Tag
regulatory-reform
- EssayThe End of the Snapshot
Environmental permits are written from models run once, on chosen inputs, whose outputs become legal facts for five to fifteen years. Seven properties of any one-time model are derived and simulated here: averaging the inputs is not averaging the answer, a design value is one draw from an unreported sampling distribution, stacked maxima are blind to coincidence, a short test of an intermittent source fails to identify a number at all, every frozen model has a half-life, the value of a model is the age of its inputs, and the resulting conservatism has been paid in production every hour for fifty years. The conclusion is not that models are bad but that a model is a state estimator that was mistakenly used as an oracle.
- EssayThe Frozen Instrument
An inventory of 18 simulation models in routine use for United States permitting finds a median governing-formulation year of 1984, a median structural age of 42 years, and none that ingest observations while running. Decomposing the error of a regulatory prediction into physics, source parameters, and input freshness shows the physics term carries at most 12 percent of total error variance, so halving it removes 3 percent of total error while halving the parameter error removes 29 percent, implying a safety multiplier of about 9.2 under present practice that falls to 1.47 once the terms are measured away.
- EssayOuch.
Environmental law is the sound a civilization makes after the burn—ouch without the flinch. This essay argues that the century-long failure to protect the living world was never a failure of caring but of loop speed, shows with control theory why a loop must close roughly eighty times faster than the harm it holds, and argues that the collapse of the understanding stage between 2022 and 2025 makes a planetary flinch buildable for the first time: reflex below, intention above.
- EssayThe Environmental Loop Through Time
A first-principles history of the environmental protection loop—sense, infer, decide, act—across every era from the Hadean to the machine era, showing which of the three physical limits (delay, noise, bandwidth) bound it at each stage. The record's rule is that bigger meant slower for four billion years; the argument is that the era now opening is the first break in it.
- EssayWho closes the environmental protection loop?
Seven eras of the environmental protection loop—sense, infer, decide, act—from a thermostat with no one to set it to a valve that shuts the second a leak opens. The operators changed six times and the four jobs never did; the only variable that ever moved was how fast the loop closes, and for four billion years a bigger domain meant a slower one. The machine loop now being built is the first regulator off that line.
- EssayWhy Build Environmental Superintelligence?
Derives, from first principles and the measured 2026 record, seven reasons to build environmental superintelligence, ranked across three tiers and each stated alongside what it does not prove. The core finding is an asymmetry of clocks—civilization changes nature at machine speed and answers at paper speed—and the observation that the cost of environmental cognition, the one input that can close that gap, is now falling faster than any cost curve in the history of environmental work.
- EssayThe Missing Chapter of AI Safety
A verbatim term search of the five documents that govern frontier AI—OpenAI's Model Spec, Anthropic's Constitution, DeepMind's Frontier Safety Framework, Meta's Frontier AI Framework, and the EU AI Act—returns zero hits for watershed, aquifer, groundwater, wetland, habitat, emissions, conservation of mass, and conservation of energy. Argues that this is not an oversight but an unopened category, and sketches what an environmentally grounded system would commit to: disclosure rather than refusal, hard constraints drawn only from conservation laws, grounding in live measurement rather than recollection, and an auditable log.
- EssayEnvironmental Safety Mode: The Proxy Stack, the Interlock, and What Physical Grounding Can and Cannot Do
The technical companion to 'The Daylight.' Establishes, with sources and uncertainty bands, the energy throughput of the sectors AI is acquiring allocation authority over; gives a formal treatment of environmental regulation as a layered proxy stack and works it against the measured reward-hacking literature; separates the is-gap from the ought-gap using three independent results (the biosphere specifies no preferred state, entropy is observer-relative, and no system grounds its own objective from inside); derives the thermodynamic feasibility of environmental gating with the three leverage quantities kept strictly apart; and specifies Environmental Safety Mode L0–L5 with requirements, costs, limits, and how an adversary defeats each level.
- EssayThe Wrong Question
An essay in six questions the inherited environmental frame cannot hold. The 1970s legal architecture, the asteroid, the Pleistocene baseline, the parallel biospheric inventory, the constructive turn, and the frame itself—each surfaces the same underlying claim: life is a structure that builds knowledge against entropy, and humans are the first part of Earth's biosphere capable of modeling and defending the experiment that produced them.
- PostThe "Blind Spot" in Environmental Engineering
The "Blind Spot" in Environmental Engineering . . . Re-Engineering Environmental Engineering based on the Laws of Thermodynamics and Information Theory . . .
- PostThe Most Complicated Law in Human History
The U.S. Clean Air Act has been found to be the most complicated law in human history.
