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Five Reasons the EPA Should Not Attempt to Deal with Global Warming
The Heritage Foundation ^ | April 23, 2009 | Ben Lieberman and Nicolas Loris

Posted on 04/26/2009 12:42:44 PM PDT by Conservative Coulter Fan

On April 17, the Environmental Protection Agency (EPA) issued an endangerment finding, saying that global warming poses a serious threat to public health and safety. Thus, almost anything that emits carbon dioxide and other greenhouse gases could be regulated under the Clean Air Act. This is the first official action taken by the federal government to regulate carbon dioxide.

The endangerment finding is the initial step in a long regulatory process that could lead to the EPA requiring regulations for almost anything that emits carbon dioxide. Automobiles would likely be the first target, but subsequent regulations could extend to a million or more buildings and small businesses, including hospitals, schools, restaurants, churches, farms, and apartments. The following five reasons explain why this would be a big, costly mistake.

1. It's an Economy Killer

Above anything else, any attempt to reduce carbon dioxide would be poison to an already sick economy. Even when the economy does recover, the EPA's proposed global warming policy would severely limit economic growth.

Since 85 percent of the U.S. economy runs on fossil fuels that emit carbon dioxide, imposing a cost on CO2 is equivalent to placing an economy-wide tax on energy use. The Heritage Foundation's Center for Data Analysis study of the economic effects of carbon dioxide cuts found cumulative gross domestic product (GDP) losses of $7 trillion by 2029 (in inflation-adjusted 2008 dollars), single-year GDP losses exceeding $600 billion in some years (in inflation-adjusted 2008 dollars), energy cost increases of 30 percent or more, and annual job losses exceeding 800,000 for several years. Hit particularly hard is manufacturing, which will see job losses in some industries that exceed 50 percent.[1]

High energy costs result in production cuts, reduced consumer spending, increased unemployment, and ultimately a much slower economy. But importantly, higher energy prices fall disproportionately on the poor, since low-income households spend a larger percentage of their income on energy.

2. Negligible Environmental Benefit

The extraordinary perils of CO2 regulation for the American economy come with little, if any, environmental benefit. In fact, analysis by the architects of the endangerment finding, the EPA, strongly suggests that a 60 percent reduction in carbon-dioxide emissions by 2050 will reduce global temperature by 0.1 to 0.2 degrees Celsius by 2095.[2]

Some environmental alarmists believe saving the environment should come at any cost, but when the benefit is barely noticeable, such an extreme viewpoint still cannot be justified.

3. Lack of Scientific Consensus

The decision to regulate carbon dioxide and five other greenhouse gases was supported by supposed compelling scientific evidence. For example, EPA administrator Lisa Jackson "relied heavily upon the major findings and conclusions from recent assessments of the U.S. Climate Change Science Program and the Intergovernmental Panel on Climate Change [IPPC]."[3] Additionally, the EPA cited harmful impacts including increased droughts, floods, wildfires, heat waves, and sea level rises as a result of climate change. But the reality is that natural disasters are just that--they occur with or without global warming.

The scientific consensus behind global warming, especially the seriousness of the impacts, is anything but strong. Last December, the U.S. Senate Minority released a report that included 650 dissenting scientists refuting claims made in the IPCC report.[4] That number has grown to over 700, more than 13 times the number of scientists (52) who had a direct role in the IPCC report.

4. Backdoor Policy

The United States Congress has been reluctant to pass any global warming legislation or engage in international climate reduction treaties. Last year's most noted global warming legislative proposals was S. 2191, the America's Climate Security Act of 2007, originally sponsored by Senators Joe Lieberman (I-CT) and John Warner (R-VA).

This cap-and-trade bill would have set a limit on the emissions of greenhouse gases, especially carbon dioxide from the combustion of coal, oil, and natural gas. A number of concerns existed, chief among them the impact on already-soaring gasoline prices, and consequently the bill was withdrawn by its Senate supporters after only three days of debate.

