13 Feb 2010, 11:34am
Forestry education Saving Forests
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Zybach On Alseya

We have presented some important works of Anthropogenic Ecology, the study of historical human influences on the environment, in the W.I.S.E. Colloquium: History of Western Landscapes. Today we are pleased to present another seminal work in AE, The Alseya Valley Prairie Complex, ca. 1850: Native Landscapes in Western GLO Surveys by Dr. Bob Zybach [here].

The Alsea [the common spelling, but Alseya is more euphoniously accurate] Valley lies in the Coast Range between Corvallis in the Willamette Valley and Waldport on the Pacific Ocean. The name of the valley refers to the Alsi, or Alseyah, or Alciyeh Indians that were resident there for 4,000 years or more prior to fatal contact with European diseases. The Alseya prairie complex refers to the culturally-modified landscape tended and cared for by the Alseya people over those millennia.

Today Alsea is a typical Oregon rural community, a small town center with rural homes, farms, fields and pastures, and a thick Douglas-fir forest blanketing the hills. Surprisingly, perhaps, the Alsea Valley has been thus for thousands of years, with the exception of the Douglas-fir thicket.

Over past few dozen centuries, the Alseya Valley has been a bustling community with fields and roads, much like today. The Alsi people were traders and merchants, as well as farmers. Their landscape was modified by anthropogenic fire which served to create and maintain an anthropogenic mosaic, a landscape that served the needs of the residents far better than dense forest.

Evidence indicates that in the 1850s, the time of initial White settlement in the area, the Alseya Valley existed as a series of prairies, brakes, balds, openings, patches and meadows connected by a network of foot trails, horse trails, and canoe routes, and bounded by stands of even-aged forest trees, burns, seedlings and saplings. This condition has been described as “yards, corridors, and mosaics” (Lewis and Ferguson 1999). Lewis and Ferguson initially used the phrase to describe a cultural landscape pattern maintained by Native people who lived in the boreal forests of Canada and Alaska, but determined that similar management patterns were also used by people in the conifer forests of the Rockies and Sierra Nevadas, northwest California, western Washington, Australia, and Tasmania (Lewis and Ferguson 1999:164-178). These researchers found that in each instance, fire was the tool most commonly used to establish and maintain grasslands and other openings (“fire yards”), bounded by stands of trees and open transportation routes (“fire corridors”). Fire was also the agent that entered unmanaged forested areas, whether by human cause or lightning, and caused burns that regenerated to a shifting mosaic of evenaged stands of seedlings, saplings, and trees (Lewis and Ferguson 1999:164-165).

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Matt Wingard, Climate Realist

Oregon Rep. Matt Wingard (R-Wilsonville) tells it like it is regarding the global warming hoax [here]. It’s nice to see an elected representative with the guts to speak the truth to power. Especially here in Loony Left Oregon, a one-party state.

12 Feb 2010, 5:26pm
Federal forest policy
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Contradicting Missions and the New USFS Planning Rule

Last December the US Forest Service announced their intention to create a new Planning Rule [here]. We presented some guidance, written by NAFSR Exec Dir Darrel Kenops, for drafting comments to assist the USFS in that process [here].

Now we present some excellent comments written by W.I.S.E. member Randy Shipman of Rock Springs, Wyoming. For a pdf version of Mr. Shipman’s comments, click [here].

BTW, comments must be received by February 16, 2010.


February 12, 2010
Forest Service Planning NOI
C/O Bear West Company 172 East 500 South Bountiful, UT 84010
via fspr@contentanalysisgroup.com

Reference: Federal Register/Vol.74, pp 67165-67169 – Notice of intent to prepare an environmental impact statement to analyze and disclose potential environmental consequences associated with a National Forest System land management planning rule.


