Comments on: CEI Comments Submitted to EPA on the Agency’s Regional Haze Power Grab http://www.globalwarming.org/2011/12/16/cei-comments-submitted-to-epa-on-the-agencys-regional-haze-power-grab/ Climate Change News & Analysis Wed, 12 Dec 2012 14:44:39 +0000 hourly 1 http://wordpress.org/?v= By: Patrick Moffitthttp://www.globalwarming.org/2011/12/16/cei-comments-submitted-to-epa-on-the-agencys-regional-haze-power-grab/comment-page-1/#comment-66487 Patrick Moffitt Sat, 17 Dec 2011 01:43:51 +0000 http://www.globalwarming.org/?p=11843#comment-66487 The interesting question for me is- does EPA have the authority to set air and/or water quality standards more stringent than the preEuropean contact "natural" background - something very much different than than EPA's reference condition.One can use changes in the fire cycle, soil water logging and forest coverage to argue that air and water are "better" now with respect to any number of regulated parameters. So what controls- the reference condition or the natural background- or something else? Basically, was the haze of the 19th century Indian summer an air quality violation? (Same questions can be asked about EPA's new reactive N push and ground level ozone precursors) The interesting question for me is- does EPA have the authority to set air and/or water quality standards more stringent than the preEuropean contact “natural” background – something very much different than than EPA’s reference condition.

One can use changes in the fire cycle, soil water logging and forest coverage to argue that air and water are “better” now with respect to any number of regulated parameters. So what controls- the reference condition or the natural background- or something else? Basically, was the haze of the 19th century Indian summer an air quality violation? (Same questions can be asked about EPA’s new reactive N push and ground level ozone precursors)

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