While some Members of Congress undoubtedly support the EPA's attempt to curb global warming, the fact that unelected and unaccountable EPA bureaucrats are trying to bypass legislative efforts makes it all the more objectionable.

Equally indefensible is any attempt to use the threat of EPA regulations to induce Congress into enacting a cap-and-trade bill it would not support otherwise. Members should not be forced to prematurely pass a bill without fully understanding its effects and consequences.

5. Expanded Bureaucracy

Having EPA bureaucrats micromanage the economy, all in the name of combating global warming, would be a chilling shift to a command-and-control system in which EPA officials regulate just about every aspect of the market.

Beyond the costs of such actions, the red tape and permitting delays are almost unfathomable. Though the Administration recently enacted a stimulus bill and touted "shovel ready" construction projects to boost the economy, EPA regulations would essentially assure that a great deal of such economic activity would be held up for months, if not years.

For instance, the National Environmental Policy Act (NEPA) requires federal agencies to file environmental impact statements for EPA review before moving forward with projects. According to the Government Accountability Office, normally it takes a federal construction project an average of 4.4 years to complete a NEPA review. Along with the Clean Water Act's Section 404 requirements, before a shovel can break ground, it could take 5.6 years for a project to jump through all the normal environmental hoops.[5] Granting the authority for one of the largest and unprecedented regulatory undertakings in U.S. history would greatly expand the EPA's power.

The kind of industrial-strength EPA red tape that routinely imposes hundreds of thousands, if not millions, of dollars in compliance costs could now be imposed for the first time on many commercial buildings, farms, and all but the smallest of businesses. Not only would these costs and delays hamper the private sector, but the paperwork could paralyze federal and state environmental regulators, drawing resources away from more useful endeavors.

A Dangerous Step

The EPA's official announcement commences a 60-day public comment[6] period before the agency issues a final ruling. Using the Clean Air Act to regulate CO2 would likely be the most expensive and expansive environmental regulation in history and will bypass the legislative process completely. In essence, the decisions of few will drastically alter the lives of many--all for a change in the Earth's temperature too small to ever notice.

Ben Lieberman is Senior Policy Analyst in Energy and the Environment and Nicolas D. Loris is a Research Assistant in the Thomas A. Roe Institute for Economic Policy Studies at The Heritage Foundation.

[1]David Kreutzer and Karen A. Campbell, "CO2-Emission Cuts: The Economic Costs of the EPA's ANPR Regulations," Heritage Foundation Center for Data Analysis Report No. 08-10, October 29, 2008, at

[2]David Kreutzer, "The Economics of Cap and Trade," testimony before the Ways and Means Committee, U.S. House of Representatives, September 18, 2008 at

[3]Environmental Protection Agency, "Overview of EPA's Proposed Endangerment and Cause or Contribute Findings for Greenhouse Gases under the Clean Air Act," April 17, 2009 at
(April 23, 2009).

[4]Marc Morano, "UN Blowback: More Than 650 International Scientists Dissent over Man-Made Global Warming Claims," U.S. Senate Committee on Environment and Public Works, December 10, 2008, at
(April 23, 2009).

[5]U.S. Department of Transportation, Federal Highway Administration, "Evaluating the Performance of Environmental Streamlining: Development of a NEPA baseline for Measuring Continuous Performance," at (April 23, 2009).

[6]Comments can be submitted at, (


TOPICS: Business/Economy; Front Page News; News/Current Events; Politics/Elections
KEYWORDS: bho44; bhoenvironment; bhoepa; heritagefoundation

1 posted on 04/26/2009 12:42:44 PM PDT by Conservative Coulter Fan
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To: Conservative Coulter Fan

6. We’re in the tenth straight year of global cooling.

2 posted on 04/26/2009 12:46:52 PM PDT by T. Jefferson (Batton down the hatches, full speed in reverse)
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To: Conservative Coulter Fan; FrPR; enough_idiocy; Desdemona; rdl6989; Little Bill; IrishCatholic; ...
This is all about a Big Government money and power grab, and flunky bureaucrats are not about to be deterred.


