Clearing the Air
The quotations circulating in the press are from a document in which OMB simply collated and collected disparate comments from various agencies during the inter-agency review process of the proposed finding. These collected comments were not necessarily internally consistent, since they came from multiple sources, and they do not necessarily represent the views of either OMB or the Administration. In other words, we simply receive comments from various agencies and pass them along to EPA for consideration, regardless of the substantive merit of those comments. In general, passing along these types of comments to an agency proposing a finding often helps to improve the quality of the notice.
Perhaps more importantly, OMB concluded review of the preliminary finding several weeks ago, which then allowed EPA to move forward with the proposed finding. As I wrote on this blog on April 17, the "proposed finding is carefully rooted in both law and science." I also noted: "By itself, the EPA’s proposed finding imposes no regulation. (Indeed, by itself, it requires nothing at all.) If and when the endangerment finding is made final, the EPA will turn to the question whether and how to regulate greenhouse gas emissions from new automobiles."
The bottom line is that OMB would have not concluded review, which allows the finding to move forward, if we had concerns about whether EPA’s finding was consistent with either the law or the underlying science. The press reports to the contrary are simply false.
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