- PostTCEQ Commissioner Job is Opening
## Jed Anderson says . . . “I’m running”
- PostHow a “Green Lizard” could save us Millions of Pounds on Air Pollution
### **The insurance aspects inherent in the market-based approach of the Draft Clean Air Act of 2018 could reduce millions of pounds of excess emissions**
- Post“I solved it.”
I solved one of our nation’s biggest challenges.
- PostKeeping Light to Yourself
Most of the forces around us tell us to keep any light we perceive to ourselves–or that the light we see is in truth darkness, or at most only light to ourselves.
- PostThe Goal of the Current Clean Air Act is Mediocrity. The Goal of My New Act . . . Perfection.
The goal of the current Clean Air Act of 1970-1990 is mediocrity. The purpose is to find a “safe” level of pollution using an increasing amount of regulations. Mediocrity. Like a student setting a goal of getting a “C”.
- Post“Artificial Intelligence” and the Clean Air Act
| | | | --- | --- | | | | | --- | | **The simplified Clean Air Act of 2018 will unleash the power of advancements in new sensoring technology, big data, and artificial intelligence**–creating astounding new economic and environmental opportunities in the United States.
- PostEnding Pollution and Law: True Freedom
 **“My personal goal is to end both pollution and environmental law. Some call this idealism.
- PostTechnology is Undermining the Clean Air Act
## ***Advancements in air quality monitoring are undermining the foundations of the U.S. air quality management system***
- PostAnderson’s Simplicity Speech at TCEQ
Below is a copy of yesterday’s speech imploring TCEQ to begin simplifying the environmental regulatory system in the State of Texas.
- PostTCEQ Out of Touch with Simplicity
TCEQ believes their rules are written with the goal of simplicity in mind.
- PostComment Filed on Trump Executive Order to Reduce Regulations that Includes Plan for Simplifying the Air Quality Management System
A public comment was filed on Executive Order E.O. 13771 that includes a plan for simplifying the air quality management system at its foundation: (see below or <https://www.regulations.gov/document?D=EPA-HQ-OA-2017-0190-0226>).
- PostEasiest Way to Avoid Environmental Laws
>—“The easiest way to avoid environmental regulation is to create more of them.”
- Post2017 Clean Air Act Reauthorization
Here are slides from the draft legislation to reauthorize the U.S. Clean Air Act.
- PostTrump Air Regulations: will “2 out 1 in” become “3 in 1 out” in four more years?
Only way to simplify air regulation is to simplify the systems in the Clean Air Act.
- PostPresident Obama Calls on Congress to Reform the Clean Air Act in NPR Exit Interview
[](https://www.youtube.com/watch?v=lEjeKrZxDFQ&t=36m8s)
- PostHouston Attorney Writes Book on Clean Air Act Reform
*Jed Anderson, nationally known expert on the Clean Air Act and partner at AL Law Group, PLLC, has written a book about leading U.S.
- PostTCEQ Loading Your Docs onto World-wide Web
 Fantastic! What bold Congressional leadership! Hopefully this helps lead to comprehensive improvements to the Clean Air Act. Thank you Congressmen Olson, Latta, Cuellar, and Kirkpatrick!
- PostParis Accord Signed
[](/images/sip/whitfield-and-clean-air-act-reform.jpg)President wants climate change legacy protected. Congressional Republicans want a better working environmental protection system.
- Post“Reevaluating the CAA would prove Disastrous”
[](/images/sip/clean-air-act-and-courage.jpg)Many Republican and Democrat leaders think that reevaluating the Clean Air Act would prove “disastrous” (see quotes in last Friday’s Politico)
- PostRecommendation: “Set the Ozone Standard at 0.0 ppb”
[](/images/sip/set-ozone-standard-at-zero.gif)I would recommend setting the ozone standard at 0.0 ppb.
- PostSuffering and the Clean Air Act
***[](/images/sip/harmful-and-the-clean-air-act.png)Sentiment: “***I don’t want to suffer.
- PostClean Air Act Reform
> ***[](/images/sip/air-quality.png)Sentiment:*** *“You folks are a failure. The Clean Air Act can’t be simplified and transformed. It’s politically impossible. You are wasting your time.”*
- PostIt’s Better to Fail
[](/images/sip/akempis-and-the-clean-air-act.png)I failed again with my request that the State of Texas recognize foreign pollution impacts to our health, economy, and ability to achieve the NAAQS (*see* TCEQ ruling).
- Post“You can Always Shoot the Cow”: Why a Strict ‘but for’ Interpretation of Section 179B would be Nonsensical
[](/images/sip/clean-air-act-section-179b.png)For some reason States seem to think that Section 179B is a strict “but for” demonstration.
- PostSimplicity and the Clean Air Act
[](/images/sip/clean-air-act-and-simplicity.png)The reason things are still complicated is that we do not fully understand them. Once we fully understand them . . . they will become simple.
