November 25, 2008
Air and Radiation Docket and
Mail Code 2822T
Re: Regulating Greenhouse Gases Under the Clean
Air Act; Proposed Rule
Docket ID No. EPA-HQ-OAR-2008-0318
Thank you for providing North Dakota Stockmen’s Association (NDSA) with the opportunity to comment on the Environmental Protection Agency’s July 11, 2008 Advanced Notice of Proposed Rulemaking (ANPR) on Regulating Greenhouse Gases (GHGs) under the Clean Air Act (CAA). NDSA strongly opposes any effort to regulate greenhouse gases under current programs of the CAA.
It is clear from the ANPR and Agency comments that the potential regulation of GHGs under the Clean Air Act would be economically devastating to American businesses, including farmers, and families. As the Department of Energy stated in its comments, the regulation of stationary sources under the Clean Air Act “would likely dramatically increase the price of energy in this country” and would increase costs of energy use by sources such as “schools, hospitals, apartment buildings and residential homes.” The Department of Commerce pointed out that for the first time many small commercial establishments like churches, hotels, and hospitals would be regulated by the EPA. Our Nation’s food supply would also be affected negatively by high energy and transportation costs, placing significant economic hardship on agricultural producers and everyday consumers. For example, the production methods and equipment used by the agricultural sector to grow the food that feeds ourselves and the rest of the world involves complex technology dependent on the consumption of all forms of energy. In addition to increased energy costs, the ANPR points out that many agricultural producers would be required to get individual CAA permits for the first time. The USDA estimates that cattle producers with 50 head of cattle or more would be required to get such permits. Some of the increased costs associated with the proposed regulation would be passed on to everyday consumers further increasing the cost of food, but much of it would have to be borne by agricultural producers themselves. The costs of permitting alone would put many producers out of business. Simply put, costs associated with GHG regulation under the CAA cannot be afforded by our agricultural producers or everyday consumers.
In addition, regulation of GHGs
under the CAA must be rejected because the CAA is fundamentally ill-suited for
GHG regulation. Indeed, Congress never
intended to regulate GHGs under the CAA.
The CAA was originally intended to regulate traditional air pollutants
from major emitters on a state or regional level. While it has done a good job of cleaning up
criteria and other pollutants, it is not adequately equipped to address global
climate change. The CAA imposes a command
and control regulatory program that would impose untenable burdens, expenses
and restrictions on industry, families, and our Nation as a whole if used to
attempt to control GHG emissions. In
addition, such a decision would provide the EPA with unprecedented control over
every sector of the
Again, thank you for this opportunity to comment.
Sincerely,
Wade Moser
Executive Vice President
701-223-2522
www.ndstockmen.org