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Surprise: EPA Climate Review Says GHGs a Danger

The EPA on Friday issued a proposed finding that should surprise few by this point: according to agency scientists greenhouse gases do, in fact, contribute to air pollution that may endanger public health or welfare.

The proposed finding, which now moves to a public comment period, identified six greenhouse gases that pose a potential threat. The exhaustive study, commissioned during the Bush Administration after a verdict by the Supreme Court demanded the EPA conduct a "thorough review," is a crucial step toward the increasingly inevitable promulgation of eventual federal GHG controls.

According to an agency release, the proposed endangerment finding was based on "rigorous, peer-reviewed scientific analysis of six gases – CO2, methane, NOX, hydrofluorocarbons, perfluorocarbons and sulfur hexafluoride – that have been the subject of intensive analysis by scientists around the world. The science clearly shows that concentrations of these gases are at unprecedented levels as a result of human emissions, and these high levels are very likely the cause of the increase in average temperatures and other changes in our climate."

Findings from a recent EPA study titled Assessment of the Impacts of Global Change on Regional U.S. Air Quality: A Synthesis of Climate Change Impacts on Ground-Level Ozone, for suggested that climate change may lead to higher concentrations of ground-level ozone. Additional impacts of climate change in the report included:
  • increased drought;
  • more heavy downpours and flooding;
  • more frequent and intense heat waves and wildfires;
  • greater sea level rise;
  • more intense storms; and
  • harm to water resources, agriculture, wildlife and ecosystems.
In proposing the finding, Administrator Jackson noted the agency took into account the disproportionate impact climate change has on the health of certain segments of the population, such as the poor, the very young, the elderly, those already in poor health, the disabled, those living alone and/or indigenous populations dependent on one or a few resources.

In addition to threatening human health, the EPA noted that it believes climate change also has national security implications. In 2007, 11 retired U.S. generals and admirals signed a report from the Center for a New American Security stating that climate change "presents significant national security challenges for the United States." The agency noted that escalating violence in destabilized regions can be incited and fomented by an increasing scarcity of resources – including water. This lack of resources, driven by climate change patterns, then drives massive migration to more stabilized regions of the world.

The proposed endangerment finding now enters the public comment period, which is the next step in the deliberative process the EPA must undertake before issuing final findings. Today's proposed finding does not include any proposed regulations. Before taking any steps to reduce greenhouse gases under the Clean Air Act, the EPA has promised to conduct an "appropriate" process and consider stakeholder input.

Notwithstanding this required regulatory process, both President Obama and Administrator Jackson have repeatedly indicated their preference for comprehensive legislation to address this issue and create the framework for a clean energy economy.

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