As a measure of habitability, the temperature of a planet is determined by the energy balance between the absorption of sunlight and the loss of thermal heat to space. Earth has been habitable for three or 4 billion years (Lepot et al., 2008;Nutman et al., 2016), owing to a relatively stable energy balance.The thermal cooling to space is modulated by gases that are radiatively active in the longwave (thermal) spectra via the greenhouse effect. Simpson (1928) formulated a simple model to explain thermal cooling to space when water vapor is the only greenhouse gas (GHG) as a function of surface temperature, assuming constant longwave transmission per mass of water vapor. The same assumption was used in other conceptual models (Ingersoll, 1969;Nakajima et al., 1992), which we refer to as the "Simpsonian" model. It implies that once the atmosphere becomes opaque, the outgoing longwave radiation (OLR) cannot increase further when the surface warms. In this case, the planet's thermal budget would become unstable because, if the absorption of sunlight