out of the comparative calculation to yield a dimensionless 25:1 ratio. During the global cooling event in the 2 years following the Pinatubo eruption, CO2 concentration decelerated rapidly. Following that 2-year period, in the next 2 years CO2 accelerated more rapidly than it had declined, reaching an average CO2 slope which exceeded MLO-measured slope for the period prior to the June 1991 Pinatubo eruption. The maximum force of the environment to both absorb and emit CO2 could be much larger than the 25 times human emission and could occur much faster. We do not know the maximum force or specific impulse. But it is very safe to infer from this result that human CO2 emissions are not an environmental crisis. If a reason exists that the natural environment responds to human CO2 in a significantly different way, e.g., the commonly asserted belief that the environment absorbs half of human CO2, then the reader is invited to put forth that theory. The calculations and data presented here disprove that theory. Among other questions, the questions shouting to be answered are: where did that CO2 go? And, where did the recovery CO2 come from? But, we know it did come from humans. The data and graphs produced by MLO also show a reduction in slope of total CO2 concentration following the June 1991 eruption of Pinatubo, and also show the more rapid recovery of total CO2 concentration that began about 2 years after the 1991 eruption. This graph is the annual rate of change (i.e., velocity or slope) of total atmosphere CO2 concentration. This graph is not human CO2. Conclusion These are experimental results. Theory must explain these results, not the other way around. Regulations must be based in fact, not theory, not estimates, not statistics and not computer models which cannot be validated against fact. When CO2 slope and acceleration declined post-Pinatubo, why was there a recovery to previous slope? What causes the additional offset increase in slope? Those are theoretical questions to be answered in the future. But, dealing only in fact and experimental evidence diligently acquired by the U.S. government-funded NOAA laboratory, the decline and the recovery of CO2 concentration were definitely not due to humans or the biosphere. As we have shown in these simple calculations, CO2 from humans and biosphere combined are over an order of magnitude less than the CO2 absorbed by the environment and then re-emitted. That alone should end fears of CO2-caused climate crisis. The proposed regulations on greenhouse gases are not based on science and certainly not based on facts and experimental evidence. Signed (Author): Clare Livingston Bromley, III (aka Bud) References Bromley, B., & Tamarkin, T., 2022. Correcting Misinformation on Atmospheric Carbon Dioxide; Pinatubo Study Phase 1 Report. ClimateCite.org. https://pinatubostudy.com/pinatuboreport.html Or: https://budbromley.blog/2022/05/20/correcting-misinformation-on-atmospheric-carbon-dioxide/ Background on The Specific Impulse Calculation: https://youtu.be/ph48Xwj_eS8 Data source: Thoning, K.W., Crotwell, A.M., & Mund, J.W. (2021). Atmospheric carbon dioxide dry air mole fractions from continuous measurements at Mauna Loa, Hawaii, Barrow, Alaska, American Samoa and South Pole. 1973-2020, Version 2021-08-09. National Oceanic and Atmospheric Administration (NOAA), Global Monitoring Laboratory (GML), Boulder, Colorado, USA https://doi.org/10.15138/yaf1-bk21 Data Set Name: co2_mlo_surface-insitu_1_ccgg_DailyData. Description: Atmospheric carbon dioxide dry air mole fractions from quasi-continuous measurements at Mauna Loa, Hawaii.