Comments of Michael E. Carlson, Principal, MEC Environmental Consulting, Royal Oak, Michigan, on EPA’s Proposed Endangerment Finding

Carlson argues in his submittal EPA is deviating from its past practices by defining the six greenhouse gases it proposes to regulate as air pollutants “on the basis of their impacts or action on the environment,” while past “air pollutants” have been defined based on their “intrinsic physical properties.” This violates Section 202(a) of the Clean Air Act, he writes, because the subject of the Endangerment Finding is one of “air pollution” not climate.