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Business Roundtable Letter to Chairman Issa - January 7, 2011

Business Roundtable Letter to Chairman Issa - January 7, 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 businesses, associations, and think tanks 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 businesses, associations, and think tanks 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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04/06/2012

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1717 Rhode Island Avenue, NWTelephone202.872.1260Suite 800Facsimile202.466.3509Washington, DC 20036Websitebusinessroundtable.org
January 7, 2011The Honorable Darrell E. IssaChairman, Committee on Oversight and Government ReformUnited States House of Representatives2157 Rayburn House Office BuildingWashington, DC 20515Dear Mr. Chairman:Thank you for your letter requesting Business Roundtable’s views on existingand proposed regulations that negatively impact the economy and themaintenance and creation of jobs. We very much appreciate the opportunityto provide input on your Committee’s important work in this area.Business Roundtable long has been concerned about the costs and burdensimposed by the significant growth in government regulations. Regulatoryburdens facing U.S. business are rapidly accelerating as a consequence of legislation passed over the previous two years that must now beimplemented and by decisions made by regulatory agencies to aggressivelyexpand their regulatory reach. This regulatory tsunami, occurring hastily andat a time when the U.S. economy is struggling to emerge from a deeprecession, is hindering investment and job creation. As Ivan Seidenberg,Chairman of Business Roundtable, noted in a June 21, 2010 letter to thenOMB Director Orszag, “[v]irtually every new regulation has an impact onrecovery, competitiveness and job creation. Often that impact is negative.On an individual basis, most businesses can cope with each new regulation.But the collective impact on the economy is enormous, and often harmful.”http://businessroundtable.org/uploads/hearings-letters/downloads/20100621_Letter_to_OMB_Director_Orszag_from_BRT_and_BC_with_Attachments.pdf  Regulations are like hidden taxes. They impose costs that are not readilyapparent but are real. Just as the public must pay for government spendingprograms through higher taxes, they must also pay a high price forregulations – as customers, employees and stockholders. The soaring costsof regulation stifle productivity, wages and economic growth. Regulationsalso undermine jobs and international competitiveness. Poorly designed andimplemented regulations impose costs much greater than their benefits anddampen economic activity.
 
Ivan G. SeidenbergVerizon CommunicationsChairmanKenneth I. ChenaultAmerican Express CompanyVice ChairmanEdward B. Rust, Jr.State Farm InsuranceCompaniesVice ChairmanLarry D. BurtonExecutive DirectorJohanna I. SchneiderExecutive DirectorExternal Relations
 
January 7, 2011Page 2In 1994, Business Roundtable issued
Toward Smarter Regulation
, which identified growing,poorly designed regulations in the environmental, health and safety areas as significant costfactors to business and our economy and proposed a framework for smarter, more effectiveregulation. The observations and recommendations contained in this document are just asrelevant today as they were in 1994. In particular, Business Roundtable noted that regulationsfrequently are not well-coordinated among agencies and that the overall cumulative impact of regulations on our economy is not considered or well-understood. Sadly, little progress seemsto have been made in the intervening years to establish a more sensible regulatory regime. Iam enclosing a copy of this report for your review.While burdensome regulations affect many areas of our economy, Business Roundtablemembers have identified three major areas of greatest concern: environmental regulation,financial reform, and health care and retirement benefits. In these areas, the potentialregulatory costs and the sheer number of regulations with which business must comply posesignificant challenges. Issues with specific current or proposed regulations within these broadcategories are listed in the enclosed attachment with a brief description of our concerns. Insome cases, particularly with respect to financial reform, proposed regulations have not yetbeen issued.We would be happy to discuss any of these issues in further detail with you or your staff orprovide you with additional information.Thank you again for giving us the opportunity to share our views and for your personal interestin identifying regulations that reduce jobs and economic growth while generating little or nobenefits.Sincerely,Larry D. BurtonAttachments (2)C: The Honorable Elijah Cummings, Ranking Minority MemberThe Honorable Edolphus Towns
 
 
Business Roundtable Policy Positions onExisting and Proposed RegulationsEnvironmental Regulations
The Environmental Protection Agency has unveiled an aggressive Clean Air Act and Clean WaterAct regulatory agenda that, cumulatively, threatens a significant number of electric powerplants and industrial boilers. Most of these regulations are scheduled to be finalized over thenext two years.
NESHAPS for Utility Boilers:
Section 112 of the Clean Air Act (CAA) requires EPA to establishNational Emissions Standards for Hazardous Air Pollutants (NESHAPS) for major (and area)sources of hazardous air pollutants (HAPS) that are subject to regulation. Pursuant to aconsent decree approved by the U.S. District Court for the District of Columbia, EPA isrequired to issue a proposed rule for the regulation of HAPS emissions from coal and oil-fired utility boilers by March 16, 2011 and to finalize the rule by November 16, 2011. It isanticipated that any final rule will require the installation of costly new control equipmentat virtually every existing coal-fired utility boiler. In addition, it is not clear if technology isavailable to meet the anticipated standards if EPA does not use its authority to sub-categorize or tailor its regulations depending on coal types. Regardless of the final form of the rule, it is anticipated that significant coal generating capacity will be at risk for closure asa consequence of the rule.
NESHAPS for Industrial, Commercial and Institutional Boilers:
In two separate rulemakingproceedings, EPA proposed rules in April 2010 that would reduce HAAPS emissions fromexisting and new industrial, commercial and institutional boilers and process heaters locatedat major sources and reduce HAPS emissions from existing and new industrial, commercialand institutional boilers located at area sources. On December 7, 2010, EPA petitioned thefederal court for an extension of the deadline for issuance of a final rule to April 13, 2012.EPA argued that it needed additional time to review over 4800 public comments filed in therulemaking proceedings. In addition, EPA indicated that the final rules would reflect materialchanges from the proposed rules. According to an EPA Fact Sheet on the NOPR for majorsources, there are approximately 13,555 boiler and process heaters at major sources in theU.S. The Fact Sheet estimates that the total national capital cost for a final major source rulewould be approximately $9.5 billion in 2012, and the total national annual cost would be$2.9 billion in 2013. EPA also estimated that for area sources, there are approximately183,000 boilers at 92,000 facilities. Most of these area sources are owned and operated bysmall entities. EPA estimates that the total national capital cost for a final area source rulewould be approximately $2.5 billion, and the total national annual cost would be $1.0 billion.

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