EPA Limits On Greenhouse Gases Will Shift U.S. Production Overseas

Climate change represents a tough and complex policy issue. That’s the reason U.S. lawmakers — more than 30 years since scientists first introduced the concept of global warming into the American political dialogue — continue to debate the best way to structure legislation aimed at reducing greenhouse gas (GHG) emissions without damaging the economy.

As Congress debates domestic legislation, the administration participates in an international process with similar objectives.

As this takes place, the Environmental Protection Agency is engaging in a form of political blackmail, threatening to push ahead on its own if elected officials don’t move as quickly as the agency wants. It has already taken the first step toward leveraging the Clean Air Act to mandate GHG reductions.

Headed toward regulatory seppuku, the agency recently finalized a climate change determination that current concentrations of GHGs — about 435 parts per million (ppm) in CO2 equivalents — in the atmosphere endanger public health and welfare.

EPA makes this claim not because these emissions are toxic like pollutants covered by the Clean Air Act, but because of their heat-trapping capacity. EPA has accepted the theory that increasing emissions of these gases will lead to unprecedented increases in the earth’s temperature and that a much warmer earth will mean health- and even life-threatening problems.

Although it has been as warm or warmer in the past, EPA wants to act assuming a worst-case scenario — even if the probability of occurrence is incredibly small.

There is support for the theory (a theory, not a fact) that the projected path of human emissions will lead to global concentrations that pose a risk. The U.N.’s Intergovernmental Panel on Climate Change has set an ambitious goal of cutting GHG emissions so concentrations do not exceed 450 ppm and keeping the global average temperature increase below 2 degrees Celsius.

Leaving aside whether achieving such a goal is even technologically or economically feasible, let’s focus on the fact that the international goal — which the Obama administration has acknowledged in the Copenhagen Accord — represents a higher concentration than what EPA claims is already endangering all of us.

If EPA Administrator Lisa Jackson really believes this, she must be setting the stage for a massive regulatory assault by declaring that any increase in GHG concentrations will further harm human health and welfare. Once the agency determines that current concentrations of greenhouse gases are unhealthy, how can U.S. negotiators agree to a U.N. limit that is higher?

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