Anonymous public comment

Introduction. Many scientists are researching human activities that release greenhouse gases into the air. This research seeks to investigate the possibility that these gases may be increasing the natural greenhouse effect and ultimately inducing global warming (Houlihan, Altman, Klesh and Hickman, 2010). Global warming is a very serious challenge that the world is currently dealing with today. Pollutants such as methane, carbon dioxide, nitrous oxide, carbon monoxide and other heat trapping gases are just some of the contributors to global warming and are compromising to our health and well being. Many are questioning the causes of global warming, how it can be controlled, and the affects it has on the world and its people. The Clean Air Act became a U.S. federal law in 1970 and intends to reduce pollution and protect air quality. Under the Clean Air Act, standards are set for air quality that limits the amount of various pollutants to specified levels. Emissions standards assist the Clean Air Act, as they require a set limit to the levels of pollutants that can be released into the atmosphere. According to the Environmental Protection Agency, after a thorough scientific review ordered by the U.S. Supreme Court, it was proposed that greenhouse gases contribute to air pollution that may endanger human health and public welfare (Houlihan, Altman, Klesh and Hickman, 2010). This finding, which is now open for public comment, identifies six greenhouse gases that pose a threat to human health and the environment, including: CO2, CH4, N2O, hexafluorocarbons, perfluorocarbons and sulfur hexafluoride. These heat-trapping gases are known as the greenhouse effect and are released into the atmosphere causing a rise of carbon dioxides. Greenhouse gases are being investigated as a possible cause for global warming and current climate changes that we are experiencing today. The harms associated with climate change are serious and well recognized. Scientists, government officials and environmentalists are not only worried about the events of global warming but also the rapid pace it seems to be occurring. Based on current research, the Environmental Protection Agency states 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 temperature and other changes in our climate (Pontius, 2009 ). The United States Environmental Protection Agency is responsible for establishing standards for air-quality under the Clean Air Act. This responsibility held by the EPA aims to help slow down the progression of global warming and limit the amount of toxic pollutants and greenhouse gases emitted into the air. Recently, there was much debate as to whether it was the responsibility of the Environmental Protection Agency to regulate emissions of carbon dioxide and other gases that are believed to contribute to global warming from motor vehicles. This debate brought about the court hearing of the state of Massachusetts vs. the Environmental Protection Agency. Recently, the EPA has implemented and finalized its Mandatory Reporting of Greenhouse Gases rule, which is significant for regulating Greenhouse gases under both the Clean Air Act and any future climate change legislation (Houlihan, Altman, Klesh and Hickman, 2010). The Environmental Protection Agency aims to address climate change issues as well as review all six of the national ambient air quality standards (NAAQS) by 2011. This is extremely significant because although the Clean Air Act requires these standards to be reviewed every five years, some have not been modified since they were established in 1971. (Houlihan, Altman, Klesh and Hicman, 2010) Background on the history of EPA vs. The State of Massachusetts Massachusetts, along with several other states and environmental organizations, rallied together to fight against the Environmental Protection Agency after their petition to regulate emissions of carbon dioxide and other greenhouse gases was denied. The Environmental Protection Agency claimed that under the Clean Air Act there was no agreement that entitled the EPA to regulate greenhouse gas emissions. The Environmental Protection Agency also believed more research was needed to show the harmful effects of these pollutants and the threat they posed on the health and welfare of the population (Austin, 2007). They also thought a further investigation was needed on the issue of global warming before the blame was completely put on greenhouse gases. The EPA simply believed that not enough evidence was provided to show that these air pollutants were a threat and endangerment to public health. The United States Environmental Protection Agency denied the petition in a notice issued Aug. 8, 2003, concluding that it lacked authority under the Clean Air Act to regulate greenhouse gases for purposes of global climate change (Watts and Wildermuth, 2008). In addition, the Environmental Protection Agency stated that even if it did have the authority to set greenhouse gas emission standards for new motor vehicles, it would be unwise to do so at that time. Upon appeal, the federal appeals court in Washington, D.C., stood by their denial of the petition. The United States