The Honorable Harry Reid
Majority Leader
United States Senate
Washington, D.C. 20510

The Honorable Mitch McConnell
Minority Leader
United States Senate
Washington, D.C. 20510

Dear Majority Leader Reid and Minority Leader McConnell:

The Environmental Protection Agency (EPA) has finalized or soon will be finalizing several regulations under the Clean Air Act addressing greenhouse gas emissions from power plants and major industrial sources. While these regulations will be challenged in the courts, the lack of a clear regulatory roadmap for these and future regulations affecting greenhouse gas emissions has created additional investment uncertainty for large portions of the utility and manufacturing sectors of our economy.

EPA and most industry participants agree that the Clean Air Act is not well-designed to regulate ubiquitous pollutants like carbon dioxide emissions, whose impact is global, not local or regional. Congress never envisioned that the Clean Air Act would be used to regulate carbon dioxide emissions and EPA has struggled mightily to tailor a regulatory program for greenhouse gas emissions under the Clean Air Act that makes sense. For this reason, Business Roundtable long has advocated Congressional action and international cooperation to address the climate issue. Without comprehensive legislation and global agreements encompassing other major emitting nations, EPA regulations only will increase energy costs for U.S. companies, thereby reducing their competitiveness in international markets, and drive up consumer costs, while doing little to reduce global concentrations of greenhouse gas emissions.

Unfortunately, it does not appear that Congress will act on comprehensive energy and climate legislation this year. It does have time to enact legislation that would delay the effectiveness of EPA regulations for up to two years, as proposed by Senator Rockefeller, until the next Congress has the opportunity to address the climate issue legislatively. We urge the Senate to do so. A two year delay will give Congress and the Administration time to work with a variety of stakeholders to develop new approaches, such as those advocated by Business Roundtable in its Balancing Act and Unfinished Business studies, focusing on new technologies and efficiency, as promising ways of addressing the climate challenge. A focus on developing needed technologies not only will help reduce greenhouse gas emissions but it will also help develop the industries of tomorrow and result in a more secure energy future.

A vote to delay pending EPA greenhouse gas emissions will provide Congress the opportunity to develop sound policy approaches to address greenhouse gas emissions, rather than default to a poorly designed EPA regulatory approach that is likely to further damage U.S. competitiveness, drive up consumer costs and make an immaterial contribution to reducing global greenhouse gas concentrations. Business Roundtable respectfully urges a favorable vote on legislation that would delay the effective date of EPA regulatory action with respect to greenhouse gas emissions.

Sincerely,

Michael G. Morris
Chairman, President and CEO
American Electric Power, Inc.
Chairman, Sustainable Growth Initiative
Business Roundtable

C: United States Senate