Our Perspective

On Greenhouse Gases and Climate Change

At T. Cozzie Consulting Inc., we continue to monitor developments in the science and policy of global climate change. We are not utterly convinced of the following four essential propositions as justification for combatting global climate change and its anticipated, negative effects:

  • First, that the planet is warming at a rate unprecedented in recorded history, with potentially catastrophic consequences for the environment and human health;

  • Second, that human activities, specifically the emissions of "greenhouse gases" such as carbon dioxide, are primarily responsible for this global climate change;

  • Third, that only drastic measures to reduce our output of CO2 and other greenhouse gases can slow or mitigate the process of global warming and its potential consequences; and

  • Fourth, that the substantial economic and developmental costs required for these emissions reduction measures are outweighed or outvalued by the potential, future costs associated with the effects of uncontrolled greenhouse gas emissions.

Nevertheless, we do recognize that regulatory and social factors will demand action to reduce emissions with the objective of mitigating global climate change. Therefore, we provide guidance and assistance to our clients who are implementing greenhouse gas emissions monitoring, reporting and reduction programs and other activities related to climate change. Look to this page for tools and information related to this important topic, including the latest actions by regulatory agencies and standard-setting bodies. For additional assistance, please contact T. Cozzie Consulting Inc.

  • Developments in Regulation of Greenhouse Gas Emissions

  • EPA publishes Endangerment and Cause or Contribute findings for greenhouse gases

    In December 2009, the US Environmental Protection Agency administrator signed two findings on greenhouse gases under the Clean Air Act:

    Endangerment: That current and projected concentrations of the six key greenhouse gases - carbon dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6) - in the atmosphere threaten the public health and welfare of current and future generations; and

    Cause or Contribute: That the combined emissions of these well-mixed greenhouse gases from new motor vehicles and new motor vehicle engines contribute to the greenhouse gas pollution which threatens public health and welfare.

    These determinations are prerequisite for EPA to finalize its greenhouse gas emissions limitations for light-duty vehicles, including passenger automobiles, proposed in September. In addition, the endangerment finding paves the way for regulatory control of greenhouse gas emissions from stationary sources. EPA can begin to regulate GHGs through the administrative rulemaking process, and has signalled its intent to apply regulatory controls to power plants and other large emitters.

    For the published text of the rule, visit edocket.access.gpo.gov/2009/E9-29537.htm or contact us at www.tcozzie.com/contact.php.

  • EPA issues rule to require annual reporting of greenhouse gas emissions

    The Environmental Protection Agency on September 22, 2009, issued its Final Mandatory Reporting of Greenhouse Gases Rule. Beginning with reporting year 2010, the rule will phase in requirements for annual reporting of greenhouse gas emissions from suppliers of fossil fuels or industrial greenhouse gases, manufacturers of vehicles and engines, and other facilities that may emit greenhouse gases in annual quantities of 25,000 metric tons or more. Covered greenhouse gases include carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons and other fluorinated gases.

    For more on the rule, including the published text, visit http://www.epa.gov/climatechange/emissions/ghgrulemaking.html or contact us at www.tcozzie.com/contact.php.

  • EPA grants waiver of Clean Air Act preemption for California's 2009 and subsequent model year greenhouse gas emission standards for new motor vehicles

    On July 8, 2009, The Environmental Protection Agency announced that it has granted the California Air Resources Board's request for a waiver of Clean Air Act preemption to enforce its greenhouse gas emission standards for model year 2009 and later new motor vehicles. This decision is under section 209(b) of the Clean Air Act (the "Act"), as amended. This decision withdraws and replaces EPA's prior denial of the December 21, 2005 waiver request, which was published in the Federal Register on March 6, 2008.

    This ruling is likely to pave the way for a de facto "national" standard for greenhouse gas emissions from motor vehicles, as automobile manufacturers will need to design their vehicles to meet the California standards when applied.

  • EPA plans to control emissions of greenhouse gases from motor vehicles

    The Environmental Protection Agency intends to set national emission standards for greenhouse gases from passenger vehicles and light trucks as part of a joint rulemaking with the National Highway Traffic and Safety Administration. A notice of intent to conduct the joint rulemaking was published in the Federal Register on May 22, 2009.

    A proposed rule is expected within the year, if EPA determines that (1) emissions of greenhouse gases may reasonably be anticipated to endanger public health or welfare, and (2) emissions from new motor vehicles and motor vehicle engines contribute to the atmospheric concentrations of these greenhouse gases (as already proposed). The national emission standards would likely be phased in over a four-year period beginning with model year 2012.

  • EPA finds greenhouse gases pose threat to public health, welfare

    In a proposal that would pave the way for regulation of greenhouse gas emissions, the Environmental Protection Agency on April 17 issued a finding that greenhouse gases contribute to air pollution that may endanger public health or welfare.

    The proposed finding identified six gases - including carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons and sulfur hexafluoride - that pose threats.

    For more information, visit http://epa.gov/climatechange/endangerment.html or contact us at www.tcozzie.com/contact.php.

  • EPA to require greenhouse gas emissions reporting

    On April 10, 2009, the Environmental Protection Agency issued a proposal to require reporting of greenhouse gas emissions from all sectors of the economy. Reportable greenhouse gases include carbon dioxide, methane, nitrous oxide and fluorinated gases. The rule would apply to fossil fuel suppliers and industrial gas suppliers, as well as to direct greenhouse gas emitters - such as operators of boilers, process heaters, incinerators and other stationary combustion sources. The proposed rule does not require control of greenhouse gases, rather it requires only that sources above certain threshold levels monitor and report emissions.

    The full text of the proposed rule can be found at http://www.epa.gov/fedrgstr/EPA-AIR/2009/April/Day-10/a5711.htm.