Beam me to Planet Gore !

3 posted on 04/26/2009 12:46:59 PM PDT by steelyourfaith ("The problem with socialism is that you eventually run out of other people's money." - Lady Thatcher)
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To: steelyourfaith
"Flunky bureaucrats" are usually hired long after the policy decisions are made ~ they're just people doing jobs.

The problem is in the private sector with the big foundations and the rich pukes like Bill Gates, Warren Buffett and others.

This can all be brought to a big screeching halt if we can derail their ability to file lawsuits.

4 posted on 04/26/2009 12:50:11 PM PDT by muawiyah
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To: Conservative Coulter Fan
The EPA kind of reminds me of a government sponsored PETA(People Eating Tasty Animals)...It always amazes me what a waste of time and money they are. They basically sit around and analyze each other's farts and when they get bored of that, they work on animal farts. Another waste of money government bureaucracy at it's best..
5 posted on 04/26/2009 12:56:44 PM PDT by KLT (A damn Yankee, from the great state of Mississippi....Go Freepers Go!)
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To: muawiyah
Leftists predominate throughout the Washington, D.C., bureaucracies. It is a company town, and the company is Big Government.

Bureaucrats are not elected, they can not be voted out, they are entrenched by unionization, and they do considerable damage on their own initiative to Constitutional freedoms of the people who make the country work.

Federal bureaucracies like the EPA are predominantly staffed by flunkies.

6 posted on 04/26/2009 1:06:43 PM PDT by steelyourfaith ("The problem with socialism is that you eventually run out of other people's money." - Lady Thatcher)
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To: steelyourfaith
Might surprise you but 100% of the people in federal government jobs where they "make policy" are NOT UNIONIZED at all.

Your letter carriers, postal clerks, mailhandlers, pressmen at Treasury, National Park Service rangers and police, etc. ARE NOT policy makers.

7 posted on 04/26/2009 1:16:01 PM PDT by muawiyah
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To: Conservative Coulter Fan

How about this one - “They’ve got no constitutional authority to do so”?

8 posted on 04/26/2009 1:35:20 PM PDT by DuncanWaring (The Lord uses the good ones; the bad ones use the Lord.)
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To: muawiyah

You neglected to mention the EPA union employees who do the leg work, just as do congressional staffers who are fronted by Reps and Senators. There are opportunities in that culture for agenda wiggle room.

9 posted on 04/26/2009 1:45:27 PM PDT by steelyourfaith ("The problem with socialism is that you eventually run out of other people's money." - Lady Thatcher)
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To: steelyourfaith

10 posted on 04/26/2009 1:47:11 PM PDT by muawiyah
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To: steelyourfaith
Take a look at the ref. The antifluoride people appear to be in charge of those unions.

Well, end of that problem.

BTW, most recognized "unions" in the federal government involve folks at the GS5/7 levels. Those are universally NON POLICY POSITIONS.

There are some so-called "unions" at higher levels but the real decision making bureaucrats are up there at GS 13/15, and in what used to be called the super-grade ranks, and at the levels of the appointees. Even GS 13/15 does not involve "policy making" although it has been known..... but I'm not telling, OK!

11 posted on 04/26/2009 1:49:46 PM PDT by muawiyah
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To: muawiyah
If at nowhere else, when these unionized government employees interface with the private sector they have discrimination to cause havoc with their interpretations of official policy, and the onus and expense is on the private citizen if he/she chooses to dedicate time challenging it.
12 posted on 04/26/2009 2:01:47 PM PDT by steelyourfaith ("The problem with socialism is that you eventually run out of other people's money." - Lady Thatcher)
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To: Conservative Coulter Fan

The Left is now referring to energy-intensive industries as “carbon polluters.”

Most people call them “employers.”

13 posted on 04/26/2009 2:21:30 PM PDT by Winged Hussar (
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To: steelyourfaith
Every federal agency has an appeals authority somewhere and a set of rules regarding what you do when your interpretation differs from theirs.

