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Dear Ms. Previte:
On behalf of the Competitive Enterprise Institute, a non-profit public policy organization headquartered in
I. Introduction
DEP proposes to revise its regulatory definitions so that carbon dioxide (CO2) is removed from the category of distillates of air and reclassified as an air contaminant (pp. 3-4). This change in CO2s status is a regulatory prelude to anticipated future regulatory adoption of a Model Rule proposed through the Regional Greenhouse Gas Initiative (RGGI), culminating in a Northeast/Mid-Atlantic regional CO2 cap-and-trade program (p. 5).
The proposed rule is a conceptual muddle. Logically, DEP cannot classify CO2 as an air contaminant unless it is prepared to apply the same designation to water vaporthe atmospheres main greenhouse gas. Presumably, DEP has no intention to cap steam from nuclear power plants, or evaporation from public green spaces, but it should be aware of the regulatory folly that its argument implicitly demands.
Even if DEPs scientific premises were correct, the RGGI cap-and-trade program would have no discernible effect on global climate change. Thus, any DEP-administered CO2 regulatory program is bound to fail a rudimentary cost-benefit test.
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