Signature Sponsor
The Social Cost of Carbon, A CO2 Ambient Air Standard, CO2 As an Air Toxic: None Can Stand as None are Legal Nor Sound





By Fred Palmer, Senior Fellow – CO2 Policy, Center for the Study of CO2 and Global Change and Head of Saving US Coal


Fred Palmer

April 7, 2021 - Politico reported yesterday that environmentalists are “pulling out all the stops” to push the Biden Administration to aggressively move on climate change. Per Politico, recommended measures from the Greens under the Clean Air Act include EPA setting a National Ambient Air Quality Standard for CO2 and also listing CO2 as a hazardous air pollutant requiring Maximum Available Control Technology (MACT) for continued production to go forward. These recommendations show once again that logic has never stood in the way of the Greens in their zeal to eliminate the use of coal, oil and natural gas. President Biden’s recent embrace of the Obama Social Cost of Carbon (SCC) shows the US Government is capable of massive illogic as well when it comes to “climate change”, using the SCC as an affirmative change agent in ultimately eliminating the use of fossil fuels.


CO2 National Ambient Air Quality Standard


A CO2 national ambient air quality standard unique to the US is physically not achievable by a collective national effort since every human on earth generates CO2 emissions and breathes the same air on the same planet with resulting same CO2 emissions also from fossil fuel use, no matter what the US does. I am sitting in Old Town Alexandria, Virginia as I draft this. The CO2 content of the air here is the same as Beijing, London, Paris, Ulaanbaatar and Sidney and always will be. These are places my life in coal have taken me often and all places that I love. If we eliminate all fossil fuel use in the US with no CO2 emissions, and China-led Asia and developing Africa maintains and more likely increases CO2 emissions in a people concentrated part of the world where the Chinese economy dominates, the CO2 content of our air will be higher and the same as theirs no matter what we do here with respect to fossil fuel use. This is a scientific result engraved in stone that the US and Greens can’t control and therefore is something the Greens have a hard time understanding as their thinking is entirely agenda driven.

CO2 As an Air Toxic


As to the Greens’ idea that CO2 is an air toxic: this is bizarre, and again logic is discarded to achieve an unachievable agenda of eliminating the use of fossil fuels. CO2 is a benign gas required for all life on earth, starting with humans and moving down the food chain including the biosphere, agriculture, animal life, all aquatic life and all other living things. Logical people like farmers and greenhouse operators understand that CO2 is a nutrient and that use of CO2 in a greenhouse allows more vigorous plant growth, more food and more wealth because of, not in spite of, CO2. Not to mention that we all exhale it, including the Greens.


On April 22, 2020, Earth Day and my birthday, Craig Idso, Frank Clemente and myself filed a second petition with EPA for summary dismissal of a filing by Food and Water Watch and other groups to declare CO2 an Air Toxic with MACT imposition resulting. We did so on behalf of the Center for the Study of Carbon Dioxide and Global Change and it is a sequel to our first filing on March 9, 2020 seeking repeal of the 2009 EPA CO2 Endangerment Finding. All of our work is featured at (Saving US Coal) and also can be found at All of our work embraces rock solid observation based scientific conclusions looking at and understanding the real world, as opposed to the virtual and conjectural world of EPA and of the Greens generated from faux computer models.


The Social Cost of Carbon


The concept of the Social Cost of Carbon (SCC) was invented by the Greens in their virtual world and is a measure 100% designed to assign phantom costs to fossil fuel use to eliminate such use. The SCC was adopted by the Obama Administration, ignored by President Trump and recently resurrected by President Biden immediately following inauguration in late January. Per Politico again, the reinstatement “will make it easier for his agencies to approve aggressive actions to confront climate change”. Another way of saying this, is that the SCC is an additional, important tool for efforts to begin weaning all of us from the use of coal-based electricity, oil and natural gas use by making such use expensive and ultimately scarce. The intended result is to forbid societal access to massive US fossil fuels’ holdings and withdrawal of permission to move goods in interstate commerce.


As CO2 is a prerequisite for human life on earth, SCC is absurd on its face and it is disproved by all recorded human development history. To understand this, first understand that the numbers are based on computer models which in turn are based on future climate scenarios generated by flawed, flux adjusted computers; neither are based on empirical data-based observations nor reasoning. Stated otherwise, the SCC models are based on the infamous climate models that run hot, are continually adjusted to get the desired answer and are always changed with a warming bias when the climate apocalypse thesis is drawn into question.


Today the concept of potential catastrophic global warming, aka “climate change”, is an untenable thesis based on observations. The UAH Satellite-Based Temperature of the Global Lower Atmosphere (version 6.0) now is back to the temperature baseline starting in 1979 as shown at the web page. The lack of alarming warming over these past 40+ years is hard evidence that CO2 will not cause a climate apocalypse. Atmospheric CO2 content in 1979 was 334 ppm and in 2020 was 414.34 ppm, 24% higher.


Over that same 40-year period there is a 100% correlation of higher atmospheric CO2 content with a greening earth and with more people living better and living longer in the United States and abroad through fossil fuel use. As these simple facts show, the SCC is flatly inconsistent with and disproved by actual human development and success:


US GDP 1979 $2.6 trillion … US GDP 2020 $21.4 trillion

US 1979 life expectancy 73.8 years . . . 2020 life expectancy 77.8 years (losing 1 year due to Corona virus)

People on Earth 1979 3.4 billion

People on Earth in 2020 7.79 billion


During the period, when fossil fuel use exploded in the 20th century, the global human population saw its greatest increase in known history rising from 1.6 billion in 1900 to over 6 billion in 20000.


In the SCC world, the Biden Administration ignores powerful human development history and projects phantom CO2 costs at $51/ton, the present number, on its way to $80/ton per rumors. According to SCC theory, we didn’t become richer or live longer over the last 120 years as atmospheric CO2 content increased: we suffered because of the massive increase in annual CO2 emissions. It was Groucho Marx that purportedly said “who are you going to believe, me or your own lying eyes”. That fits nicely here.




Many reading this are concerned about CO2 emissions from fossil fuel use, even those in the business. Many reading this have adopted corporate policies of decarbonization and an ESG policy embracing such policies as a path to sustainability long-term. Many reading this are for carbon capture and geologic storage as well as use. President George W.H. Bush was concerned about CO2 and adopted a policy of no regrets. President Bush funded the FutureGen initiative and I was involved with that for Peabody Energy. Also, while at Peabody, China installed GreenGen near Tianjin on the Boahai Sea with CCUS from a gasifier and I was privileged to consult with the management there.


But being in the “do something” camp about CO2 doesn’t mean you have to accept the SCC initiative or the attempted distortions of the Clean Air Act and the EPA mission by the Greens. The three policies discussed here are in our view anti people, not pro people, and they must be resisted at EPA and ultimately in the courts. If they become hard law, fossil fuels will become a thing of the past in the United States independent of any Congressional action.


To win, the Saving US Coal Team as found at needs to be involved and we are ready to go. We are coal centric of course but as President Kennedy said about immigration to the US, “we came over on different ships but we are all in the same boat”. And as I like to say, if we make the world safe for US Coal we make the world safe for democracy, as well as oil and natural gas.