Subject: File No: S7-10-22
From: Bob Williams
Affiliation:

Mar. 23, 2022

To Whom it May concern: 


Your proposed rule assumes facts not in evidence. Your emphasis assumes carbon dioxide is in fact driving our climate. It is clear you have swallowed a "theory" without proof as being in fact a law of nature. At present, the multiple supercomputer models showing significant unprecedented increases in temperature have failed to be able to predict temperature within two standard deviations. The current models do not model, into their calculations, cloud formation at all altitudes, length of persistence of cloud, solar cycle changes in relation to climate, magnetic field changes and their impact on volcanic eruption, orbital changes with known periodicity and a myriad of other factors. In point of fact, the RSS satellite reports a temperature decrease since 2016 almost matching the temperature change increases noted since 1900. This decrease has occurred even while CO2 has increased. That in itself should send you a message. A theory that better models climate and better matches climate is one totally out of the control of your regulations. This is the likely coming Grand Solar Minimum with lessening magnetic sun spots and increased effect on cloud formation by released energetic particles that may also have greater impact due to the decreasing magnetic field of earth. Your regulations are simply busy work as no company can guess better than the supercomputer models which themselves haven proven their fallibility. What can a company do but waste time, money and paper satisfying something impossible to achieve and presenting a worthless prediction to investors and others who themselves do not understand, for the most part, how chaotic and complicated the climate is and that it remains unpredictable. 

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Bob Williams