The USDA-USFS has allowed itself to gradually be placed into a contradiction of missions, in part, by purging itself of professional foresters and engineers to make way for a new grand experiment as explained by the Committee of Scientists. Today, the USFS with the aid of the Congress have provided the taxpayer an agency that:

* has not retained workforce expertise to promote and finalize rule promulgations in concert with local affected governments and sometime the public as is consistently proven through the hiring of 3rd party contractors to disseminate information to the public and the agency;

* allows confusion of purpose within its ranks as proven through inconsistent application of planning methodology and/or policy or directive that currently exists between identical forest regimes in adjacent districts or regions;

* provides excuses to the public rather than a system of accountability when USFS actions impact private, local and state real properties;

* knowingly relinquished the charge of the agency’s Organic Administration Act among others in the promulgation of the 2000 36CFR219 rule and associated rules that require consistency with the ill-conceived 36CFR294 Roadless Area Conservation rule promulgation;

* is increasingly becoming a drag on the entire U.S. economy by devastating local forest dependent community stability through internal dictatorial processes that today is purposely leaving local and state governments out of the loop and on the hook to pay for and pick up the pieces of carnage that have followed three decades of USFS attempts to be “responsive to the challenges of climate change; the need for forest restoration and conservation, watershed protection, and wildlife conservation; and the sustainable use of public lands to support vibrant communities.” No one can be entirely certain what that really means, with perhaps the exception of those individuals or organizations who professionally and constantly litigate USFS processes in order to gain easy access to federal government funds rather than address issues found in the Substantive Principles for a New Rule. But then that is a particular matter for the Congress to account.

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12 Feb 2010, 1:22am
Forestry education
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Another Crack Showing in the Old Paradigm

We have frequently described the New Paradigm in forest science and ecology as the recognition of historical human influences.

Ecology is an historical science, in that it attempts to describe how vegetation and animal populations change over time. The Old Paradigm, which we have called Clementsian [here], holds that ecological dynamics have always been “natural”, at least up until recently, because Modern Man has only recently messed with Mother Nature. Or so the Clementsians say.

In the W.I.S.E. Colloquium: History of Western Landscapes [here], we have presented scientific papers and reviews of books written by the leading proponents of the New Paradigm. They hold that human beings have been modifying vegetation and animal populations for many thousands of years.

For example, the Old Paradigm considers the Amazon Basin to be a wilderness untouched by Man. But intrepid New Paradigm researchers have found mounds, canals, and human-modified soils called terra preta that are evidence of vast Amazonian populations in pre-Columbian times [here, here, here, for instance].

Similarly, the Old Paradigm maintains that the Pacific Northwest was also an untouched wilderness prior to Euro-American settlement. It’s ridiculously a-historical and a-scientific of course, but that’s the myth that has dominated PNW forest science for 80 years. To counter that myth, we have posted numerous papers and book reviews that express New Paradigm findings in the PNW [here, here, here, for instance].

In particular, historical anthropogenic fire gave rise to open, park-like forests, savannas, and prairies [here, here, here, here]. Frequent, seasonal, deliberate, expert, traditional Indian burning created conditions whereby trees could live to old ages, i.e. the old-growth trees extant today [here, here, here, here, for instance].

Sometime we feel like we have beat this drum to the point of boring readers excessively, but truthfully the New Paradigm has not yet supplanted the old one. There have been some notable cracks in the old facade, however [here, here, here, for instance].

Last month another crack appeared, as some Old Paradigmers gingerly dipped their toes in the new waters. A paper was published wherein the old guard finally admitted there might be something to this historical anthropogenic fire after all.

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Ecosystem Management and Statist Bureaucracy

Nearly twenty years ago the US Forest Service adopted “ecosystem management” as a primary mission. Ecosystem management is a nebulous term that means whatever they want it to mean, and surprise surprise, it has entailed a massive transfer of power from the individual to the state.

An excellent synopsis of the meaninglessness of the phrase, and of the statist power grab that lies hidden beneath the veneer of “ecosystem management”, may be found in our latest addition to the W.I.S.E. Colloquium, Forest and Fire Sciences [here]

The paper is:

Travis Cork III. 2010. The Fictional Ecosystem and the Pseudo-science of Ecosystem Management. W.I.S.E. White Paper No. 2010-3, Western Institute for Study of the Environment.

This is the third in our new series of White Papers. More are to come.

It has been our practice to place most comments regarding Colloquia papers here at SOS Forests. We don’t wish to clutter the Colloquia with off-topic and less than scholarly comments, but we do encourage your participation in the discussion. So comments on Mr. Cork’s paper should be directed towards this post.

If you have a pertinent scholarly commentary that meets the quality criteria of our Colloquia editors, then we can place it over there. We reserve the right to control placement.

