Public Comments

Standards of Performance for Greenhouse Gas Emissions for New Stationary Sources: Electric Utility Generating Units

Chapter 3 of EPA’s the Regulatory Impact Analysis (RIA) for the Proposed Standards of Performance for Greenhouse Gas Emissions for New Stationary Sources: Electric Utility Generating Units is concerned with “The climate change problem and rationale for rulemaking.” The Chapter “summarizes the adverse effects on public health and public welfare detailed in the 2009 Endangerment Finding” and has this to say regarding the source of the scientific opinions underlying the Endangerment Finding:

The major assessments by the U.S. Global Change Research Program (USGCRP), the Intergovernmental Panel on Climate Change (IPCC), and the National Research Council (NRC) served as the primary scientific basis for these effects.

In fact, the USGCRP 2009 report, Global Climate Change Impacts in the United States is the only one of these documents that relates directly and purposefully to climate change in the U.S. It is therefore of much more import than the other two.

The EPA’s proposed rule states that “There is no reason to revisit the 2009 Endangerment Finding given recent scientific findings that strengthen the scientific conclusion that GHG air pollution endangers human health and welfare.”

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