Discussion of Scientific Support and Analysis [of EPA’s Notice of Proposed Rulemaking on Climate Change]

The Environmental Protection Agency's proposed finding that greenhouse gases endanger public health could lead to “serious economic consequences” for small businesses, according to a memo from the White House Office of Management and Budget. The memo also suggested an endangerment finding might not be the best approach for regulating emissions and the proposal fails to provide adequate scientific backing for its conclusions that greenhouse gases endanger health. Moreover, it applies “a dramatically expanded precautionary principle,” whereby the agency adopts a regulatory approach even though there may be no direct link between exposure to a pollutant and a specific health effect. The undated memo was circulated at a Senate hearing May 12 after being posted to the public docket on the proposed finding April 22.