Some excerpts from The Fictional Ecosystem and the Pseudo-science of Ecosystem Management by Travis Cork III:

LAND USE CONTROL has long been the goal of the statist element in our society. Zoning was the first major attempt at land use control. Wetland regulation and the Endangered Species Act have extended some control, but nothing has yet brought about a general policy of land use control. Ecosystem management is an attempt to achieve that end.

In The Use and Abuse of Vegetational Concepts and Terms, A. G. Tansley coined the term “ecosystem.” Tansley rejected the “conception of the biotic community” and application of the “terms ‘organism’ or ‘complex organism’” to vegetation. “Though the organism may claim our primary interest, when we are trying to think fundamentally we cannot separate them from their special environment, with which they form one physical system. It is the systems so formed which, from the point of view of the ecologist, are the basic units of nature on the face of the earth. … These ecosystems, as we may call them, are of the most various kinds and sizes… which range from the universe as a whole down to the atom” 1/

The ecosystem may be the basic unit of nature to the ecologist, that is—-man, but it is not the basic unit to nature. Its proponents confirm that it is a man-made construct. …

The nebulous nature of the ecosystem has not deterred bureaucrats, statist academics, and green advocacy groups (GAGs — The Nature Conservancy, Sierra Club, Audubon, et al.) from pushing it as the basic management unit in nature. …

Lack of a rigid operational definition of an ecosystem gives the designer a blank check. Corruption and exploitation are inevitable. …

Given that Mother Nature does not delineate ecosystems, who will delineate these fictional ecosystems? The answer is obvious, the self-interested elitists in the ruling class. …

Supporters of the fictional ecosystem demand that it be managed. Enter the pseudo-science of ecosystem management. …

A management policy that cannot define its basic unit, the ecosystem, cannot have clear, operational goals. It cannot be based on sound models or understanding at any scale or in any context.

That life is complex is no argument for the ecosystem or ecosystem management, especially by government. No entity is less prepared to deal with complexity or to be adaptable and accountable than bureaucracy. …

Ecosystem management will mean more government control. It will intrude on private property rights. If a justification is to be created using the Constitution, it will result in a further perversion of that document and our long-lost republican form of government. …

The ecosystem management literature is filled with this command-and-control, central planning mentality. Ecosystem management is a process rife with opportunities for exploitation and corruption by government and its allies. …

10 Feb 2010, 6:12pm
Climate and Weather
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George Taylor on Climate Change

Taylor speaks about warming

by Alex Paul, Albany Democrat-Herald, February 9, 2010 [here]

Like a fluctuating stock market, climate change is cyclical and should be looked at over the long-term, not just a few decades at a time, George Taylor president of Applied Climate Services, said this morning at the ninth annual Ag Appreciation Breakfast sponsored by the Albany Area Chamber of Commerce.

Taylor was state climatologist for 19 years before resigning after clashing with Gov. Ted Kulongoski about climate change issues.

“I believe in data. I trust data,” Taylor said at the Linn County Fair & Expo Center. “There are those who believe climate change can be predicted through modeling. I don’t.”

Taylor said environmental extremists like former vice-president Al Gore use specific time periods to try to convince the public that humans play a major role in climate change. Taylor believes human activities have a minor role in global warming.

“Alarmists are cherry picking,” Taylor said. “They pick their starting and ending dates to help make their point.”

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Palin likens global warming studies to ’snake oil’

Note: Former Alaska Gov. Sarah Palin spoke at the Sierra-Cascade Logging Conference in Redding, CA yesterday. The following is the AP report.

Palin likens global warming studies to ’snake oil’

By JUDY LIN, San Jose Mercury News, 02/08/2010 [here]

REDDING, Calif.—Former Alaska Gov. Sarah Palin called studies supporting global climate change a “bunch of snake oil science” Monday during a rare appearance in California, a state that has been at the forefront of environmental regulations.

Palin spoke before a logging conference in Redding, a town of 90,000 about 160 miles north of the state capital. The media were barred from the event, but The Associated Press bought a $74 ticket to attend.

Palin said California’s heavy regulatory environment makes it difficult for businesses to succeed, a point that is shared by many business leaders in the state.

She criticized what she said were heavy-handed environmental laws. As Alaska governor, for example, she said she sued the federal government to overturn the listing of polar bears as a threatened species.

