November 25, 2008
Air and Radiation Docket
U.S. Environmental Protection Agency
Mailcode 2822T, 1200 Pennsylvania Avenue, NW
Washington, D.C. 20460
Re: RDC comments on regulating greenhouse gas emissions under the Clean Air Act; Advanced Notice of Proposed Rulemaking; Docket ID No. EPA-HQ-OAR-2008-0318
The Resource Development Council (RDC) appreciates the opportunity to comment on the Advanced Notice of Proposed Rulemaking (ANPR) on regulation of greenhouse gas (GHG) emissions under the Clean Air Act (CAA). RDC is an Alaskan‐based, non‐profit, business association comprised of individuals and companies from Alaska’s oil and gas, mining, timber, tourism and fishing industries. Our membership also includes Native regional and village corporations, local governments, organized labor and industry support firms. RDC’s mission is to grow Alaska’s economy through the responsible development of natural resources.
RDC opposes the regulation of GHG emissions through the CAA. Separate legislation should be pursued in Congress that addresses greenhouse gases directly, rather than using the CAA. Using the CAA to regulate carbon dioxide is much like using the Endangered Species Act listing of polar bears to regulate climate change. Neither is appropriate.
Separate GHG emission legislation should be based on sound environmental and economic principles within the context of U.S. energy needs and the national economy. Such legislation should be coordinated with other emitting nations to ensure this problem is addressed on a global scale and does not put American business at a competitive disadvantage. Otherwise, new regulations would likely result in unintended consequences, including a shift in emissions, and possibly production capacity, from the U.S. to other countries. This could result in a net increase in global emissions.
RDC urges the Environmental Protection Agency (EPA) to conduct a comprehensive discussion of the impacts and costs of the program envisioned under the ANPR. The EPA must explain in clear terms the costs and benefits of the U.S. using the CAA to regulate greenhouse gases. As currently proposed, the new regulations pose significant and untimely impacts to a weak domestic economy and may result in higher prices for energy, food, manufactured goods and transportation.
RDC believes an effective regulatory framework that advances solutions to climate change within the context of U.S. energy security and the economy can be achieved through separate legislation that is international in scope. Using the CAA unilaterally to regulate GHGs is the wrong approach.
Sincerely,
Resource Development Council for Alaska, Inc.
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