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American Chemistry Council Letter to Chairman Issa - January 18, 2011

American Chemistry Council Letter to Chairman Issa - January 18, 2011

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Published by CREW
In December 2010, Representative Darrell Issa, Chairman of the U.S. House Committee on Oversight and Government Reform, sent a letter to over 150 companies, trade groups, and research organizations asking them to identify federal regulations that adversely affect job growth. This letter is one of the many responses that CREW has collected and posted for public review.
In December 2010, Representative Darrell Issa, Chairman of the U.S. House Committee on Oversight and Government Reform, sent a letter to over 150 companies, trade groups, and research organizations asking them to identify federal regulations that adversely affect job growth. This letter is one of the many responses that CREW has collected and posted for public review.

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Published by: CREW on Jan 24, 2011
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American
Chemistry
Council
January
18,
2011
The
Honorable
Darrell
E.
Issa
Chairman
Committeeon
Oversight
and
Government
Reform
2157Rayburn
House
Office
Building
Washington,
DC
20515
Dear
Mr.Chairman:
I
am
writing
in
response
to
your
December
8,
2010
letter
regarding
existing
and
proposed
federal
regulations
that
negatively
impact
the
economy,
the
investment
climate
in
the
United
States,
and
job
creation
and
maintenance.
You
have
raised
a
critical
issue;
one
that
is
becoming
more
widely
recognized
asreflected
by
President
Obama'scomments
in
this
morning's
Wall
Street
Journal
noting
his
interest
in
ensuring
that
regulations
do
not
createan
unreasonable
burden
on
U.S.businesses.
TheAmerican
Chemistry
Council
(ACC),
representing
America's
chemical
manufacturers,
believes
our
abilityas
anindustry
to
compete
in
a
growing
global
market,
drive
innovation
throughout
the
value
chain,
and
preserve
and
createthe
high-skilled,
high-paying
domesticmanufacturing
jobs
of
the
future
is
directlyrelated
to
our
abilityas
a
nation
tostrike
the
right
balancewith
respect
to
government
regulation.
We
share
your
concern
about
thepotential
impact
of
recent
and
new
regulatory
proposals
on
the
nascent
economic
recoveryand
American
jobs.
As
an
example,
ACC
has
estimated
thatjust
one
of
the
Environmental
Protection
Agency's
proposed
regulations
--
for
industrial
boilers
and
heaters
(the
so-called
"Boiler
MACT"
rules)
-
would
jeopardize
some
60,000
jobs
and
impose
capital
costs
on
the
order
of
$3.8
billion
in
the
chemical
industry
alone.
There
areseveralrecentregulations
that
deserve
scrutiny
becauseof
their
anticipated
consequences
,
including
the
"Boiler
MACT"
rules
mentionedaboveand
EPA's
rules
regulating
greenhouse
gasemissions
from
stationarysources.
But
theseindividual
rules
shouldbe
viewed
as
symptoms
of
alarger
problem
that
must
be
addressed
in
order
to
ensure
more
transparent,
fully-informedand
balanced
rulemakings
in
the
future.
Two
seriousroot
problems
exist
in
the
process
used
by
federal
regulatory
agencies
to
developand
evaluate
potential
new
regulations.
First,
thequality
and
scope
of
economic
assessments
to
measure
financial
and
employment
impacts
of
proposed
rules
must
be
improvedby
ensuring
that
thecosts
of
overlapping
rules
and
economy-wide
costsare
measured.
Second,
regulatory
agencies
must
establish
clear
standards
for
scientific
data
used
to
develop
rules
in
order
to
ensure
its
objectivity
and
credibility.
amerieanehemistry.com
700
2nd
street,
NE,
AVashington,
DC
20002
1
(202)
249.7000
1
 
We
believe
EPA's
economic
models
andapproach
to
evaluating
scientific
information
are
flawed
and
deserve
examinationby
the
committee
.
Addressing
these
twofundamentalproblems
will
help
ensure
thatrules
better
reflect
costs
and
benefits
and
will
provide
greater
clarity
about
thetrue
consequences
of
proposed
regulations.
Federal
agency
assessments
of
the
likely
economic
impacts
of
specific
proposed
rulesarc
importantdeterminants
of
the
valueof
regulatory
action.
Unfortunately,
the
assessments
vary
widely
in
quality,
and
the
assessment
process
itself
is
not
entirely
transparent.
Forexample,
the
Department
of
Commerce
has
reportedly
conducted
an
assessmentof
the
potential
job
implications
of
EPA's
proposed
Boiler
MACT
rules
thatdiffers
significantly
from
EPA's
own
assessment.Despite
requests
from
then-SenatorCarte
Goodwin;
Reps.
Upton
and
Whitfield
(attached);
and
Senators
Snowe,
Pryor,
Vitter
and
Begich
(attached),
the
Commerce
Department's
studyhas
not
been
publiclyreleased
and
therefore,
we
do
not
have
a
full
picture
ofwhat
thetrue
impactof
the
rules
is
likelyto
be.
Not
only
does
the
administration's
failureto
make
public
the
Commerce
Department's
studyprevent
affectedindustries
and
elected
officials
from
understanding
regulation's
consequences,
it
also
is
in
contradiction
to
its
stated
principles
of
transparency,
another
issue
that
we
would
encourage
the
Committee
to
examine.
We
note
that
EPA
has
asked
the
U.S.
Court
ofAppeals
for
the
District
of
Columbia
Circuit
for
more
time
to
review
and
assessthe
Boiler
MACT
rule,a
review
which
we
believe
is
warranted
given
the
economic
impacts
andincomplete
data
uponwhich
the
proposal
was
based.
As
the
Committee
is
nodoubt
aware,
Executive
Order
12866
requires
agencies
to
ensure
that
thebenefits
ofmajor
regulatory
actions
justify
their
costs.
In
addition,
the
Order
specificallyrequires
agencies
to
take
into
account
thecosts
associated
with
cumulative
regulations,
although
the
typical
agency
cost
and
benefit
assessmentdoes
not
comport
with
this
requirement.
Executive
Order12866
also
applies
to
significant
policy
andguidance
documents
that
may
have
cost
implicationsacross
the
economy,
according
to
a
March
4,
2009
memorandum
from
Peter
Orszag,
then
Director
of
the
Office
of
Management
and
Budget.
Yet
in
some
cases,
such
as
EPA's
Dioxin
Preliminary
Remediation
Goals,
noimpactassessment
has
been
conducted.
A
flawed
economic
model
leads
to
flawed
conclusions.
Forexample,
Administrator
Jackson
recently
asserted
that
increasedregulation
will
actuallycreate
jobs.
As
the
representative
of
a
highly
regulated
industry,
I
can
tell
you
that
the
rules
proposed
by
the
Environmental
Protection
Agency
in
the
past
two
years
will
put
tens
of
thousandsofhigh-payingmanufacturing
jobs
at
risk.
Any
economicmodel
that
comes
to
an
alternative
conclusionshouldbe
reexamined.
A
similar
concern
exists
with
respect
to
chemical
specific
risk
assessmentsandguidance
documents
that
do
not
reflect
the
best
available
science
-
and
which
in
turn
may
have
significant
economic
and
job
impacts.
In
ACC's
view,
it
is
critical
that
the
science
relied
on
in
agency
risk-based
decision-making
comport
with
the
higheststandards
of
quality,
reliability,
and
credibility.

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