As Alaska North Slope wells dry up, the state is examining offshore drilling for oil and natural gas reserves. Protections for polar bears under the Endangered Species Act could thwart those explorations, according to Palin and her successor, Alaska Gov. Sean Parnell, who has picked up the cause.

Palin told the audience that filled the 2,000-seat Redding Convention Center that she disagreed with the science the government used to support the listing.

“We knew the bottom line … was ultimately to shut down a lot of our development,” she said during her 40-minute speech, which was followed by a 20-minute question-and-answer session.

“And it didn’t make any sense because it was based on these global warming studies that now we’re seeing (is) a bunch of snake oil science.”

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9 Feb 2010, 8:41am
Saving Forests
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The Benefits of Forest Restoration

Note: This essay, with references, is now available for downloading as W.I.S.E. White Paper 2010-2 [here]

By Mike Dubrasich

Restoration forestry aims to recover our nation’s forest heritage while also restoring the productive and harmonious relationship between people and forests that existed in historic forests. Restoration forestry is a vision for the future rooted in respect for the past. — Dr. Thomas M. Bonnicksen, Protecting Communities and Saving Forests–Solving the Wildfire Crisis Through Restoration Forestry.

FOREST restoration means active management to bring back historical cultural landscapes, historical forest development pathways, and traditional ecological stewardship to achieve historical resiliency to fire and insects and to preclude and prevent a-historical catastrophic fires that decimate and destroy myriad resource values.

Forest restoration is beneficial to man and nature in numerous ways. The following describes these benefits in general.

1. Heritage and history

To restore means to return to a former or original state. In the case of forests, restoration requires knowledge of and respect for forest history as a starting point. Forest restoration looks to pre-Contact forest conditions as a guideline.

Many (if not most) North American forests were at one time (prior to ~120 years ago) open and park-like, with widely spaced, large, old trees. Forests were conditioned to be that way by frequent, non-stand-replacing, anthropogenic fires. Historical human features included village sites; sacred and ceremonial sites; hunting, gathering, agricultural and proto-agricultural fields; extensive trail networks; prairies and savannas; and other features induced and maintained by ancient human tending through the use of traditional ecological knowledge.

Forest restoration, properly researched, designed, and implemented, restores, protects, and perpetuates many of the heritage features of forested landscapes.

2. Ecological functions including old-growth development

Our old-growth trees arose under much different conditions than today. The forest development pathways of pre-Contact eras were not punctuated by catastrophic stand-replacing fires but instead were the outcomes of frequent, seasonal, light-burning fires in open, park-like forests. Those fires were largely anthropogenic (human-set by the indigenous residents). Because the fires of historic eras were frequent and seasonal, they gently removed fuels without killing all the trees. The widely-spaced trees thus survived repeated burning and grew to very old ages.

As more and more forests have been investigated for actual age distribution, it has been discovered that “old-growth” forests, are not even-aged. Instead, many (if not most) older forests are distinctly multi-cohort. That is, forests often have two or more widely divergent age classes of trees. This fact tends to disprove the “stand replacement fire” theory, at least in regards to older forests. Their development pathways must have been different than that. It is now widely concluded that many (if not most) North American forests were at one time (120 to 500 years ago) open and park-like with widely spaced, large, old trees, and that forests were conditioned to be that way by frequent, anthropogenic fires. That is, the actual historical forest development pathways for many (if not most) of our forests involved frequent, light-burning fires, not stand-replacing fire.

Restoration forestry seeks to restore, maintain, and perpetuate historical forest development pathways that engender old-growth trees.

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Battling Over the Forest Restoration Meme

When does “forest restoration” mean “abandonment to catastrophic destruction”? Answer: in the “Green Budget 2011″ proposal.

A coalition of quangos (quasi-governmental non-governmental organizations) is playing games with words. They want the word “restoration” to mean the opposite of what it actually means, prompting a battle over the meme.

The “Green Budget 2011″ [here] was prepared by 34 “environmental” lobbying groups including perennial litigation-happy bullies such as Defenders Of Wildlife, Earthjustice, Environmental Defense Fund, National Audubon Society, Natural Resources Defense Council, Sierra Club, The Wilderness Society, and the World Wildlife Fund. Note that these same groups are the big pigs at the EAJA trough, raking in $billions from the government to sue the government in order to sabotage restoration programs [here].

