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April 03, 2007

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» More Mass v. EPA Commentary: from The Volokh Conspiracy
For those who want more commentary on the Supreme Court's decision in Massachusetts v. EPA, I have an op-ed-style commentary a... [Read More]

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evden eve nakliyat

very nice informations.thank you very much.and ver nice blog i will come here all the time.thankss...

MA

Your suggestion that EPA address the problem of global warming through the establishment of a NAAQS for GHGs, followed by a national FIP, has little merit. Without significant amendment, not only is title I of the CAA ill-suited for the task, but such efforts would take well over a decade.

The first step in the process you suggest would be for EPA to establish GHGs as a criteria pollutant. Under the best of circumstances, that would take one year. (Total: 1 year)

In reviewing and revising the existing NAAQS, EPA has repeatedly argued that it requires at least five years for this task. Assuming that the complex task of assessing the problem of global warming and developing an appropriate standard could be done within the standard time frame, that would require at least five years. (Total: 6 years).

The recent ozone and PM2.5 NAAQS were finalized in 1997. Litigation over the EPA’s actions in issuing the NAAQS took until 2002. One could easily assume that whatever standard EPA established for GHGs, it would be challenged. Let’s be optimistic and assume that the Supreme Court does not take cert. Litigation would then consume perhaps two years. (Total: 8 years).

As part of the NAAQS process, EPA would have to determine how to designate nonattainment areas. Would nonattainment be based on GHG concentrations at ground level? Concentrations 10 miles up? Where would the monitors be placed that are necessary for demonstrating attainment or nonattainment? How to determine the size of the nonattainment area? The whole country? Let’s be incredibly optimistic and assume that those problems are addressed and the entire country is designated nonattainment in one year. (Total: 9 years).

States would then have some period of time to develop SIPs to address the nonattainment problem. Again, let’s be optimistic and assume two years. (Total: 11 years). The federal government then indicates that really, it does not expect States to submit SIPs and is planning to promulgate a FIP. The States go along with the plan, fail to submit SIPs and are immediately subject to automatic sanctions, losing all federal highway funds. Hmmm...wonder how the States might feel about that?

The federal government is now ready to roll out its plan for addressing GHGs through a cap and trade program. It must propose and take comment on its plan and then promulgates a final FIP. (Total: 12 years). Assuming the FIP is not challenged, finally, in 2020, the US government has a FIP in place to address GHGs. And that’s the optimistic scenario.

As this brief summary indicates, there are numerous practical issues associated with using title I of the CAA to address GHGs. I sincerely hope that addressing climate change through a national FIP is not “the best option for sensible climate policy.”

Joan A. Conway

Nuclear Power is a hard alternative to obtaining clean air without greenhouse emissions, but France leads the way with about 58 power facilities in the little country, less the size of Texas.

France currently is selling it to London and German and Italy, and building power facilities for North Sea Countries.

Wouldn't it be a lot easier to change our appetite for power than expose ourselves to the dangers of nuclear power facilities?

Many cities use horse-drawn carriages for tourists, and have made way for bike paths, but when a city is as labor intense as Chicago, with many workers within three miles of their offices, this begs for another solution.

Using grease for fast-foods restaurants, like Daryle Hannah's SUV, offers another alternative to consume what we would otherwise discard as a waste product.

Moving our jobs overseas to more tolerant countries is going to be very attractive to employers seeking less legislative control over how they do business, as is already the case with manufacturing processes.

Perhaps there are natural solutions to this bad state of affairs, like we take oatmeal for our high cholestral to absorb it and lower our cholestral.

Maybe there are insects or animals or birds or fish that can absorb the greenhouse gases in our atmosphere for us, as we learn to eliminate our dependency upon its source(s).

Certain fishes have been known to eliminate the algea in our lake waters.

What if big generators of lake water could filter and recycle our air to eliminate the greenhouse pollutents, and damp moist cold, sometimes icy, air was the side affect for doing so?


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