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Letter Regarding Business Roundtable Priority Regulations

The Honorable Darrell Issa
Chairman, Committee on Oversight and Government Reform
2157 Rayburn House Office Building
Washington, DC 20515

The Honorable Jim Jordan
Chairman, Subcommittee on Regulatory Affairs, Stimulus Oversight and Government Spending
1524 Longworth House Office Building
Washington, DC 20515

Dear Chairman Issa and Chairman Jordan:

Thank you for your letter of May 16, 2012 and most importantly, for your diligent oversight of existing and proposed federal regulations that negatively impact jobs and the economy.

Business Roundtable (BRT) is an association of chief executive officers of leading U.S. companies with over $6 trillion in annual revenues and more than 14 million employees. Our companies generate an estimated $420 billion in sales for small and medium-sized businesses annually. BRT members comprise nearly a third of the total value of the U.S. stock market and invest more than $150 billion annually in research and development- nearly half of all private U.S. R&D spending.

BRT members have identified the costs and uncertainty associated with increasing federal regulation as a key barrier standing in the way of greater jobs creation. In fact, our member surveys consistently show that BRT members rank the regulatory climate as one of their most pressing concerns.

Under the leadership of Andrew Liveris, Chairman, President and CEO of The Dow Chemical Company and Chair, Business Roundtable Select Committee on Regulatory Reform, BRT reviewed the Administration’s regulatory agenda, assessed the potential economic costs of these anticipated regulations and discussed the regulatory landscape with BRT CEOs. As a result of a CEO survey completed early in 2012, BRT identified over 60 existing or pending regulations of concern to its members.

From this larger list of regulations, we identified eight regulations that emerged as areas of greatest concern. These regulations fall into three broad categories: environment; implementation of the Patient Protection and Affordable Care Act, including imposition of new health care taxes and the definition of full-time and part-time employees; and implementation of the Dodd-Frank Wall Street Reform and Consumer Protection Act, including implementation of the Volcker Rule, regulation of derivates and conflict minerals disclosure. Taken together, these proposed or anticipated regulations will affect virtually every company operating in the United States and are likely to impose many billions of dollars of new annual regulatory costs on the U.S. economy. I am enclosing both the high-priority list of eight regulations we identified and the more inclusive list of more than 60 regulations for your review.

I also am enclosing two studies we completed recently on regulatory reform (Achieving Smarter Regulation (September, 2011)) and permitting reform (Permitting Jobs and Business Investment: Streamlining the Federal Permitting Process (April, 2012)). Both studies contain our recommendations as to how to improve the regulatory process and streamline the federal permitting process. Both studies are available electronically on the Business Roundtable’s web site: I also am enclosing Taking Action for America: A CEO Plan for Jobs and Economic Growth (April, 2012) which contains a chapter highlighting the importance of reducing regulatory burdens for jobs creation.

Thank for your interest and leadership on this important issue. Please feel free to contact me if you have any questions or if we can be of assistance to you in this endeavor.


John Engler

C: The Honorable Elijah Cummings, Ranking Minority Member
The Honorable Dennis Kucinich, Ranking Minority Member, Subcommittee on Regulatory Affairs, Stimulus Oversight and Government Spending