Paul Driessen, with the Committee For A Constructive Tomorrow, submits comments to the Federal Government in response to the Advance Notice of Proposed Rulemaking (ANPR) on Regulating Greenhouse Gases under the Clean Air Act (CAA), issued by the Environmental Protection Agency (EPA) and published in the Federal Register on July 30, 2008.

Based on its careful analysis of this ANPR and its likely impacts on American businesses, jobs, minorities, low and fixed income families, and others, the Committee For A Constructive Tomorrow concludes that EPA should not make an endangerment finding or promulgate these proposed rules. Such an action would have disproportionate impacts on minorities and would violate civil rights and accepted standards of science, economics and environmental justice.

The Clean Air Act is not an appropriate vehicle for regulating greenhouse gas emissions. EPA Administrator Stephen Johnson himself has noted: the Clean Air Act is “outdated,” intended to control “regional pollutants that cause direct health effects,” and “ill-suited for the task of regulating global greenhouse gases.” Pursuing the course of action outlined in the ANPR, he continued, “would inevitably result in a very complicated, time-consuming and likely convoluted set of regulations” that “would have a profound effect on virtually every sector of the economy and touch every household in the land.” Making a finding that CO2 emissions “endanger” the health and welfare of American citizens — and promulgating rules to restrict and control energy use and greenhouse gas emissions — would have major, far-reaching and harmful impacts on millions of businesses and families. Poor and minority families would be especially hard hit. Moreover, the environmental benefits of these proposed rules would be minimal, at best.