- PostAir Pollution: Eastern States Point Fingers at Midwestern States
[](/images/sip/governors-and-clean-air-act.png)Everyone get a chance to read the Northeast’s petition to include the Midwest in the OTC (see link)? A few questions:
- PostThe Pain and Difficulty of Updating the Clean Air Act
[](/images/sip/clean-air-act-reform.png)The main reason why I think we don’t want to get involved with updating the Clean Air Act is that it will be difficult and painful. We want happiness and peace—not pain and difficulty.
- PostOccam’s Razor and the Clean Air Act
[](/images/sip/occam-and-the-clean-air-act.png)I wonder what would happen if we applied Occam’s Razor to the Clean Air Act?
- PostBruce Lee and the Clean Air Act
[](/images/sip/bruce-lee-and-the-clean-air-act.png)I wonder what Bruce Lee would think about the Clean Air Act?
- PostEinstein and the Clean Air Act
[](/images/sip/einstein-and-the-clean-air-act.png)I wonder what Einstein would think about the Clean Air Act?
- PostIsaac Newton and the Clean Air Act
[](/images/sip/isaac-newton-and-the-clean-air-act.png)I wonder what Isaac Newton would think about the Clean Air Act?
- PostSteve Jobs and the Clean Air Act
[](/images/sip/steve-jobs-and-the-clean-air-act.png)I wonder what Steve Jobs would think about the Clean Air Act?
- PostThoreau and the Clean Air Act
[](/images/sip/thoreau-and-the-clean-air-act2.png)I wonder what Thoreau would think about the Clean Air Act?
- PostWinston Churchill and the Clean Air Act
[](/images/sip/churchill-and-the-clean-air-act.jpg)I wonder what Churchill would think about the Clean Air Act?
- PostGina McCarthy Answer to Senate Committee Regarding Foreign Pollution
> **[](/images/sip/mccarthy-and-foreign-pollution.png)Senate Question: According to recent NOAA reports, half of all the current ozone exceedances in many areas in the Western US are due to emissions from Asia.
- PostThe Ninth Symphony and Clean Air Act Reform
Still think we can’t reform the Clean Air Act? Guess what. We already are. This is the first movement. Want to hear what the finale might sound like? Listen to the 4th movement of Beethoven’s Ninth. My favorite part of the 4th movement is how dark it begins.
- PostThe Most Frequent Excuse I Hear for Not Wanting to Change the Clean Air Act
[](/images/sip/general-washington.png)Probably the most frequent excuse I hear for not wanting to try to improve the Clean Air Act is if we give this thing to Congress you never know what they will do with it.
- PostRelatively Wrong vs. Absolutely Wrong: Foreign Pollution and the Clean Air Act
[](/images/sip/transpacific-pollution.png)Just because foreign pollution is hard to measure doesn’t mean that we can continue assuming for SIP purposes that it does not exist.
- PostHow the Clean Air Act will be Changed
[](/images/sip/art-buchwald.png)When we think of how the Clean Air Act will be changed I think we envision some powerful and influential person, who understands the Clean Air Act much better than we do, giving a rousing speech before…
- PostWest vs. East: Pollutant Transport Under the Clean Air Act
[](/images/sip/eastern-vs-western-states-and-transported-pollution1.png)Eastern States are now suing to get Western States to address Eastern State’s pollution in Western State’s SIPs (see headlines below). Absurd?
- PostCongress Hears from States and Local Governments in Clean Air Act Forums—Fix the SIP Process!!!
Today at 10:00 am is the 3rd forum in the House Energy & Commerce Committee on the Clean Air Act (see link).
- PostWant Cleaner Air? Simplify the Clean Air Act
Is your life too busy? Are you having problems getting everything done? As counterintuitive as this might seem, one of the easiest ways to get more done is to try to do less. Reduce the clutter. Simplify.
- PostClean Air Act Reform
[](/images/sip/caa1.png)
- PostHow to Reduce Clean Air Act Litigation
[](/images/sip/legal.jpg)One of the central focuses of the Congressional Clean Air Act Forums so far has been the crazy amount of litigation on air quality matters.
- PostWe’ve Got No Power, No Money . . . I Like Our Chances to Reform the Clean Air Act!
What? How can I like our chances? Because when the weak charge headlong into a challenge, acknowledging their weakness, and doing so in an manner that does not conform to the norms around them, they usually win.
- PostReforming the Clean Air Act: A New Approach to Addressing Stationary Sources
[](/images/sip/future2.png)How about working to build something new together? Here is an idea. If we succeeded in this endeavor we could greatly reduce costs to industry and the public–and improve environmental quality.
- PostDistinction Between Ozone Attainment and Nonattainment Areas Disappearing
The NAAQS-SIP process is focused on the distinction between attainment areas and nonattainment areas. I’m just not seeing these distinctions much anymore. Here are just a few points on this: