Virginia Regulatory Town Hall
Department of Environmental Quality
Air Pollution Control Board
Regulation for Emissions Trading [9 VAC 5 ‑ 140]
Action Repeal CO 2 Budget Trading Program as required by Executive Order 9 (Revision A22)
Stage Proposed
Comment Period Ended on 3/31/2023
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3/31/23  1:26 pm
Commenter: Rick Ryan, Retired Mechanical Engineer

Water Vapor is the Dominant Greenhouse Gas, not Carbon Dioxide

I begin with conclusions then follow with rationale.


CO2 is not an existential threat.  It never has been and it never will be.  It is a harmless greenhouse gas (GHG), essential to plants, and by extension, to all life on earth.


Water vapor as steam ( humidity ) and condensed steam (clouds ) is the dominant GHG owing to its abundance in the atmosphere and the wide range of spectra in which it absorbs/emits infrared radiation.  CO2 absorbs radiation only in a very narrow wavelength range, 15 micrometers, of the infrared spectrum and is overlapped by the water vapor range.


The rush to decarbonize is a fool’s errand.  Aside from the fact that it is not feasible considering the enormity of replacing carbon based power generation with ruinously expensive wind, solar and batteries, all of which must be replaced every 20 or so years.


Wind and solar are intermittent.  Conventional backup power is needed to bridge the slack times, kilowatt for kilowatt.  If batteries supply the slack times, the acreage of the installation must be at least tripled because batteries must be charged at the same time wind and solar are supplying the grid, which averages only eight hours on a good day.


The climate change alarmists know that adding CO2 to the atmosphere is not an existential threat.  But, they need an object fatale to support their fabricated 97% consensus claim and CO2 fills that bill perfectly.  In order to garner public and institutional support, alarmists have added environmentalism as cover for their true purpose, end American capitalism.  Decarbonization fulfills that purpose by bankrupting the American economy, by dragging us into net-zero, the green new deal and the socialist new world order.  “You will own nothing and you will be happy.”


Virginia membership in RGGI is just a baby step toward meaningless decarbonization, but it opens the door to future more draconian policies, like following the climate policies of California.  Virginia must withdraw from RGGI and stop the increasing harm it portends.


Now some rationale


A Greenhouse Gas, GHG, consists of a molecule which contains three or more atoms and readily absorbs and emits infrared radiation.  Absorption of an infrared photon is a resonance phenomenon and causes the GHG molecule to vibrate: spin, stretch, rotate or bend, at the frequency of the absorbed photon.  Having only two identical atoms, oxygen, O2, and nitrogen, N2, are not GHG’s.  They do however weakly absorb some of the visible light spectrum coming from the sun.


Approximate concentrations of major GHG’s near the surface in parts per million, ppm:

Water Vapor  15,000 ppm or 1.5% of the atmosphere, more in the tropics, less over deserts and in the artics.

CO2       420 ppm or 0.042%, methane   CH4       1.8 ppm,

nitrous oxide          N2O       324 parts per billion.


GHG’s exhibit a property similar to the economic law of diminishing returns.  Each molecule of a GHG added to the atmosphere has less warming effect than the one added just before it.  The effect is called saturation.  As concentration increases, the added warming effect becomes vanishingly small.  About 450 million years ago, CO2 concentration was ~6400 ppm, or 0.64% of the atmosphere.  The earth did not become the burned out cinder.  To the contrary, chlorophyll containing plants flourished and produced the atmosphere we breathe today containing 21% oxygen.


Of the annual contribution of CO2 to the atmosphere, 95% is natural: volcanism, release from ocean and land reservoirs, animal respiration, only 5% is anthropogenic, mainly power generation, smelting metals and concrete.  Thus for 5%, the alarmists want to starve our economy of life and comfort giving energy.


Without GHG’s, the earth would be as cold and lifeless as Mars.  In conclusion, the property of saturation completely nullifies the alarmist extinction claim.

CommentID: 216117