The Chamber Needs Your Help: EPA Advanced Notice of Proposed Rulemaking on Greenhouse Gases published today in the Federal Register

Dear Committee Member: Once or twice a year, I will communicate directly regarding issues so important that the Chamber needs not only your attention but your assistance. Today is one of those days. Today, the controversial Advanced Notice of Proposed Rulemaking (ANPR) on greenhouse gas emissions released earlier this month by the Environmental Protection Agency (EPA) was published in the Federal Register. Comments on the ANPR must be received by EPA on or before November 28, 2008.

The document, and commenting instructions, can be accessed at the following address: http://www.regulations.gov/fdmspublic/component/main?main=DocumentDetail&d=EPA-HQ-OAR-2008-0318-0117. The Chamber maintains a website containing the ANPR, all official supporting documents, and other relevant information at http://www.uschamber.com/co2.

 
The ANPR is part of EPA's response to the Supreme Court's ruling in Massachusetts v. EPA, which directed the agency to determine whether CO2 and other greenhouse gas emissions from new motor vehicles endanger public health or welfare. The ANPR includes a comprehensive outline by EPA staff of the multitude of Clean Air Act programs that would be applied to CO2 and other greenhouse gases. The EPA staff draft sets forth program outlines and technical data ranging from new National Ambient Air Quality Standards (NAAQS) for states and localities to stringent new standards for cars, trucks, planes, trains, boats, refineries, manufacturing plants, heavy- and light-duty equipment, and even farms.
Most ANPRs are five pages long with a general request for comment. This ANPR is hundreds of pages long, and is one of the most comprehensive and exhausting documents created by EPA in recent memory. In addition, there are several hundred more pages of technical documents supporting the ANPR itself, many relying on scientific and/or proprietary studies.

The Chamber does not believe the existing Clean Air Act should be used to regulate greenhouse gas emissions, and is developing comments in response to the many issues raised in the ANPR. I ask that any Committee Member either working on a response to the ANPR or with an interest in joining our efforts opposing the ANPR contact me or my staff. In addition, I ask that you consider sharing any scientific or policy analysis your companies are exploring with the Chamber so that we can add it to our comments. The Chamber runs a Working Group dedicated to responding to the ANPR; if you have experts in legal, economic, scientific or policy areas relating to the ANPR and would be willing to participate in the Working Group, please contact me or my staff for details.
For more information, contact Bill Kovacs (wkovacs@uschamber.com), Tom Myers (tmyers@uschamber.com), Walter Shaub (wshaub@uschamber.com), or Ross Eisenberg (reisenberg@uschamber.com).

Regards,

Joanna L.C. Bonfanti
Government Affairs
Florida Chamber of Commerce
Office: 850.521.1253
Cell: 850.284.9283
Fax: 850.521.1247