The Green Budget 2011 defines “restoration” this way:

Restoration management should be viewed as a way to recover the natural processes, structure, composition and function of a healthy forest ecosystem; it is an intentional effort to restore land, air, and water degraded by human activities to a more natural state, enhancing our forests’ ability to adapt and be resilient to disturbances and change. This is a separate and distinct vision from traditional logging or hazardous fuels reduction; while these activities may have a place on national forests, the goals and objectives are not necessarily consistent with ecosystem restoration, and the terms should not be used interchangeably.

In other words, to the quangos “restoration” means No Touch, Let It Burn, Watch It Rot.

In actuality, real forest restoration means active management to bring back historical cultural landscapes, historical forest development pathways, and traditional ecological stewardship to achieve historical resiliency to fire and insects and to preclude and prevent a-historical catastrophic fires that decimate and destroy myriad resource values.

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President Jokes About ‘Snowmageddon’

This is priceless:

Epic Snowstorm Batters Mid-Atlantic Region

Fox News, February 06, 2010 [here]

WASHINGTON — Mid-Atlantic residents were buried Saturday from a likely record-setting blizzard the president jokingly called “Snowmageddon,” and those brave enough tried to clear a path through the wet, heavy mounds of thigh-high snow.

The snow was falling too quickly in the nation’s capital for crews to keep up, and officials begged residents to stay home and out of the way so that roads might be cleared in time for everyone to return to work Monday. The usually traffic-snarled roads were mostly barren, and Washington’s familiar sites and monuments were covered with nearly 2 feet of snow. …

The storm toppled trees and knocked out power to hundreds of thousands of customers in Washington, Virginia, Maryland, Delaware, Pennsylvania and New Jersey. The situation was the same in West Virginia, where some 400 National Guard troops were helping with snow removal. …

First, there was a small fender bender on the White House south lawn. Then a tree branch, overcome with snow, cracked and fell on a motorcade vehicle with press inside when the president was coming back from a speech at the Democratic National Committee’s winter meeting in town.

Instead of a presidential limo, Obama rode in a black SUV covered with presidential seals.

Obama thanked Democrats for being “willing to brave a blizzard. Snowmageddon here in D.C.” …

Barack O. is from Hawaii via Indonesia. “Snowmageddon” is painful irony, because for years the Dems have been hysterical about Thermageddon, aka the Venus Effect, aka the boiling of the seas and end of all life due to runaway global warming as predicted by Al Gore, James Hansen, and various other nutjobs.

But it’s all a joke, a rude joke, a joke on you and me, the American taxpayers, who are being asked to fork over $trillions and to gut the American economy in the name of preventing Thermageddon.

Ha ha, Mr. President. Très drôle. Now sack your worthless Constitution-bashing climate czars, including EPA drama queen Lisa Jackson and population bomber John Holdren. The joke (aka the biggest hoax in history) is over.

3 Feb 2010, 10:03am
Forestry education Saving Forests
by admin

Defining, Identifying, and Protecting Old-Growth Trees

Note: This essay, with references, is now available for downloading as W.I.S.E. White Paper 2010-1 [here]

By Mike Dubrasich, Western Institute for Study of the Environment, Feb. 3, 2010

IN ORDER TO SOLVE our current forest crisis and protect our old-growth, it is useful to understand what old-growth trees are and how to identify them in the field.

At first blush this may seem to be a simple problem, but it is not, and much confusion and debate abounds over the issue. Old-growth trees are “old,” but how old does a tree have to be to qualify as “old-growth”? And what is the difference between an individual old-growth tree and an old-growth stand of trees? Why does it matter?

Some rather sophisticated understanding of forest development is required to get at the root of these questions.

Frequent Fire and Multicohortedness

As we have discussed at SOS Forests numerous times, so-called old growth stands are actually multicohort, meaning separate and distinct age classes of trees coexist in the same stand. Typically the older cohort consists of trees that arose in the frequent fire era, while the younger cohort of trees arose after the frequent fire era ended.

The frequent fire era is more properly termed the anthropogenic fire era — the last 6,000 to 12,000 years during which the indigenous residents managed landscapes with frequent, seasonal, deliberate burning.

That deliberate burning gave rise to an anthropogenic mosaic. The fires set by human beings may have sometimes been accidental, but by and large the fires were set intentionally to modify the vegetation for purposes of human survival. Carefully timed and located burning was used by the First Residents to develop and maintain berry patches, for instance. Some of those “patches” covered thousands or even tens of thousands of acres, so the word “patch” is an understatement in this case.

