Is this the regulatory camel's nose in under the greenhouse? In what some observers fear is the beginning of a climate change regulatory initiative, the Environmental Protection Agency has published a request for comments on a draft greenhouse gas emissions inventory. Moreover, the agency proposes to list ozone as a greenhouse gas, which could bring NOx and emissions of volatile organic compounds (VOCs) under the Kyoto treaty reduction targets. It also alludes to possible greenhouse gas effects for SO2.
EPA denies that the present proposal - "Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-1996" -- is part of an eventual rule making. Officially, the agency says, "The U.S. greenhouse gas inventory is being prepared to provide a basis for the ongoing development of a comprehensive and accurate system to identify and quantify emissions and sinks of greenhouse gases in the U.S. It will serve as part of the U.S. submission to the secretariat of the Framework Convention on Climate Change and to contribute to updates to the U.S. Climate Action Report." An EPA source acknowledges, however, that an emissions inventory is the necessary first step toward an emissions trading program, which is the centerpiece of the administration's climate action regulatory plan.
The Kyoto treaty only lists carbon dioxide, methane, nitrous oxide and certain chlorofluorocarbons as greenhouse gases. But the EPA inventory includes NOx and emissions of VOCs on the grounds that they are precursors to tropospheric ozone, and that ozone is a greenhouse gas. Scientists have not been targeting ozone as a factor in climate change, because it is short lived and high concentrations seldom last more than a few days. So its effect, if any, on climate is impossible to determine using existing models. However, according to an Energy Information Administration report, Emissions of Greenhouse Gases in the United States, tropospheric ozone is in fact "a potent greenhouse gas."
EIA also says that the criteria pollutants NOx, SO2, particulates, and carbon monoxide, which are emitted by many power plants, are themselves "radiatively important gases." However, the report concludes, "These gases have ambiguous effects on climate, which are difficult to quantify." An industry source worries that by including such gases in its inventory, EPA is setting the stage to regulate them in new and unpredictable ways, further complicating an already confusing compliance planning situation. Comments on the proposed inventory are due July 6, 1998.
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