On the EPA’s Proposed Endangerment Finding, the NAM Comments

The comment period closed on Tuesday for the EPA’s proposed endangerment finding for carbon dioxide and other “greenhouse gases” under the Clean Air Act. The National Association of Manufacturers submitted comments, which you can read at www.nam.org/endangerment. Excerpt:

The NAM’s mission is to enhance the competitiveness of manufacturers and improve American
living standards by shaping a legislative and regulatory environment conducive to U.S. economic growth. As a general matter, the NAM supports EPA regulations that are designed to provide net benefits to environmental quality and the public health, including the health of manufacturing workers and their families. Conversely, NAM opposes regulations that would impose overly burdensome compliance costs on the manufacturing sector, especially those with no clear goal for achieving improved environmental quality.

Applying these principles here means that NAM must oppose EPA’s proposed endangerment determination. An endangerment determination by EPA is not simply an observation by the agency about climate change nor is it simply a straightforward recitation of scientific data. Rather, it is a policy determination, which must be based on a solid factual record, and which, once made, will have profound consequences for American workers and businesses. A positive endangerment determination would trigger an unprecedented expansion of the EPA’s regulatory authority over the American economy because it would allow – and in some cases require – EPA to regulate domestic emissions of carbon dioxide and other GHGs. Regulated entities would include thousands of stationary sources and millions of motor vehicles. Such action will provide no net benefits to environmental quality, but will result in serious risks to our nation’s short-term economic recovery and long-term international competitiveness. EPA regulation of GHGs as air pollutants under the Clean Air Act would even hinder the manufacturing sector’s ability to deploy the advanced technologies which will be necessary to deal effectively with the challenges posed by GHG emissions, therefore undermining the objectives of any rational federal climate policy.

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