Attempts to regulate greenhouse gases under the Clean Air Act would have numerous potentially harmful consequences, the National Petrochemical & Refiners Association told the US Environmental Protection Agency.
"The regulation of GHGs under the CAA would constitute EPA's single largest and potentially most complex assertion of authority over the [US] economy and Americans' lifestyles," the trade association warned in a Nov. 25 response to EPA's July 30 Advanced Notice of Proposed Rulemaking.
"Regulation of GHGs under the act would have enormous consequences for every facet of the economy, for industry large and small, as well as for the general population. Indeed, the potential impact on the country to regulate GHGs cannot be overstated and makes all prior EPA regulatory efforts pale by comparison," it maintained.
It said that EPA still has a lot of work to do before making a final decision on whether GHG emissions from automobiles cause or contributed to a US public health or welfare endangerment. EPA's analysis "draws most heavily on reports prepared by only a handful of entities, particularly the Intergovernmental Panel on Climate Change, and especially with respect to its analysis of human health and welfare effects," NPRA said in its filing.
"The agency has an obligation, however, to consider all relevant science on climate change, impacts, and effects on health and welfare. It may not disregard data without justification," the association said.
NPRA does not believe that EPA should proceed with an endangerment finding at this time nor begin a process of subjecting various entities to various CAA provisions in an effort to begin GHG emissions, NPRA President Charles T. Drevna said on Dec. 2.
"The act was not designed to address a global pollutant like [carbon dioxide] and, thus, cannot be used to meaningfully alter its atmospheric concentration. Indeed, EPA's suggested approaches for applying the CAA's provisions to GHG sources would impose severe costs on domestic industry, reduce our domestic energy security, and damage the national economy as businesses shift activities overseas to areas where they will not be subject to futile regulation," he said.
"Discussion of these issues in the ANPR is woefully inadequate, and the public should be given the opportunity to consider them before EPA makes any further decisions under the CAA," Drevna said.
Contact Nick Snow at firstname.lastname@example.org