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I am writing in response to EPA’s Advance Notice of Proposed Rulemaking (ANPR) regarding the regulation of greenhouse gases under the Clean Air Act. EPA should not find that greenhouse gases endanger human health and welfare and EPA should not use the Clean Air Act to regulate greenhouse gases. To quote EPA Administrator Johnson himself, the Clean Air Act “is ill-suited for the task of regulating global greenhouse gases.”

EPA Should Not Find that Greenhouse Gas Endanger Human Health and Welfare

CO2 is in fact making the planet greener; plants love it. It is not a polutant.

The physician's admonition : "First, do no harm" must be recognised as the true "precautionary principle" in situations of incomplete and questionable knowledge. Tangible harm has already been done, and truely disasterous economic harm could be done in the name of this increasingly discredited alarmism. BA

The ANPR seems to presume that greenhouse gases harm human health and welfare. There is little evidence for this claim and historical data show the opposite. Over the past 100 years, as temperature and greenhouse gas concentrations have increased, global GDP has increased 18 fold, average life span has doubled, and per capita food supplies have increased even as global population has quadrupled. What is more, these increases in human welfare have been due to economic growth, which necessarily went hand in hand with greenhouse gas emissions. Had such emissions been capped in 1908, human health and welfare would certainly have suffered during the 20th century. EPA should examine actual historical data to put the model projections into their proper context.

EPA argues the Clean Air Act is precautionary in nature. This is true, but EPA should not regulate greenhouse gases without compelling information that they are causing harm to human health and welfare. This information does not exist today.

EPA should be very cautious about inflicting harm on the economy through increased regulation because, as Lutter, Viscusi, and Morrell argue in their 1999 paper, every additional $15 million in regulatory costs leads to an additional statistical death. This is because regulatory costs impose costs on society that reduce income and in turn reduce expenditures on health and safety.

The regulation of greenhouse gases under the Clean Air Act would cost billions, if not trillions of dollars, and as Lutter, Viscusi, and Morrell point out, lead to great harm to human health and welfare.

There is Profound Scientific Uncertainty Concerning the Impact of Increasing Greenhouse Gases on Human Health and Welfare

The science of climate change is far more unsettled than EPA explains in the ANPR. EPA should fully examine the state of climate change science. Here are a few examples of issues EPA needs to address and understand before it can accurately state that greenhouse gases harm human health and welfare:

• The leveling off of global temperature. Since 2001, there has not been a statistically significant increase in temperature, even as carbon dioxide levels increased by 4 percent during this period. This leveling-off of global temperatures was not predicted by the global climate models. It is true that the climate is a complex system with many cyclical variations, but each passing year with flat temperatures (in spite of rising greenhouse gas concentrations) renders the most alarming projections less and less credible.
• Heat-related mortality. EPA argues that warmer temperatures will lead to greater heat-related mortality. While this makes intuitive sense, EPA should examine actual data on heat-related mortality. For example, in the United States heat-related morality has decreased even as temperatures increased from the 1970s through the 1990s. EPA fails to consider the countervailing economic and health-related improvements that have caused heat-related mortality to fall as temperatures have increased.
• Worse air quality. EPA argues that "the IPCC projects with virtual certainty" that warming will lead to worse air quality. This is highly unlikely. Instead of relying on the IPCC’s projections on air quality, EPA needs to examine its own air trends website. The website states that, “National average air quality continues to improve as emissions decline through 2007.” These improvements have occurred in spite of increasing population growth, GDP, vehicle-miles traveled, temperature, and greenhouse gas concentrations. There is no reason to believe the air quality trends will reverse.
• Sea level rise. There is nothing new about rising sea levels. Sea levels have been rising for the last 10,000 years—since the end of the last ice age. The real question is whether the rate of sea level rise is increasing. Recent papers by Holgate, Berge-Nguyen et al., and Unnikrishnan et al. all show no increase in the rate of sea level rise. If increased greenhouse gas levels were driving sea level rise, we should see an increase in the rate of sea level rise, but that has not happened.
• A national solution will not solve a global issue. The Clean Air Act is not an appropriate way to regulate greenhouse gases because greenhouse gases are a global issue, not just an issue for the United States. We could reduce our greenhouse gas emissions to zero, but even this dramatic result would not have much of an impact on global temperatures in the long run. The vast majority of increases in greenhouse gas emissions come from the developing world, not the United States. National policies can give incentives for manufacturers to move their operations to unregulated regions, paradoxically leading to higher emissions to produce the goods in question.
• EPA’s models should be open and transparent. EPA should not use closed-source models for critical projections and modeling. All the models EPA references should be available for public inspection and download. EPA should also detail all of the assumptions and documentation for the models. EPA should not hide key assumptions and projections from the public.
• The ANPR has many legal problems. For example, EPA writes that it has the authority under the Clean Air Act to implement a cap-and-trade scheme for greenhouse gases. This claim is unlikely to pass muster with the courts. The DC Circuit, in the recent CAIR decision, ruled that EPA does not have the authority to implement cap-and-trade under the Clean Air Act.

Conclusion: These are just a few of the reasons EPA should not use the Clean Air Act to regulate greenhouse gases, nor should it make a finding that greenhouse gases endanger public health and welfare. Although many climate scientists endorse man’s role in rising temperatures, there is no comparable consensus among economists, medical doctors, and other experts on the impacts such warming may have on human health and welfare. Indeed, poorly designed regulations could cause harms (in lost economic output) that far outweigh the modest benefits of lower greenhouse gas emissions.

Read the footnotes: http://www.americanenergyalliance.org/PDF/EPA_footnotes.pdf