Comments from Citizens Against Government Waste Institute Submitted to EPA Regarding the Advanced Notice of Proposed Rulemaking for Greenhouse Gases Under the Clean Air Act

CAGW is particularly concerned that if the EPA makes an endangerment finding for GHG, it will insert itself into an area that should only be the purview of elected officials, namely Congress, and not by unelected bureaucrats. EPA’s involvement in regulating GHG will create a bureaucratic nightmare for businesses and other entities. It will drive up the budgets of the EPA plus state and local regulatory agencies and increase the size of these bureaucracies. The proposed regulation, if undertaken, will cost businesses and taxpayers billions of dollars. A
recent study by the Heritage Foundation has estimated the cost of implementing the regulation would result in gross domestic product loses of nearly $7 trillion by 2029.1 This study used the least onerous assumptions for CAA regulation impacts, so the likely costs will be even higher.