Comment Solicitation
EPA limits solicitation of comment on the proposal to the simple statements on page six to the effect that it seeks comment on all aspects of this action (data, methodology, and major legal and policy considerations). While this is efficient and legally sufficient, the agency may want to highlight a few key areas in which
Accounting for the Global Nature of Greenhouse Gas Pollution in the Findings
In this draft proposal, EPA finds under Clean Air Act (CAA) section 202(a) that (1) “air pollution” in the form of the global mix of six greenhouse gases (or the GHGs) may be reasonably anticipated to endanger public health and welfare (the endangerment finding); and (2) emissions of an “air pollutant” in the form of
Agency compliance with other environmental mandates
There is some concern that an endangerment finding, and some of the language used to support the finding, will make it more difficult to comply with NEPA and other environmental planning statutes. This finding and the associated emission standards for these six greenhouse gases.
The role of mitigation, adaptation, and/or benefits of climate change
To the extent that climate change alters our environment, it will create incentives for innovation and adaptation that mitigate the damages from climate change. The document should note this possibility and how it affects the likely impacts of climate change.
