Comments from the Free Market Coalition Submitted to EPA Regarding the Advanced Notice of Proposed Rulemaking for Greenhouse Gases Under the Clean Air Act

We are writing to urge EPA not to make an endangerment finding with respect to greenhouse gas (GHG) emissions under §202 of the Clean Air Act (CAA). A positive finding of endangerment would require EPA to establish first-ever GHG emission standards for new motor vehicles.

Thanks to EPA’s Advanced Notice of Proposed Rulemaking (ANPR),1 several congressional testimonies by attorney Peter Glaser,2 and the U.S. Chamber of Commerce’s compliance burden report,3 it is now clear that setting GHG emission standards under CAA §202 would trigger a regulatory cascade throughout the Act, imposing potentially crushing burdens on regulated entities and the economy.