EPA Fails To Properly Assess Risk Of Greenhouse Gases

Pushed by the Supreme Court to make a determination whether “greenhouse gases” are dangerous to public health, the EPA recently decided that CO2 is a Very Bad Thing.  You know CO2, that pesky stuff that is part of the circle of life because all us mammals exhale it and then trees and other growing plants inhale it because they need it to survive, and then they exhale oxygen that we in turn inhale because we need it to survive, and so on.

This definition of CO2 as a danger to public health fits in very nicely with President Obama and his administration’s push for cap & trade.  You know cap & trade, that pesky little credit scheme for alleged polluters that Obama “promises” us isn’t a tax but will raise the price of everything from heating and cooling to transportion to goods and even food because manufacturers have to recoup their increased cost of doing business and the only way to do that is to pass on their costs to we, the consumers. 

Well, even though it’s now obvious the change Obama spouts on about on his never-ending campaign trail means only grabbing what’s left of it in our wallets, it seems that some folks in Obama’s administration have taken a look at what will happen if the government steps in to regulate greenhouse gases during this truly manmade “climate change” in the American economy.  And what they see is what many of us have been saying all along.

Cap and trade, not CO2, is the Very Bad Thing.

CBS’s Jake Tapper has reported that an interagency review memo warns the EPA that government regulation is not only a bad move economically, but it also raises the more dangerous question about government regulation.  Here are some of the highlights:

 The finding rests heavily on the precautionary principle, but the amount of acknowledged lack of understanding about basic facts surrounding GHGs seem to stretch the precautionary principle to providing for regulation in the face of unprecedented uncertainty.

Since tropospheric ozone is already regulated under the Clean Air Act, EPA should explain why those regulations are inadequate to protect public health from the ozone impacts of climate change.

The Finding should also acknowledge that EPA has not undertaken a systematic risk analysis or cost-benefit analysis.

 …there is a concern that EPA is making a finding based on

(1) “harm” from substances that have no demonstrated direct health effects, such as respiratory or toxic effects,

(2) available scientific data that purports to conclusively establish the nature and extent of the adverse public health and welfare impacts are almost exclusively from non-EPA sources, and

(3) applying a dramatically expanded precautionary principle.

If EPA goes forward with a finding of endangerment for all 6 GHGs, it could be establishing a relaxed and expansive new standard for endangerment. Subsequently, EPA would be petitioned to find endangerment and regulate many other “pollutants” for the sake of the precautionary principle (e.g., electromagnetic fields, perchlorates, endocrine disruptors, and noise).

Making the decision to regulate CO2 under the CAA for the first time is likely to have serious economic consequences for regulated entities throughout the U.S. economy, including small businesses and small communities.

To the extent that climate change alters our environment, it will create incentives for innovation and adaptation that mitigate the damages from climate change. The document should note this possibility and how it affects the likely impacts of climate change.

…the document would appear more balanced if it also highlighted whether particular regions of the US would benefit, and to what extent these positive impacts would mitigate negative impacts elsewhere in the United States.

…there should be a consideration of the fertilizing effect of CO2, which may overwhelm the negative impact of additional hot days on agricultural yields in some regions of the US.

… it is not clear why they [perfluorocarbons and sulfur hexafluoride] are included in the endangerment and “cause or contribute” findings.

 EPA would benefit from making its position explicit in this proposal. Commenters are sure to take this important issue on in some fashion so EPA may as well do what it can to shape the debate and the comments being invited.

 The proposed Finding erroneously suggests that Intergovernmental Panel on Climate Change (IPCC) predicts an increase in both crop and forest production in the U.S.  Significant increases in production may be possible within North America as a whole, but are unlikely within the U.S. itself.

These are your tax dollars at (shoddy) work, but the administration isn’t listening, of course.  Representative Henry Waxman (D-CA) was to meet with his Democrat pals behind closed doors today (there’s more of that promised “transparency” for you)  to discuss his “Waxman-Markey American Clean Energy and Security Act of 2009” – because the President would prefer legislation instead of demanding it himself.  The better to claim the resulting economic collapse isn’t his fault, of course.