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AFS Responds to EPA Request for Comments on Greenhouse Gas Emissions |
AFS has responded to the Environmental Protection Agency's (EPA) request for comments regarding the regulation of greenhouse gas (GHG) emissions under the Clean Air Act (CAA). The proposal sets forth a large number of CAA programs EPA would use to regulate all sources of greenhouse gas emissions, and would give EPA vast control over the daily operations of many aspects of the economy not presently regulated by EPA.For stationary sources, EPA considers three specific pathways to regulate under the CAA:
AFS noted in its comments that all of these methods will result in significant administrative burden and cost to the metalcasting industry. Specifically, regulation of greenhouse gases as HAPs will force strict technological standards on anyone emitting more than 25 tons per year of CO2. AFS also stated that if EPA finds endangerment and greenhouse gases are regulated by any provision of the CAA, Prevention of Significant Deterioration permitting authority will be triggered for any source emitting more than 250 tons per year of CO2. This potentially exposes more than a million medium and large facilities in the U.S. to costly, onerous permitting requirements anytime construction is undertaken that will result in CO2 emissions over the 250-ton-per-year threshold.
Sen. Boxer (D-CA), Chair of the Senate Environment and Public Works Committee, said she will introduce legislation in 2009 that would direct EPA to develop a carbon cap-and-trade system by amending the CAA. This action would most likely preempt GHG regulation under NAAQS, NSPS and HAPs, but would still give EPA significant control over much of U.S. industry. To read a copy of AFS' comments to the EPA, click here. For more information, contact Alicia Oman, AFS Washington Office, at
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or 202/842-4864.
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