Well, not zero, but not based on a risk-risk tradeoff. There are pollutants that have either real or effective thresholds of effect. Add a safety factor to that and you will get a non-zero standard. Even for carcinogens, which by policy we consider posing a risk at any concentration above zero, are regulated at a non-zero level.
The problem is as to what level one would select for CO2. Potentially, one could pick a number that reflects a zero human contribution (beyond breathing). What will happen, however, will reflect the economic realities of CO2 regulation - something not considered when setting standards under the Clean Air Act. Hence, the CAA is not the appropriate mechanism for addressing the risks posed by anthropogenic CO2. d. On Fri, Dec 19, 2008 at 12:38 PM, Richard Wilson <[email protected]>wrote: > David Schnare wrote: > >> No, we did not say there will be no controls on CO2 emissions. The Agency >> only stated that CO2 is not properly considered under Clean Air Act >> permitting at this time. The reasons are technical legal reasons and the >> make complete sense. I have spoken with Steve about his views on this and >> he is a cap and trade supporter and a strong one at that. The Clean Air Act >> is not the way to address CO2 emissions. It is an unworkable legal morass >> for a pollutant that is emitted by human mouths and noses. All that aside, >> the Agency has not even stated that it should not be regulated under the >> Clear Air Act. Only that it should not be so regulated at this time. There >> is no National Ambient Air Quality Standard for CO2, so it is not possible >> to determine how much control is necessary. Further, the Agency has not yet >> made an endangerment finding - something that will also address the emission >> levels it is necessary to achieve (in a back handed way). Until the Agency >> takes those steps, it cannot require CO2 controls in a permit. >> So, calm down. I assure you, a new administration is on its way and they >> fully intend to find a way to regulate CO2, if not through the CAA, then >> through some cap and trade program. >> WELLL SAID >> > > The Clean air act is for pollutants whose optimum level in the air is zero. > > > Dick Wilson > > > > On Fri, Dec 19, 2008 at 11:29 AM, Greg Rau <[email protected] <mailto: >> [email protected]>> wrote: >> >> *Without any controls on CO2 emissions who'a gon'a call? - >> Geoengineering!* >> *Congratulations guys - don't blow it. -G* >> * >> * >> * >> * >> *EPA memo bans to curb CO2 emissions* >> Dina Cappiello, Associated Press >> Friday, December 19, 2008 >> >> *(12-19) 04:00 PST Washington -* -- >> The Bush administration is trying to make sure in its final days >> that federal air pollution regulations will not be used to control >> the gases blamed for global warming. >> >> >> In a memorandum sent Thursday, outgoing Environmental Protection >> Agency Administrator Stephen Johnson set an agencywide policy >> prohibiting controls on carbon dioxide emissions from being >> included in air pollution permits for coal-fired power plants and >> other facilities. >> The decision could give the agency a legal basis for issuing >> permits that increase global warming pollution until the incoming >> Obama administration can change it, a process that would require a >> lengthy rule-making process. >> "The current concerns over global climate change should not drive >> EPA into adopting an unworkable policy of requiring emissions >> controls," Johnson wrote. And while the administrator acknowledged >> public interest in the issue, he wrote: "Administrative agencies >> are authorized to issue interpretations of this nature that >> clarify their regulations without completing a public comment >> process." >> The White House has repeatedly said that the Clean Air Act should >> not be used to regulate carbon dioxide or other greenhouse gases, >> even though an April 2007 Supreme Court decision determined that >> the EPA could do so under the law. >> The Thursday memo from Johnson was an attempt to clarify the >> agency's position after an appeals board in November rejected a >> federal permit for a Utah power plant, putting the fate of scores >> of coal-burning power plants and other industrial facilities in limbo. >> In that case, the judges said the EPA did not make a strong enough >> case for not requiring controls on carbon dioxide, the leading >> pollutant linked to global warming. Environmentalists had >> challenged the permit saying that law makes clear that greenhouse >> gas emissions can be controlled. >> >> /This article appeared on page* A - 12* of the >> San Francisco Chronicle/ >> >> >> >> >> >> > -- David W. Schnare Center for Environmental Stewardship --~--~---------~--~----~------------~-------~--~----~ You received this message because you are subscribed to the Google Groups "geoengineering" group. To post to this group, send email to [email protected] To unsubscribe from this group, send email to [email protected] For more options, visit this group at http://groups.google.com/group/geoengineering?hl=en -~----------~----~----~----~------~----~------~--~---
