Advanced Notice of Proposed Rulemaking for Greenhouse Gases Under the Clean Air Act, EPA-HQ-OAR-2008-0318-0117 [ANPR]

Published November 28, 2008

Clearly, the ANPR is attempt to develop a carbon management tool by the U.S. government that, in effect, reduces the use of fossil fuels in the development and distribution of energy across the electricity and transportation modes for the industrial, commercial, and residential sectors of our economy. This policy, in effect, selects fuels or technologies that have not yet proven themselves to be economically efficient or reliable for affordable energy. A carbon cap and trade system, even a carbon tax, simply redistributes wealth from the consumer to a corporate carbon exchange or to government. Neither model effectively reduces greenhouse gas emissions from the atmosphere by any legitimate or reliable measurable standard, but they significantly restrict the nation’s economic growth in numerous economic studies.

The EPA should not implement the ANPR as it is proposed or establish an endangerment finding under the Clean Air Act. To do so will significantly place an undue burden of high energy prices on individual consumers as they go about their daily lives and impair the U.S economy and reduce our ability as a nation to compete in the global market place.