The Heartland Institute provided the following comments about the U.S. Environmental Protection Agency’s proposed regulation of six greenhouse gases under the Clean Air Act, 42 U.S.C. §7401 et seq., as detailed in the ANPR.
For the reasons discussed below, the ANPR and its supporting documentation violate the Information Quality Act, 44 USCS § 3516, et seq.; the Office of Management and Budget’s Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by Federal Agencies, 67 Fed. Reg. 8452 (February 22, 2002) (“OMB Guidelines”); and the Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by the Environmental Protection Agency (updated as of 2005) (“EPA Guidelines”).
Much of the scientific evidence put forth by the staff of EPA in the proposed ANPR and its supporting Endangerment Technical Support Document (Technical Support Document for Endangerment Analysis for Greenhouse Gas Emissions under the Clean Air Act, Sixth Order Draft (June 4, 2008) (“EPA Endangerment TSD”) has taken the melodramatic form of climate alarmism without the balance of scientific and economic rationale that should have equal weight in determining any environmental policy undertaken by the Environmental Protection Agency or the U.S. government with such a dramatic impact on U.S. economic and energy security. There appears to be a significant omission of climate science data published after 2006 as well as a coherent review of the opposing views in the scientific literature. This is in violation of the Information Quality Act requirements.