A leaked memo from the Office of Management and Budget (OMB) questions the EPA findings on CO2 being a “threat to human health”.

The leaked internal memo was marked “Attorney Client Privilege”.

It has some strong language about the negative impact EPA regulation of CO2 would have on the U.S. economy: “Making the decision to regulate CO2…is likely to have serious economic consequences for regulated entities throughout the U.S. economy, including small businesses and small communities.”

The memo further indicates that the burden of proof of CO2 as harmful isn’t there, and the EPA finding last month that greenhouse gases are a danger to public health rests on dubious assumptions and could have negative economic impacts, the memo warned.

The memo has no listed author but is marked “Deliberative–Attorney Client Privilege.” A spokesman for OMB told Dow Jones Newswires that the brief is a “conglomeration of counsel we’ve received from various agencies” about the EPA finding, the conclusions of which would trigger regulation of greenhouse gases under the Clean Air Act.

The author(s) of the memo suggest the EPA did not thoroughly examine the relationship between greenhouse gases and human health.

In the absence of a strong statement of the standards being applied in this decision, there is concern that EPA is making a finding based on…’harm’ from substances that have no demonstrated direct health effects,” the memo says, adding that the “scientific data that purports to conclusively establish” that link was from outside EPA.

Importantly, there’s language in the memo that says there may be beneficial effects to increased CO2 rather than negative effects, and that man, as always, can quickly adapt:

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