Comments from S. Fred Singer/NIPCC Submitted to EPA Regarding the Advanced Notice of Proposed Rulemaking for Greenhouse Gases Under the Clean Air Act: Addendum

In finding that CO2 causes or contributes to global warming, or in determining what ambient atmospheric level of CO2 to regulate, EPA must be guided by the principles of sound science. Therefore, EPA should not try to regulate carbon dioxide as a pollutant under the Clean Air Act, because:

(1) One cannot show, based on science, that CO2 is a pollutant, i.e. producing climate changes that are harmful to public health and welfare

(2) Even if CO2 could be shown to have a discernable climate effect and if such a climate change could be shown to have an overall deleterious impact, there is no objective way to establish a “bright line,” i.e. to set a NAAQS, to demonstrate the existence of a critical level of ambient CO2 concentration

(3) Even if there were such an ambient level, EPA has not demonstrated that any possible policy of emission control, as set forth in the ANPR, could achieve such a level of NAAQS under realistic scenarios.