The American Environmental Coalition (“AEC”), a broad-based coalition of 12 million everyday Americans who are concerned about America's future and working to keep America beautiful, strong and prosperous submits these comments in response to the Advance Notice of Proposed Rulemaking (ANPR) on Regulating Greenhouse Gases Under the Clean Air Act (CAA) issued
by the Environmental Protection Agency (EPA) and published in the Federal Register on July 30, 2008.
The Clean Air Act (“CAA”) is ill-suited for regulating greenhouse gas emissions, and we urge the EPA to not move forward with a proposed rule or any other type of regulation of greenhouse gas emissions under the CAA. More specifically, we urge the EPA not to make an endangerment finding with respect to greenhouse gas (GHG) emissions. Simply stated, regulation of greenhouse gas emissions under the CAA will result in unintended regulatory consequences that could wreak economic havoc on all sectors of business and will impose heavy burdens on every citizen in the United States while providing no certain benefit.