This is part of the Constitutinal doctrine referred to as "administrative due process".

Once you have completed "administrative due process" and have a letter in hand from an appropriate agency director that says "final agency decision" you can go to court.

There are other methods ~ go up the line to the guy's boss. Buy his boss a new car, maybe a boat.

There are a myriad of ways to handle this.

Usually the agency employees who make the decision are going to be found to be correct because, as it turns out, they work this stuff all the time and know what the winning answers are.

You can hire lawyers to handle this stuff for you ~ they specialize by agency.

14 posted on 04/26/2009 2:29:02 PM PDT by muawiyah
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To: Conservative Coulter Fan

Not one of these will make a damned bit of difference to the EPA.

15 posted on 04/26/2009 3:28:36 PM PDT by Lurker (The avalanche has begun. The pebbles no longer have a vote.)
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To: Conservative Coulter Fan

marker to the dirtballs

16 posted on 04/26/2009 3:57:33 PM PDT by BonRad (As Rome goes so goes the world)
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To: muawiyah
I'm a small business owner, and oh yeah, I've had some anecdotal experience with appeals. I don't budget for possible legal contingencies.

Long story, I'll make as brief as I can:
I had a female employee who told me that she just became aware that she was pregnant. I congratulated her and told her she could work as far into her pregnancy as she would like, and that the job would be available at the time of her choosing after the delivery. I asked her only to please give me a heads up when she planned to take off as her position was critical to the functioning of my office and I needed at least a couple of months to break in someone to handle her responsibilities. I figured I'd have several months at least to line up and train a temporary replacement without loss of productivity and my responsibility to my patients.

The next working day she failed to show up. We could not contact her. She did not answer her telephone. We had to hustle and find some temporary help. Days later she surfaced wanting her paycheck. I wrote her out a check for the days she worked. No statement about quitting was spoken by either party, but it was obvious she had quit on me.

Sometime later I am contacted by the state that my unemployment fund rate had gone up as I had a claim against me. It was the pregnant lady who had left us high and dry. Great. I should have seen it coming.

I appealed. A time was arranged with a three way telephone call (former employee, state employee and me). Three times during the phone call the employee started sentences with, "I quit because...(one inane reason after another)".

The state upheld her claim, and my unemployment tax mandate increased. I could hardly believe it.

Yes, I have little faith in the fair, equitable and wise machinations of government.

Almost without fail, every year my practice receives notification of some newly vested government bureaucracy (state, federal or county) that some additional aspect of my business is now subject to regulation, inspection and taxation.

Compliance is an expense that I must pass on to my patients, and if I can't pass it on I could find it necessary to close down my business.

I don't know how my profession managed to help people over the years without all this help from the government. < / s >

Of course, my experiences are merely a microcosm of what is happening nationwide.

I despise socialism, and mourn the systematic destruction of the Constitution.

17 posted on 04/26/2009 6:08:31 PM PDT by steelyourfaith ("The problem with socialism is that you eventually run out of other people's money." - Lady Thatcher)
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To: steelyourfaith
Still, what you are talking about is an employer/employee relationship, and that has its own set of specialized laws.

Here's a clue for you ~ do not engage in phone calls in such matters. Odds are pretty good that you can represent yourself well enough, so demand a HEARING IN PERSON.

If you are "incorporated" you will need to have a lawyer along.

BTW, if you are "incorporated" that call would have never needed more than your lawyer to handle. The state employee would have probably cited some regulatory requirements under the applicable statutes and your lawyer would agree or disagree and toss a couple of references back at him.

Regarding your pregnant employee's "excuses", what were they?

18 posted on 04/26/2009 6:16:19 PM PDT by muawiyah
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To: Conservative Coulter Fan
How about the real #1?

The premise these "solutions" are based upon (that man causes "it," and man can reasonably do something about "it," when "it" itself is in dispute) is a big fat lie.

19 posted on 04/27/2009 6:43:36 AM PDT by vox_freedom (If there were no God, there would be no Atheists. - G. K. Chesterton)
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