EPA CO2 Comment Deadline Approaching
by Daniel Simmons, posted at Watts Up With That, Nov 25, 2009 [here]
I wanted to bring your attention to an EPA comment period that closes this Friday. As you previously covered on Watts Up With That, EPA is working on declaring that CO2 and GHGs greenhouse gases endanger human health and welfare under the Clean Air Act [here].
That endangerment finding is the first step to regulating GHGs and the second is to develop the actual regulations to regulate GHGs for cars and light trucks. On Friday, the comment period for EPA’s proposed regulations on cars and light trucks closes. It would be very helpful to push back on the proposed endangerment finding by pushing back on the proposed regulations on cars and light trucks and sending EPA as many comments as possible on the proposed GHG regulations for cars.
We want to make sure as many people as possible know about this proposed rule and generate as many comments as possible. To facilitate people sending comments to EPA on the proposed rule, we put up a page that contains a model comment to send to EPA [here].
Also, the EPA’s Proposed Rule is [here] and a direct link to the Docket to submit comments to EPA is [here].
People can also send email on this rule directly to EPA at a-and-r-Docket@epa.gov.
It would be very helpful if you would let your readers know about this comment period. Because of Thanksgiving and the cap-and-trade bills, this proposed rule hasn’t gotten very much attention and yet it relies on the same science as EPA’s other regulations and will help trigger a regulatory cascade of EPA inserting itself into many areas of life because those activities emit GHGs.
Here’s more background: To address climate change (and relying on the standards sources of climate science–the IPCC, NCDC, GISS, etc.) EPA is proposing to use the Clean Air Act to require 35 mpg fleetwide fuel economy standards by 2016—four years faster than Congress’ plan in the Energy Independence and Security Act of 2007. Not only will this rule drive up car and truck prices and limit consumer choice, it will start a regulatory cascade with EPA regulating GHGs using a number of sections of the Clean Air Act.
But EPA’s data show that the rule is all cost and no benefit. According to EPA, the proposed rule will increase car and truck prices an average $1,100 (74 Fed. Reg. 49460). As a result of less CO2 in the air, the rule will lead to decrease in global mean temperature by 16 thousandths of a degree Celsius (0.016°C) in 2100 and a decrease in mean sea level rise by 1.5 mm (74 Fed. Reg. 49589). That’s not a joke — that’s what the rule says. Obviously 16 thousandths of a degree Celsius, 90 years down the road, will not affect the climate in any way.
It would be bad enough if the rule only imposed exorbitant costs and with no benefits. But this will start the regulatory cascade that many of us have written about. To finalize this rule, EPA would also finalize their “endangerment finding” (in other words, EPA would find that GHGs from motor vehicles harm public health and welfare). CO2 and GHGs will become subject to National Ambient Air Quality Standards, New Sour Performance Standards, Hazardous Air Quality Standards, among other regulatory schemes.
If EPA makes an endangerment finding for GHGs, that action would make two permitting programs apply to GHGs—prevention of significant deterioration (PSD) and Title V. PSD applies to stationary sources which emit more than 250 tons a year and Title V applies to stationary sources which emit 250 tons per year. According to EPA, this would force as many as 6 million buildings (school, churches, hospitals, office buildings, farms, etc.) to comply with the Clean Air Act’s permitting provisions. To try to address this problem, EPA has proposed a “tailoring rule.” The point of the tailoring rule is that 250 tons per year of emissions can be read to mean 25,000 tons per year. Again, that’s not a joke [here].
Please let the EPA know your views right away. Time is of the essence.
