Comment to EPA: Regulating Greenhouse Gas Emissions under the Clean Air Act
- Nov 18, 2008 - comment
The Environmental Protection Agency (EPA) is asking for public comments through Nov. 28 on a proposal to regulate carbon dioxide (CO2) and other greenhouse gas emissions that would financially burden families, churches, and businesses. It’s very simple to submit a comment. Visit www.regulations.gov , enter “EPA-HQ-OAR-2008-0318-0117” in the search box, and hit “go.” Then click “send a comment or submission.” You will then be able to enter your own comments. We have provided this sample comment to help you write yours. Or, if you prefer, you can simply submit our sample comment as your own. Just copy all or part of our sample comment and paste it in the EPA comment box.
The potential regulations on greenhouse gas (GHG) emissions under the Clean Air Act prescribed by the Environmental Protection Agency’s staff in the Advance Notice for Proposed Rulemaking (ANPR) should be rejected as they would unduly burden American families, churches, and businesses, and would especially harm poor Americans. The regulations would touch everyday household items such as lawn mowers, trimmers, and power generators, hurting the daily lives of Americans and small business owners. The impact on larger businesses would be catastrophic as well, encompassing everything from the buildings themselves down to the everyday equipment used in construction and in warehouses. Due to the regulations of small and large business equipment and facilities, the proposals in the ANPR would also be tragic for American employment, especially jobs held by lower-income Americans, such as manufacturing, physical labor, and energy jobs. Finally, the regulations could have significant financial ramifications for many religious organizations, as estimates suggest that 10 percent of religious buildings would be affected by the EPA’s proposal. Yet, despite the extreme costs that would be leveraged on people, businesses, and community organizations across the nation, meaningful reduction in GHG emissions is far from guaranteed, as developing nations—many of the world’s leading energy consumers—would offset any GHG reductions in the United States; and, any potential reduction that could be achieved would be slight and not worth the severe financial and social hardships that would have to be endured.
In light of the recent rejection of the Lieberman-Warner bill in Congress due to the outrageous costs that would be borne by everyday consumers, it is appalling that proposals have been presented that would undoubtedly cause even more economic hardship than the cap-and-trade legislation soundly defeated by legislators representing concerned American voters. As the Department of Energy stated in its comment, the regulation of stationary sources under the proposal “would likely dramatically increase the price of energy in this country” and would “increase costs associated with direct energy use . . . by sources such as schools, hospitals, apartment buildings, and residential homes.” The Department of Commerce has also highlighted the possibility of churches, along with hotels and police stations, coming under the regulatory clutches of the EPA. American families and businesses already face high energy costs, and the adoption of these proposed regulations, which would result in increased energy costs, would reflect a dearth of understanding of the needs and well-being of everyday Americans. The further rise in energy costs would be most devastating to low-income Americans with little disposable income, as energy expenditures are a much higher percentage of their household budgets.
Beyond jobs and energy consumption, our nation’s food supply would also be affected, again placing hardship on everyday consumers. The increases in energy and transportation costs would apply to farmers as well, and in a dramatic fashion. The production methods and tractors used by farmers universally involve complex technology dependent on the consumption of energy, from diesel to natural gas to electricity. The increases in costs associated with the proposed regulations would be passed on to consumers and further increase the cost of food on top of the recent inflation in food prices due to already high energy and commodity prices. It is also likely that increased business costs would result in decreased supply, again causing prices to rise. These effects cannot be afforded by American farmers or the end consumer, especially as consumers would, at the same time, be facing higher energy costs.
In addition to the negative effects the EPA’s proposed GHG regulations would have on jobs and businesses in America, of particular concern is the potential to burden American religious organizations. The Department of Commerce has already highlighted the financial burdens that the proposed regulations would place on churches and community organizations, but I find it necessary to expand upon this concern. Many churches could suffer the double-effect of having their energy expenditures greatly increased while seeing their donations reduced. Under the proposal, the EPA would impose regulations on any building that emits over 250 tons of carbon dioxide a year, which is approximately $70,000 in energy use. This would cause a huge financial burden to many medium to large churches and nonprofit organizations. No matter if religious buildings would be affected, the increase in food and energy costs to ordinary Americans and the decrease in middle- and lower-class jobs would cripple the donations to local religious and community organizations. Facing the potential for increased costs, along with decreased donations, many religious organizations would be forced to curtail their community projects, reduce their care for the poor, and decrease their paid staff, adding further burden to American communities that would already be suffering from the direct effects of the GHG regulations.
Beyond the direct economic impact of the proposals in the ANPR, the proposed regulations also represent an extraordinary government invasion into the daily lives of American individuals. In addition to the lawn care appliances which would be regulated, recreational vehicles, such as all-terrain vehicles (ATVs), dirt bikes, boats, and snowmobiles, could also be affected. Concern for the environment by citizens is important, but it must also be recognized that citizens should be able to enjoy that environment and care for their land without being unduly hampered by agency regulations. In fact, if costs for those appliances and vehicles increase, consumers would be more likely to rely on older, less environmentally sound devices, defeating the purpose of the new regulations. In addition, the various standards that would have to be developed for each device (such as a “standard lawn” measure for mowers or grams per kilogram-meter measure for forklifts) would differ greatly for the different types of machines and create a massive quagmire of regulatory measures.
I agree with Administrator Johnson that the Clean Air Act is “an outdated law…ill-suited for the task of regulating global greenhouse gases.” I also agree with his prediction that “pursuing this course of action would inevitably result in a very complicated, time-consuming and, likely, convoluted set of regulations.” Such a monstrous regulatory nightmare is unnecessary and would be detrimental to the economic well-being of our citizens, churches, and businesses. Although I respect the decision of the Supreme Court, despite my profound disagreement, the possible regulations that have been presented by the EPA staff cross the line of what is necessary, beneficial, or feasible. I support Administrator Johnson’s views and emphatically reject the potential regulations of GHGs under the Clean Air Act enumerated in the ANPR.
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