Deliberate burning also gave rise to oak and conifer savannas that covered millions of acres. Every year (or two or three) the inhabitants set the prairie grasses on fire. The fires were light-burning, but they killed most of the tree seedlings that might have been present.

Across the West, and in other regions of North and South America, trees readily establish themselves. But frequent anthropogenic fire favors grasses, not trees. Historically, only a very few seedlings survived the frequent fires. Perhaps one seedling per acre every 20 to 40 years survived the repeated burning and grew to a fire-resilient size. Over time, 5 to 25 large trees per acre comprised the oak and conifer savannas. Beneath the trees, grasses and other prairie plants dominated the “understory.”

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Cap-and-Trade Is Dead

In case you didn’t notice, cap-and-trade is dead. Al Gore’s scheme to create a new “carbon market” has bitten the dust. He and his partner in that crime, Goldman Sachs, the global investment banking and securities giant, may or may not realize it, but the canary is belly up.

Al and GS hoped to hamstring American industry (and the world) with an Enron-style market based on fiat “carbon derivatives” of no intrinsic value, bleeding coerced investors, utilities, and rate payers dry. But the MSM is now reporting what the rest of us have known for awhile — that dog won’t hunt.

Advocates of Climate Bill Scale Down Their Goals

By JOHN M. BRODER and CLIFFORD KRAUSS, NY Times, January 26, 2010 [here]

WASHINGTON — As they watch President Obama’s ambitious health care plan crumble, the advocates of a comprehensive bill to combat global warming are turning their sights to a more modest package of climate and energy measures that they believe has a better chance of clearing Congress this year.

Their preferred approach, a cap-and-trade system to curb emissions of climate-changing gases, already faced a difficult road in a bruised and divided Senate. Its prospects grew dimmer after the special election in Massachusetts last week was won by Scott Brown, a Republican who repudiated the federal cap-and-trade proposal in his campaign.

Republicans, industry executives and some Democrats have already written cap and trade’s obituary, at least for this year. And even some of the system’s most ardent supporters now say they must scale back their ambitions and focus on job-creating energy projects and energy efficiency measures if they are to have any hope of dealing with climate change in this Congress.

“Realistically, the cap-and-trade bills in the House and the Senate are going nowhere,” said Senator Lindsey Graham, Republican of South Carolina, who is trying to fashion a bipartisan package of climate and energy measures. “They’re not business-friendly enough, and they don’t lead to meaningful energy independence.”

Mr. Graham said the public was demanding that any energy legislation from Washington focus on creating jobs, whether by drilling for offshore oil or building wind turbines.

“What is dead is some massive cap-and-trade system that regulates carbon in a fashion that drives up energy costs,” he said. …

Last December Sen. James M. Inhofe (R-Okla.), Ranking Member, Committee on Environment and Public Works, announced at the UN Climate Change Conference in Copenhagen [here]:

I want to be sure the 191 countries understand this: again, an economy-wide cap-and-trade bill stands no chance of passing. …

Today the cost of cap-and-trade bills before the House and Senate bear striking resemblance to those of Kyoto. Take the Waxman-Markey bill, for example. A government study by the Energy Information Administration concluded that the Waxman-Markey bill destroys up to 2.3 million jobs in 2030 and destroys up to 800,000 manufacturing jobs in 2030 — and, I should note, those figures include new green jobs, so they are net job losses.

And in September, under pressure from a Freedom of Information Act request, the Obama Administration released a per-household cost estimate of the President’s cap-and-trade program. The cost per family was over $1,700 per year. Again, that would be the largest tax increase in history. …

When asked to prioritize a list of 20 public policy issues, respondents put climate change dead last. And the Senate has responded. At most there might be 25 votes in the Senate for a cap-and-trade bill, and they need 60.

My stated reason for attending Copenhagen was to make certain the 191 countries attending COP-15 would not be deceived into thinking the US would pass cap-and-trade legislation. That won’t happen. And for the sake of the American people, and the economic well-being of America, that’s a good thing.

Inhofe was correcto mundo. Cap-and-trade is deceased, has kicked the bucket, and is pushing up daisies.

Poor Al. The best laid schemes o’ mice an’ men gang aft agley.

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