The EPA-OMB battle over GHG's and potential adverse human health effects

Global warming is likely to increase deaths due to higher ozone levels, heat waves, and severe weather events, according to an EPA document that was posted on the Internet on July 14.  The document cited the Intergovernmental Panel on Climate Change for the proposition that higher ozone levels due to an increase in global temperatures could result in a 4.5% increase in deaths from ozone exposure.  EPA prepared the analysis as part of an advanced notice of proposed rulemaking that was released July 11, seeking comments on potential regulation of GHG's under the CAA.  The proposal was designed to address the U.S. Supreme Corut's decision in Massachusetts v. EPA.  For a copy of the proposal, go to http://www.regulations.gov and in the search box enter EPA-HQ-OAR-2008-0318-0064.1.  [You may also click on the EPA number; it should take you to a site from which you can open the document in PDF form.]

The earlier EPA draft noted that climate change could increase summer ozone levels by 2-8 ppb by 2050.  [In March, EPA set an 8-hour ambient ozone standard of 75 ppb, down from the then current standard of 80 ppb.]  As frequently happens in these types of analyses, various climate models were used.  Some models produced a decrease in ozone levels in some regions, but the report notes that an increase was larger and more consistent in the projections.  Ozone increases were most pronounced in the Mid-Atlantic, Northeast, and lower Midwest regions; results were conflicting for the West Coast and Southeast.  The results primarily focused on tropospheric ozone [the lowest atmospheric layer; from 4 to 11 miles high (depending on latitude)] because the scientific understanding of this atmospheric region is more "complete".  See http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=181744.

However, in a letter to EPA dated July 10, 2008, OMB told EPA that they were withdrawing the draft from review pursuant to Executive Order 12866 because regulating GHG's under the CAA was not Bush administration policy and the proposal lacked support from other federal agencies.  See http://www.reginfo.gov/public/postreview/OIRA_letter_to_EPA_7_10_08.pdf.  EPA had submitted its advance notice to OMB on June 17, and OMB had in turn shared it with other federal agencies.  The letter noted that the issued raised during the review process are so significant that the administration had been unable to reach an interagency consensus.  Input from the agencies allegedly noted that the proposal would harm the U.S. economy and not provide an effective response to global warming.  Critical comments were apparently received from Departments of Agriculture, Commerce, Transportation, and Energy, CEA, OSTP, CEQ, and SBA.  A copy of the OMB letter and those from the other federal agencies can be found at http://www.reginfo.gov/public/jsp/EO/postReviewLetters.jsp.