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Letters / Testimonies / Presentations

The Honorable John Thune 
United States Senate 
Washington, DC 20510 
The Honorable Pete Olson

On May 9, 2014, the National Association of Manufacturers and the U.S. Chamber of Commerce (“the Chamber”)1 co-signed comments in response to the Environmental Protection Agency’s Proposed Standards of Performance for Greenhouse Gas Emissions from New Stationary Sources: Electric Utility Generating Units. The NAM and the Chamber respectfully request the opportunity to submit this letter into the docket in order to amend their comments with regards to the EPA’s Best System of Emission Reduction (BSER) analysis for Natural Gas Combined Cycle (NGCC) turbines. As described below, the NAM and the Chamber offer two points for consideration in the final rule.

The U.S. Chamber of Commerce, the world’s largest business federation representing the interests of more than three million businesses of all sizes, sectors, and regions, as well as state and local chambers and industry associations, and dedicated to promoting, protecting, and defending America’s free enterprise system, strongly supports H.R. 5078, the “Waters of the United States Regulatory Overreach Protection Act.” This bipartisan bill would uphold the federal-state partnership to regulate the nation’s waters by preserving existing rights and responsibilities with respect to ”waters of the United States” under the Clean Water Act.

America’s Outer Continental Shelf (OCS) is one of its greatest single strategic assets. For decades, across multiple administrations, this asset has been underutilized to the nation’s detriment. As BOEM initiates this process to develop the 2017-2022 Leasing Program, it is important that the entire OCS be considered for leasing. BOEM should continue to include existing areas in Alaska and the Gulf of Mexico currently available for leasing under the current 5 Year Program and should also make new areas in the Atlantic, Pacific, and Eastern Gulf of Mexico available for leasing.

We urge BOEM to evaluate and consider all planning areas and not prematurely eliminate any areas with potential resources at this stage of the process. Preemptively removing any areas at this initial stage would be inconsistent with the process established in the Outer Continental Shelf Lands Act and would represent a tremendous missed opportunity. Such an action would be premature and given the long lead times necessary for offshore development, could undermine U.S. energy security for decades to come.

The Chamber has long been clear in its view that the Clean Air Act (CAA) is not the appropriate vehicle to regulate greenhouse gases (GHG), and is poorly designed for such a task. We believe EPA’s proposed rule illustrates this incompatibility, as it is fundamentally inconsistent with numerous practical, technical, and legal aspects of America’s electricity system. Nonetheless, we appreciate this opportunity to communicate specific concerns regarding the rulemaking.