Supreme Court ruled in favor of the state of Massachusetts by a 5-4 vote, concluding that greenhouse gases were considered pollutants and needed be regulated by the Environmental Protection Agency to ensure that appropriate standards were set for air quality. Specifically, the Court held that carbon dioxide, methane, nitrous oxide, and hydrofluorocarbons were to be considered air pollutants because they are physical and chemical substances that are emitted into the ambient air (Watts and Wildermuth, 2008). Although it was not originally indicated that these greenhouse gases were considered harmful pollutants, the Courts decided that they were now to be considered included within the Clean Air Act. Carbon dioxide and other greenhouse gases that fell within section 202 (a)(1) of the Clean Air Act, which states that the Environmental Protection Agency Administrator by regulation should order (and when necessary revise) in agreement with the requirements of the 202 (a)(1) section, standards applicable to the emission of any air pollutant from any class of new motor vehicles or engines, which may cause or contribute to air pollution which may reasonably be probable to endanger public health or welfare (Austin, 2007). The Environmental Protection Agency is now required to regulate emissions of carbon dioxide and other greenhouse gases or provide a reasonable explanation for its failure to do so. The Court found that States had reason to defend themselves against the threat of air pollutants and possible effects to their environment. The ruling concluded that greenhouse gases are considered pollutants that were originally described in the Clean Air Act. The Clean Air Act currently and its position on Greenhouse Gases. The year 2009 represented a major turning point in the Clean Air Act and its acknowledgement of greenhouse gases as a pollutant. Under the Obama Administration, the U.S. Environmental Protection Agency issued an endangerment finding with respect to greenhouse gases and granted California’s waiver request. The California waiver involved the Environmental Protection Agency to enable the state of California to enforce its greenhouse gas emissions standards. In September 2004, the California Air Resources Board passed regulations to reduce greenhouse gases from new passenger vehicles starting in 2009. These regulations were authorized by the 2002 legislation Assembly bill California requested from the Environmental Protection Agency. The waiver required for implementation of the Pavley regulations in December 2005. The request was subsequently denied in December 2007 (Houlihan, Altman, Klesh and Hickman, 2010). After taking office in January, President Barack Obama directed the USEPA to assess the appropriateness of denying the waiver. In granting the California waiver, the EPA found that California continues to have a need for its motor vehicle emissions program, including the greenhouse gas standards. The Environmental Protection Agency also found that the California program meets legal requirements regarding the protectiveness of public health and welfare (Houlihan, Altman, Klesh and Hickman, 2010). The year 2009 did not see as many challenges to regulation under the Clean Air Act as in past years however, there was a continued level of activity in regard to climate change lawsuits. The Obama administration has focused many of its efforts on reducing both green house gases and carbon dioxide emissions. Interest in this issue has grown drastically and many efforts are currently being made to try to limit the use of greenhouse gases to improve air quality. Besides emission regulations, other policies are being carried out as well, including requirements for renewable fuel use and stricter energy-efficiency standards for vehicles, buildings, and appliances (Burger, Ecola, Thomas, and Toman, 2009). In an article, it was predicted that 2010 would likely see a growing trend in climate litigation (Houlihan, Altman, Klesh and Hickman, 2010). For example, the proposed rulemakings on greenhouse gas emissions and NAAQS will more than likely have a big impact in the coming future. There are currently a wide variety of regulatory proposals that exist and this more than likely means that the year 2010 should be another year of significant Clean Air Act revisions and developments. The Obama administration and the Environmental Protection Agency have proceeded to begin the process of regulating Greenhouse gases under the Clean Air Act. The Bush administration and EPA tried hard to avoid this issue in the past by delaying response to the U.S. Supreme Court’s mandate that it issue an endangerment finding regarding the risk of Greenhouse gases to human health and the environment (Austin, 2007). After President Obama took office, much attention has been given to the issue of greenhouse gases and its threat to the environment. On April 24, 2009, the Environmental Protection Agency published the Proposed Endangerment and Cause or Contribute Findings for Greenhouse Gases Under Section 202(a) of the Clean Air Act in the Federal Register. It proposed to find that atmospheric concentrations of greenhouse gases that endanger public