On April 17, the Environmental Protection Agency (EPA) issued an
endangerment finding, saying that global warming poses a serious
threat to public health and safety. Thus, almost anything that
emits carbon dioxide and other greenhouse gases could be regulated
under the Clean Air Act. This is the first official action taken by
the federal government to regulate carbon dioxide.
The endangerment finding is the initial step in a long
regulatory process that could lead to the EPA requiring regulations
for almost anything that emits carbon dioxide. Automobiles would
likely be the first target, but subsequent regulations could extend
to a million or more buildings and small businesses, including
hospitals, schools, restaurants, churches, farms, and apartments.
The following five reasons explain why this would be a big, costly
1. It's an Economy Killer
Above anything else, any attempt to reduce carbon dioxide would
be poison to an already sick economy. Even when the economy does
recover, the EPA's proposed global warming policy would severely
limit economic growth.
Since 85 percent of the U.S. economy runs on fossil fuels that
emit carbon dioxide, imposing a cost on CO2 is equivalent to
placing an economy-wide tax on energy use. The Heritage
Foundation's Center for Data Analysis study of the economic effects
of carbon dioxide cuts found cumulative gross domestic product
(GDP) losses of $7 trillion by 2029 (in inflation-adjusted 2008
dollars), single-year GDP losses exceeding $600 billion in some
years (in inflation-adjusted 2008 dollars), energy cost increases
of 30 percent or more, and annual job losses exceeding 800,000 for
several years. Hit particularly hard is manufacturing, which will
see job losses in some industries that exceed 50 percent.
High energy costs result in production cuts, reduced consumer
spending, increased unemployment, and ultimately a much slower
economy. But importantly, higher energy prices fall
disproportionately on the poor, since low-income households spend a
larger percentage of their income on energy.
2. Negligible Environmental
The extraordinary perils of CO2 regulation for the American
economy come with little, if any, environmental benefit. In fact,
analysis by the architects of the endangerment finding, the EPA,
strongly suggests that a 60 percent reduction in carbon-dioxide
emissions by 2050 will reduce global temperature by 0.1 to 0.2
degrees Celsius by 2095.
Some environmental alarmists believe saving the environment
should come at any cost, but when the benefit is barely noticeable,
such an extreme viewpoint still cannot be justified.
3. Lack of Scientific Consensus
The decision to regulate carbon dioxide and five other
greenhouse gases was supported by supposed compelling scientific
evidence. For example, EPA administrator Lisa Jackson "relied
heavily upon the major findings and conclusions from recent
assessments of the U.S. Climate Change Science Program and the
Intergovernmental Panel on Climate Change [IPPC]." Additionally, the
EPA cited harmful impacts including increased droughts, floods,
wildfires, heat waves, and sea level rises as a result of climate
change. But the reality is that natural disasters are just
that--they occur with or without global warming.
The scientific consensus behind global warming, especially the
seriousness of the impacts, is anything but strong. Last December,
the U.S. Senate Minority released a report that included 650
dissenting scientists refuting claims made in the IPCC report. That
number has grown to over 700, more than 13 times the number of
scientists (52) who had a direct role in the IPCC report.
4. Backdoor Policy
The United States Congress has been reluctant to pass any global
warming legislation or engage in international climate reduction
treaties. Last year's most noted global warming legislative
proposals was S. 2191, the America's Climate Security Act of 2007,
originally sponsored by Senators Joe Lieberman (I-CT) and John
This cap-and-trade bill would have set a limit on the emissions
of greenhouse gases, especially carbon dioxide from the combustion
of coal, oil, and natural gas. A number of concerns existed, chief
among them the impact on already-soaring gasoline prices, and
consequently the bill was withdrawn by its Senate supporters after
only three days of debate.
While some Members of Congress undoubtedly support the EPA's
attempt to curb global warming, the fact that unelected and
unaccountable EPA bureaucrats are trying to bypass legislative
efforts makes it all the more objectionable.
Equally indefensible is any attempt to use the threat of EPA
regulations to induce Congress into enacting a cap-and-trade bill
it would not support otherwise. Members should not be forced to
prematurely pass a bill without fully understanding its effects and
5. Expanded Bureaucracy
Having EPA bureaucrats micromanage the economy, all in the name
of combating global warming, would be a chilling shift to a
command-and-control system in which EPA officials regulate just
about every aspect of the market.
Beyond the costs of such actions, the red tape and permitting
delays are almost unfathomable. Though the Administration recently
enacted a stimulus bill and touted "shovel ready" construction
projects to boost the economy, EPA regulations would essentially
assure that a great deal of such economic activity would be held up
for months, if not years.
For instance, the National Environmental Policy Act (NEPA)
requires federal agencies to file environmental impact statements
for EPA review before moving forward with projects. According to
the Government Accountability Office, normally it takes a federal
construction project an average of 4.4 years to complete a NEPA
review. Along with the Clean Water Act's Section 404 requirements,
before a shovel can break ground, it could take 5.6 years for a
project to jump through all the normal environmental hoops.
Granting the authority for one of the largest and unprecedented
regulatory undertakings in U.S. history> would greatly expand the
The kind of industrial-strength EPA red tape that routinely
imposes hundreds of thousands, if not millions, of dollars in
compliance costs could now be imposed for the first time on many
commercial buildings, farms, and all but the smallest of
businesses. Not only would these costs and delays hamper the
private sector, but the paperwork could paralyze federal and state
environmental regulators, drawing resources away from more useful
A Dangerous Step
The EPA's official announcement commences a 60-day public
comment period before the agency issues a final
ruling. Using the Clean Air Act to regulate CO2 would likely be the
most expensive and expansive environmental regulation in >history and will bypass the legislative process completely. In essence, the decisions of few will drastically alter the lives of many--all for
a change in the Earth's temperature too small to ever notice.
Lieberman is Senior Policy Analyst in Energy and the
Environment and Nicolas D. Loris is a Research Assistant in the
Thomas A. Roe Institute for Economic Policy Studies at The Heritage