Jun. 12, 2022
Well done. Thank you. It is dangerous to be right in matters where established men are wrong.--- Voltaire Gregory R. Wrightstone Executive Director CO2 Coalition 1621 N. Kent St. Suite 603 Arlington, VA 22209 I submit the following comment on the SEC proposal for an ESG rule. E. Payne Kilbourn, Neavitt, MD Author of "Elements of Climates." Professional Engineer. Comment: Any rule mandating carbon dioxide related reporting is predicated on flawed research and unscientific theorizing. Any such data compiled would serve no rational purpose. In the late 1980’s the United Nations chartered the International Panel on Climate Change to coordinate research on earth’s climate. Around the world, the climate research community began building computer models, encouraged by the experience of meteorologists in using computer models to understand weather and to make increasingly better weather forecasts. Experimental testing being impossible, the approach to modeling rested on drawing inferences from two measurable trends: rising levels of carbon dioxide and increasing temperatures. The former is specific and the measurements are precise. The latter is neither. Nonetheless the climate research community somehow concluded that a representative average temperature could be compiled. That left creating models that would validate the idea that carbon dioxide was responsible for rising temperatures. As the models grew more inclusive of other variables that influence atmospheric dynamics it was anticipated that the unknown but hypothesized relationship between carbon dioxide and temperature trends could be better understood. This has yet to be the case. There are simply too many dynamics occurring over different time scales that act to create local or regional climates. To ascribe dominance to the phenomena surrounding thermal radiation as the prime driver of climates is the basis of climate models. It is not scientific. It is a guess. Somehow confident that the guess is correct, the IPCC models have been adjusted to validate the guess. The basis of the guess was an idea: radiative forcing. Because it was known that carbon dioxide absorbed and emitted infrared radiation, it was postulated that more carbon dioxide would absorb and emit more thermal infrared radiation and would raise the temperature of the atmosphere. Next, it was postulated that a warmer atmosphere would cause more ocean water to evaporate. Because water vapor is a very strong absorber and emitter of thermal infrared radiation, it was further postulated that this would act as a positive feedback mechanism to multiply the effect of more carbon dioxide. The radiative forcing concept has not, and essentially cannot be validated scientifically. Further, the string of postulates that it contains cannot be correlated and thus are unprovable as causation. The assertion of the International Panel on Climate Change that upon reaching a given amount of carbon dioxide in the atmosphere the average temperature will reach a specific number is a computer numerical modeled projection that is not founded on experimental results or proof. This conclusion is not merely mine. It is also the conclusion of the IPCC Working Group One chartered to assess the physical scientific basis of the climate system. However, for whatever reasons, this conclusion is not noted within the recent IPCC Reports for Policymakers. I urge the SEC to revisit the unscientific basis for the political climate change narrative and to reject the mandates for American businesses to make wasteful and unnecessary reports on carbon dioxide environmental disclosures.