health and welfare within the definition of Section 202(a) of the Clean Air Act and combined emissions from new motor vehicles and new motor vehicle engines that are contributing to this mix of greenhouse gases in the atmosphere (Houlihan, Altman, Klesh and Hickman, 2010). The proposed rule received nearly 400,000 comments during the 60-day public comment period that both criticized and/or supported the ruling. The EPA issued the final rule on December 7, 2009. (Houlihan, Altman, Klesh and Hickman, 2010). The U.S. Environmental Protection Agency plans to set up the first U.S. national system for reporting emissions of CO2 and other greenhouse gases. Current administrator of the Environmental Protection Agency Lisa Jackson stated that the proposal marks the first step toward a program for climate control. Through this new reporting it is believed that accurate and more comprehensive data about the production of greenhouse gases will help with better protection of human health and the environment (Chemical Engineering, 2009). Under the initial proposal, the reporting requirements would apply to suppliers of fossil fuel and industrial chemicals, oil and chemical refineries, manufacturers of motor vehicles and engines, and facilities that have greenhouse gas emissions of 25,000 m,t./yr or more (Chemical Engineering, 2009 ). My position After researching this issue of greenhouse gases and its negative effect on the environment, air quality, human health and climate change, I am in agreement with this proposal to have mandatory reporting of greenhouse gases. I am convinced that this will be a good approach to this issue and will help with trouble shooting through this global warming crisis. Reporting greenhouse gases will not only improve air quality but human health and well -being will benefit from this proposal as well. Decreasing the amount of inhaled pollutants will also help in the reduction of respiratory and cardiopulmonary illnesses. In an article written in 2007, authors Chen, Craig, and Krewski stated that protecting public health from environmental risks involves taking regulatory and other actions based on statistics about population health indicators and their associations with exposure to certain pollutants (Chen, Craig, and Krewski, 2008). These man-made green gas emissions are posing a threat to both the population and the environment and this issue needs to be recognized. I believe having businesses and facilities report greenhouse gases will bring much needed attention and awareness to the country and its need to adapt these current environmental policies to the changes that the world is currently seeing today. Presently, there are issues such as climate change, toxic air pollutants, and global warming that need to be addressed when referring to the Clean Air Act and the obligations that the EPA has to protect people and the environment in which we live need to be addressed. There are many questions regarding the causes of global warming and what steps should be taken to help slow down its progression. Although there are still some uncertainties on all the causes of global warming and climate change, it is clear that poor air quality is viewed as a major contributor. One of the main reasons that I agree with the decision to have the EPA regulate emissions and mandatory reporting of greenhouse gases is the possibility that these gases and pollutants may have some causation in global warming and recent climate change issues. As the years go on, population will more than likely increase as well as world carbon dioxide emissions. We, as public health professionals, must help control this issue by recognizing the risks, assessing the situation, and implementing control strategies. This proposal will assist the goals of public health when it comes to air quality and help with accountability. Conclusion In conclusion, I am in complete agreement with the proposal to have mandatory reporting of greenhouse gases. As a citizen, I believe this petition is justified and assists the Environmental Protection Agency goal to protect the environment and human health. The Clean Air Act clearly states that any pollutants, which may endanger the environment and population, should be regulated. Greenhouse gases are now considered to be harmful pollutants and it is the Environmental Protection Agency’s duty to regulate them. This proposal will also bring a lot of interest and attention to the issue of climate change and global warming. Environmental risks are clearly present and should not be over-looked or ignored. These air pollutants are not only harmful to the environment, but they also put the population at risk for cardiopulmonary and respiratory illnesses. In order to move in the right direction as far as air pollutants are concerned, we must recognize the need to revise the original Clean Air Act to ensure that current issues are being taken into account. This will not only set better standards for air quality and but will also help to improve environmental policies. These environmental policies will help to improve the health and welfare of the population and also provide a more stable atmosphere for the environment.