AEA Comments on EPA’s Flawed Greenhouse Gas Regulation Scheme

The American Energy Alliance recently sent comments to EPA on EPA’s plan to regulate greenhouse gases. We will continue to fight against ideological fringe groups to who are working to dramatically increase the cost of energy in America.

This past summer, EPA released an "Advance Notice of Proposed Rulemaking" (ANPR) that outlined how it might go about shoehorning the ability to regulate carbon, at best (outright criminalize it, at worst) into the authority already assigned to the EPA by the Clean Air Act. The comment period for these proposed regulations ended on Friday.

AEA was instrumental in building an aggressive coalition aimed at exposing the folly of allowing an army of federal bureaucrats to unilaterally regulate 85 percent of the output of America’s economy. We used our grassroots network to generate more than 6,600 comments from individuals to EPA, and produced a series of detailed comments explaining some of the many ways in which theANPR was flawed. 

The following represent some of the highlights of our analysis:

  • EPA outright ignores the impact of greenhouse gas emissions from developing countries in its analysis.
    • EPA does not consider that China is the world’s #1 emitter of carbon dioxide.
    • Since 2000, China’s greenhouse gases emissions have nearly doubled, India’s increased by 36%, Russia’s increased by 10%, but the U.S.’s only increased by 3%.
  • EPA does not explain why global temperature has not increased since 2000. This seems a very important fact if EPA is supposed to regulate greenhouse gases in the name of global warming.
  • EPA Administrator Johnson stated that the Clean Air Act is "ill-suited for the task of regulating greenhouse gases." This is true:
    • If EPA regulates greenhouse gases under one section of the Clean Air Act, it will be forced to regulate greenhouse gases under other sections, creating an uncontrollable regulatory cascade that may include a national ambient air quality standard for greenhouse gases, and numerous other regulations.
    • EPA’s regulation of carbon dioxide would lead to a series of bizarre and unpalatable outcomes, such as a tax on every dairy cow of $175 per year, a tax on every head of cattle of $44 per year, and a tax on every hog of $20 per year as a result of the greenhouse gas "emissions" of these entities.
    • EPA would also be forced to regulate building structures ranging in size from a sports arena to a church. Also to be caught up in the net: schools, hospitals, and office buildings, and possibly even lawn mowers, depending on their size. The impact of this would be immediate, and its consequences would not be pretty.

The Clean Air Act is indeed ill-suited to regulate greenhouse gases. AEA will continue to leverage our grassroots and in-house scholars to explain the flaws of these massive attacks on freedom and affordable energy.

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